ML20072G531
| ML20072G531 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 06/24/1983 |
| From: | Furse M, Gallo J COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8306280535 | |
| Download: ML20072G531 (39) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION x; ?A ff '
- "' s BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ' -
In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454 OL
) 50-455 OL (Byron Nuclear Power Station, )
Units 1 & 2) )
COMMONWEALTH EDISON COMPANY'S PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW REGARDING LIQUID PATHWAY i
1 June 24, 1983 MA O!hkS4 L Ts03
TABLE OF CONTENTS OPINION F. Rockford League of Women Voters' (League) and DAARE/ SAFE Consolidated Contentions 39 and 109 -- Liquid Pathway . . . . . . . . . . 1 Applicable Law . . . . ... . . . . . . . . . . . . 2 Byron Site Characterization . . . . . . . . . . . 4 Postulated Boron Recycle Holdup Tank Rupture . . . 13 Assessment of Environmental Risk . . . . . . . . . 14 Conclusions . . . . . . . . . . . . . . . . . . . 17 FINDINGS OF FACT III. CONTENTIONS F. Rockford League of Women Voters' (League) and DAARE/ SAFE Consolidated Contentions 39 and 109 -- Liquid Pathway . . . . . . . . . . 1 Contention as Litigated. . . . . . . . . . . . . . 1 Witnesses. . . . . . . . . . . . . . . . . . . . . 1 Byron Site Investigation . . . . . . . . . . . . . 2 Byron Site Characterization. . . . . . . . . . . . 4 Calculation of Groundwater Velocities and Travel Times . . . . . . . . . . . . . . . . . . 7 Grouting . . . . . . . . . . . . . . . . . . . . . 9 Postulated Boron Recycle Holdup Tank Rupture . . . 10 Assessment of Environmental Risk . . . . . . . . . 11
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454 OL
) 50-455 OL (Byron Nuclear Power Station, )
Units 1 & 2) )
COMMONWEALTH EDISON COMPANY'S PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW REGARDING LIQUID PATHWAY
- OPINION II. CONTENTIONS F. Rockford League of Women Voters' (League) and DAARE/ SAFE Consolidated Contentions 39 and 109 -- Liquid Pathway Consolidated Contentions 39 and 109 allege that the ground-water system underlying the Byron site has not been adequately characterized, and that, therefore, it is impossible to deter-l mine the radiation hazards and environmental consequences of radionuclide releases to this system.
l These proposed findings are presented in the form of a partial initial decision which addresses one of the eight litigated issues, specifically, Liquid Pathway. The proposed findings on the other seven issues have been or will be sub-mitted in accordance with the schedule stated in the "Proced-ural History" section of " Commonwealth Edison Company's Pro-posed Findings of Fact and Conclusions of Law Regarding Seis- '.
mology, Waterhammer, and ALARA" filed on May 31, 1982, into which this document is incorporated.
A major issue to be decided by the Board, therefore, is whether the Byron site groundwater system has been adequately characterized. The characterization issue may for additional clarity be divided into two subissues: (1) whether a suffi-ciently thorough investigation using proper methods was con-ducted, (2) assuming an adequate site investigation, whether the results of the investigation were correctly interpreted.
The purpose of an adequate site characterization is, inter alia, to facilitate the assessment of consequences from postulated radionuclide releases to the groundwater system. A second major issue, then, is whether the likely consequences of postulated radionuclide releases have been adequately assessed.
Applicable Law Prior to issuance of an operating license, the Commis-sion must find, inter alia, that the Byron Station has been constructed in acordance with its rules and regulations, and that reasonable assurance exists that the activities authorized by the operating license can be conducted without endangering the health and safety of the public. 10 C.F.R. $$ 50.57(a)(1) and 50.57(a)(3). These regulations are implemented with respect to the evaluation of design basis accidents by the provisions of 10 C.F.R. Part 100.
Generally, the acceptability of the radiological consequences of design basis accidents is governed by the guideline values set forth in 10 C.F.R. 5 100.11. (See also section 15 of the NRC Standard Review Plan, NUREG-0800, Rev. 2,
July 1981). These guideline values, however, are not appiied with respect to the evaluation of postulated radioactive re-leases to the groundwater due to liquid-containing tank fail-ures. Instead, the NRC Staff uses 10 C.F.R. Part 20, Appen-dix B, Table II, Column 2 as an acceptance criterion. (Id. at section 15.7.3.)
The accident evaluation of the postulated tank fail-ure, in this case the boron recycle holdup tank, must show that the calculated releases of radionuclides are within the concen-tration limits of Table II. Compliance with this radiation standard warrants a finding of adequate protection to the health and safety of the public as a matter of law. Citizens for Safe Power, Inc. v. Nuclear Regulatory Commission, 524 F.2d i
1291, 1299 (D.C. Cir. 1975).
In addition, the National Environmental Policy Act (NEPA), 42 U.S.C. $$4321 et seg, requires that all agencies of the federal government prepare detailed environmental state-ments on major federal actions significantly affecting the-quality of the human environment. The adequacy of the analysis contained in the environmental statement is determined by a rule of reason. Columbia Basin Land Protection Assoc. v.
! Schlesinger, 643 F.2d 585, 592 (9th Cir. 1981). The environ-ment statement mu'st contain a reasonably thorough evaluation of the significant aspects of the probable environmental conse-quences of the action being considered. Id.
l l With respect to an application for an operating l license for a nuclear power plant, 10 C.F.R. Part 51 implements i
i
the policies of NEPA by requiring the NRC Staff to submit a Final Environmental Statement (FES) which thoroughly assesses and evaluates the environmental consequences of the proposed action. With respect to the liquid pathway aspects of this analysis, information contained in the FES, as supplemented by hearing testimony, must provide an adequate evaluation of the environmental consequences of release of radionuclides to the groundwater system.
The Board must, therefore, address two separate issues with respect to an evaluation of consequences of radio-nuclide releases to the groundwater system underlying the Byron site: (1) whether the investigation of the groundwater system was sufficient to permit a determination that reasonable assur-ance exists that even in the event of the most severe but credible design basis accident, the calculated release of radionuclides to the groundwater system will not exceed the numerical limits specified in 10 C.F.R. Part 20, Appendix B, Table II, Column 2; and (2) whether the Final Environmental Statement, compiled and submitted by the NRC Staff, as supple-mented by testimony in this proceeding, provides an adequate evaluation.of the environmental consequences of the release of radionuclides to the groundwater system.
Byron Site Characterization The character of rock formations underlying a nuclear power plant site determine to a great extent the velocity with which contamination released to the groundwater system will
travel to a source of public exposure, e.g., drinking water.
(Finding 309.) It is, therefore, very important that both the hydrogeologic and geologic aspects of the underlying bedrock be understood.
Mr. Lawrence Holish, the head of the Geotechnical Division at Sargeant & Lundy, testifying for the Applicant, described the extensive site investigation undertaken for Byron. This investigation included more than four miles of geophysical surveys; the drilling, sampling, and selective water pressure testing of 154 borings of the foundation bedrock; the measurement of geologic features over the surface of the site area; the installation and measurement of observation wells throughout the site and adjoining properties; the detailed measurement and mapping of exposed bedrock features found in structure excavations; and the monitoring of the behavior of structure foundations. (Findings 311-315).
The Byron site investigation was conducted in accord-ance with Sections 2.4 and 2.5 of Regulatory Guide 1.70, which was in effect at the time of the investigation. Thereafter, the site investigation methodology used for Byron was also determined to be consistent with Regulatory Guide 1.138, pub-lished in 1978, and Regulatory Guide 1.132, published in 1979.
(Finding 316.) Moreover, neither the NRC Staff nor the Inter-venors offered any criticism of the site investigation method-ology. (Finding 317.) The Board finds that the Byron site investigation was adequate to determine the hydrogeologic and geologic characteristics of the Byron site.
/
The four most significant hydrogeologic units under-lying the Byron site are the glacial drift, the Galena-Platte-ville dolomites, the sandstone units of the Cambrian-Ordivician aquifer, and the Mount Simon Sandstone. (Finding 319.) However, only the glacial drift and the upper formations of the Galena-Platteville dolomites are pertinent to the calculation of groundwater travel times at the Byron site. This is because within the Byron site area groundwater in the Galena-Platteville dolomites is perched on the Harmony Hill Shale Member of the Glenwood formation. Since the Glenwood formation has very low permeability, it acts as a hydraulic barrier to the lower aquifers, which supply most of the region's drinking water.
(Findings 323-324.)
The Dunleith formation, located within the Galena-Platteville dolomites, provides the foundation for all Byron safety-related structures. (Finding 026.) Results of bedrock borings indicate that the Dunleith formation is fractured, jointed and thin bedded but that no large openings along joints or bedding planes exist. (Finding 326.) At the Byron site, the most highly fractured portion of the bedrock has been excavated and the reactor basemat is resting on essentially fresh and stable bedrock. (Findings 327-328.)
The only significant area of disagreement between the Applicant and the NRC Staff, on the one hand, and the Intervenors, on the other hand, concerns the characterization of the fractures running through the bedrock underlying the Byron site. Both the Applicant and the NRC Staff have concluded that it is
appropriate to characterize the bedrock underlying the Byron .
site as equivalent to porous media. The Darcy equation, which is applicable only in the case of porous media or its equiva-lent, was used by the Applicant and the NRC Staff to calculate groundwater velocities and travel times. (Finding 332-337.)
The conclusions of the Applicant and the NRC Staff are based on the results of the Byron site investigation, which measured the frequency of jointing in the bedrock, the aperture size of the joints, and the orientation and distribution of the joints. These measurements indicate that it is appropriate to characterize the fractured bedrock underlying the Byron site as porous media. (Finding 330.) Moreover, contaminant migration studies have been performed which have empirically measured travel times in extensively fractured rock, and these measured times have been consistent with times calculated using Darcy's equation and assuming porous media. (Codell, Tr. 6581-83; Holish, Tr. 6768-69.)
Because he feels that the fractures underlying the Byron site are not only extensive but also continuous over long distances, Dr. Bernard Wood testified for the Intervenors that the characterization of porous media underlying the Byron site and the use of the Darcy equation to calculate travel times are inappropriate. While it is true that the existence of contin-uous fractures could effectively invalidate such a characteri-l zation, and thus the use of the Darcy equation, (Holish, Tr.
6766; Wood, Tr. 6942.), results of. the site investigation indicate that fractures underlying the Byron site area are not l
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, continuous over long distances. (Staley, NRC Staff Prepared .
- Testimony at 14, ff. Tr. 6649; Codell, Tr. 6644; Staley, Tr.
j 6652, 6655; Holish, Tr. 6766.)
.Dr. Wood seems to place little weight on the Appli-4 cant's site investigation, relying instead on a study of cya-i _ nide dumping at the nearly Byron salvage yard which occurred between 1969 and 1972. The study is entitled " Contribution of i
Surficial Deposits, Bedrock and Industrial Waste to Certain Trace Elements in Groundwater," and is authored by Gilkerson, Cartwright, Follmer and Johnson-of the Illinois State Geologi-cal Survey. (Wood, Tr. 6885.) The study was performed during 1974 and 1975 and cyanide contamination was found in wells 1.2 and 1.8 miles from the dump site. According to Dr. Wood, this implies groundwater velocities of at least 8 feet per day.
(Wood, Intervenor's Prepared Testimony at 5, ff. Tr. 6879.)
Dr. Wood derived this figure by dividing a travel distance, i
e.g., 1.8 miles, by the number of days in the travel period,
, e.g., four years. (Wood, Tr. 6889.) Dr. Wood testified that this transport rate proves incorrect the much lower velocities calculated by Applicant and the NRC Staff, and by implication demonstrates that it is erroneous to consider the underlying bedrock as equivalent to porous media. (Wood, Tr. 6891-6900.)
l Both Applicant and the NRC Staff disagree sharply with Dr. Wood. They urge that the Gilkerson study is not a
! reliable data source for drawing conclusions concerning the i
j characterization of the bedrock underlying the Byron site.
(Codell, Tr. 6605, Staley, Tr. 6692; Holish, Tr. 6746-49.) The I
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NRC Staff testified that the study provides no clear indication how the cyanide was transported, whether by surface flow, groundwater, or perhaps the wind. (Staley, Tr. 6692.) The Staff further testified that since the precise dumping locations are not known, it is impossible even to calculate the travel distance. (Id.)
Dr. Wood admitted that the salvage yard data contained in the Gilkerson study is " pretty thin." (Wood, Tr. 6883.) He further testified that significant surface flow could not be ruled out (Wood, Tr. 6937, 6939), that he is not sufficiently familiar with the salvage yard terrain to comment on the possi-bility of surface flow (Wood Tr. 6939.), and that the establish-ment of surface flow as the dominant transport factor would tend to invalidate his conclusions. (Wood, Tr. 6901.) In fact, there is strong evidence to suggest that much of the waste transport was actually by surface water. Several lagoons containing contaminated water at the salvage yard site were broken, releasing large quantities of contaminants to surface drainageways. (Codell, NRC Staff Prepared Testimony at 17-18, ff. Tr. 6649.) Moreover, cattle died from cyanide poisoning as a result of drinking from contaminated pools of water downstream from the dumping site, thereby supporting the hypothesis that the cyanide contamination got to the pools by surface migration.
(Wood, Tr. 6902.)
The NRC Staff testified that geologic conditions at the Byron salvage yard are " radically different" from those at the Byron plant. The salvage yard is very steep, and much of
m the cyanide was located where it could flow directly into the stream surface water-ground water network. -The Byron site does not have these features. (Codell, Tr. 6602, 6603.) In addi-tion, the Byron site is located on a much harder and more resilient bedrock. (Holish, Tr. 6749.) Dr. Wood admitted that the bedrock under the salvage yard is probably more fractured than the bedrock under the Byron plant site. (Wood, Tr. 6911.)
Indeed, he testified to a discussion with Dr. Gilkerson, one of the authors of the cyanide migration study, in which Dr. Gilkerson stated his belief that the groundwater velocities under the plant site are less than those at the salvage yard, and also that the fracturing under the plant site is not as extensive.
(Wood, Tr. 6944-45.)
To further emphasize his point that a fracture can under certain circumstances conduct water very rapidly, Dr. Wood postulated a perfectly straight continuous fracture with a 1/40 inch diameter. (Wood, Intervenor's Prepared Testimony at 5-6, ff. Tr. 6879.) By ignoring the potential for friction losses, bend losses, and other factors likely to reduce groundwater velocities, he was able to calculate transport velocities of up to 3000 feet per day. (Id.) The NRC Staff testified at length that these calculations were extremely unrealistic. (Staley, Tr. 6697-6705.) 'On cross examination, Dr. Wood admitted that his assumptions were unrealistic. (Wood, Tr. 6909-10.) Dr. Wood eventually expressed regret that he had included this calcula-tion in his prepared testimony. (Wood, Tr. 6940.) The Board finds that Dr. Wood's postulation of a perfectly straight
continuous fracture is incredible and does not weigh against Applicant's detailed site characterization.
Dr. Wood testified that groundwater velocities through a non-porous media, as in his opinion exists beneath the Byron site, can be determined unequivocally only by means of a tracer study. (Wood, Tr. 6919.) He also proposes that detailed modeling be performed of the Byron site fissure system. (Wood Intervenors' Prepared Testimony at 8, ff. Tr. 6879.) The NRC Staff testified that such a modeling effort would be highly impractical and not reliable. (Staley, Tr. 6596.) In addition to the possible long time needed to complete a tracer study, the tracer method is difficult and not well known by many engineers. (Holish, Tr. 6768, 6842, 6920.) Finally, Dr. Wood conceded that he is not aware of tracer studies having previ-ously been performed at any nuclear plant sites. (Wood, Tr.
6921-22.)
The Board finds that Applicant and the NRC Staff correctly characterized the bedrock underlying the Byron site as equivalent to porous media. The results of the Byron site investigation are sufficient to warrant this characterization.
Conversely, the Board finds unwarranted Dr. Wood's reliance on the cyanide migration study. The evidence clearly indicates
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the likelihood th'at transport mechanisms other than groundwater flow were involved. Thus, Dr. Wood's calculated travel time calculations cannot be considered to represent reliably the travel time associated with groundwater at the salvage yard.
Nor are his calculations reliable for the purpose of drawing
~ inferences concerning the hydrogeologic characterization of the bedrock underlying the Byron site. In addition, since there are significant geologic differences between the plant site and the salvage yard site, the relevancy of the salvage yard data, even assuming its accuracy, is highly questionable.
In view of the Board's finding that the bedrock underlying the Byron site is properly characterized as the equivalent of porous media, travel times may be properly deter-mined by the use of the Darcy equation. As we understand Dr. Wood's position, his endorsement of tracer studies and fissure system modeling stemmed from his belief that the bed-rock was non-porous in character. Thus, the Board's contrary i ,
finding on this point makes the performance of the tracer study and modeling unnecessary.
The Board also observes that all major solution enlarged joints, bedding planes and other planar features of the Dunleith formation bedrock underlying the Byron site have been filled and sealed by pressure rock cement grouting.
(Finding 338.) The grouted bedrock beneath the Byron site has i a permeability about a factor of 10 less than the ungrouted bedrock. As a result, the travel time of postulated radio-l active liquids threugh the groundwater system underlying the Byron site has be'en increased by several months. (Finding 339.)
The travel times calculated by both the Applicant and the NRC Staff conservatively ignore the effects of the grouting.
(Finding 340.)
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Postulated Boron Recycle Holdup Tank Rupture To determine whether the potential release of radio-active material to the groundwater system underlying the Byron ,
site endangers the health and safety of the public, the NRC Staff required the Applicant to analyze such a release as a design basis accident. The postulated accident involves the rupture of a 125,000 gallon boron recycle holdup (BRH) tank, located in the auxiliary building. The accident assun.es that the 125,000 gallon tank is full, ruptures, and that its radio-active contents percolate onto the foundation bedrock through a
.1 inch wide crack along the entire width of the auxiliary building floor. (Finding 341.) Thereafter, the radioactive fluid would mix with the groundwater, resulting in dilution of the radioactive concentration by a factor of 2,200. The travel time of the contaminated flow from the point of release to the nearest well would be approximately 30 years. By this time, the vast majority of the radionuclides released by the accident would decay to negligible levels. Moreover, those radionuclides which would not decay to negligible levels would, due to the dilution of the contaminated liquid by the groundwater, be well within limits proscribed by 10 CFR Part 20, Appendix B, Table II, Column 2. (Findi,ngs 342-343.) The Board finds that the conse-quences of the postulated ERH tank rupture do not endanger the health and safety of the public.
Assessment of Environmental Risk Among the accident conditions cvaluated in the Byron FES is the risk associated with the accidental release of radioactive materials to the groundwater. The principal con-tributor to this particular risk is the core melt accident.
Penetration of the reactor basemat by the molten core results in the release of core debris to the strata beneath the plant.
The soluble radionuclides in this debris can be leached and transported with groundwater to downgradient domestic wells or to surface water bodies.
The FES evaluation of the liquid pathway risk relies upon a detailed analysis of risk for generic nuclear sites presented in the Liquid Pathway Generic Study (LPGS). The LPGS concludes that the risk from the liquid pathway for generic sites is very small. To evaluate the Byron liquid pathway risk, drinking water use, fish catch and shoreline use for the Byron site were compared with those of a generic small river site which was considered in the LPGS. Based on this compari-son, and also based on several highly conservative assumptions, the NRC Staff concluded in the FES that the risks from the liquid pathway at the Byron Station are acceptably small.
(Findings 344, 347-351.) The Board agrees with this judgment.
The most significant conservatisms in the FES involve the Staff's assumptions concerning the interaction of the molten core with the concrete basemat and the nature of the source term discharged to the groundwater. Every postulated core melt event was assumed to result in containment basemat
Assessment of Environmental Risk Among the accident conditions evaluated in the Byron FES is the risk associated with the accidental release of radioactive materials to the groundwater. The principal con-tributor to this particular risk is the core melt accident.
Penetration of the reactor basemat by the molten core results in the release of core debris to the strata beneath the plant.
The soluble radionuclides in this debris can be leached and transported with groundwater to downgradient domestic wells or to surface water bodies. -
The FES evaluation of the liquid pathway risk relies upon a detailed analysis of risk for generic nuclear sites presented in the Liquid Pathway Generic Study (LPGS). The LPGS concludes that the risk from the liquid pathway for generic sites is very small. To evaluate the Byron liquid pathway risk, drinking water use, fish catch and shoreline use for the Byron site were compared with those of a generic small river site vTich was considered in the LPGS. Based on this compari-son, and also based on several highly conservative assumptions, the NRC Staff concluded in the FES that the risks from the liquid pathway at the Byron Station are acceptably small.
(Findings 344, 347-351.) The Board agrees with this judgment.
The most significant conservatisms in the FES involve the Staff's assumptions concerning the interaction of the molten core with the concrete basemat and the nature of the source term discharged to the groundwater. Every postulated core melt event was assumed to result in containment basemat
penetration with a subsequent groundwater release, while in fact the vast majority of postulated core melt events would not result in containment basemat penetration. (Finding 352.)
Additionally, the Staff used the LPGS source term, which assumes that highly contaminated sump water will follow the molten core through the penetrated basemat. The presence of such sump water following basemat penetration increases the source term by a factor of 100 to 1,000. (Finding 353.)
At Byron, however, the sump water source term can be eliminated. Mr. George C. Klopp, on behalf of the Applicant, testified quite extensively that basemat penetration would not occur with significant sump water present because the sump water would act as a coolant. Conversely, if a molten core reached a temperature sufficient to ablate concrete, sump water would not be discharged to the groundwater. ' ristead, the water would flash to steam as the ablating reaction between the molten core and the concrete was occurring, and significant amounts of radionuclides, including all volatiles and all noble gasses would be released to the atmosphere through the failed containment structure. For these reasons, the Board agrees with Applicant's testimony that the source term used in the Byron FES is overstated by a factor of 100 to 1,000. (Findings 354, 355.)
The assessment in the FES of the Byron-specific consequences of a core melt accident is based on a travel time of radioactive contaminants consistent with the hydrogeology of the Byron site. The NRC Staff relied on pumping test data 1 .__ . _ _ _ _ . _ _ _ _
initially presented in the Applicant's Final Safety Analysis Report (FSAR) to calculate a travel time to the nearest ground-water source of 24.4 years. (Finding 346.) Recent information has shown that the FSAR pumping test data is not valid. How-ever, new data submitted by the Applicant indicates that the 24.4 year travel time is extremely conservative. Rather than modify the FES to reflect the much longer travel time generated by the new data, the NRC Staff has continued to rely on 24.4 years in the FES as a highly conservative travel time estimate.
(Finding 347.) The Applicant, using the new data and assuming no sump water source term, calculated a travel time to the nearest well of approximately 92 years. (Finding 358.)
Both travel times provide ample opportunity to imple-ment interdiction measures. Two general methods of interdic-tion could be implemented in the event of a core melt release.
First, grouting could be performed to contain the radioactive liquid and, thereafter, the liquid could be pumped out of the contained area. Wells could be drilled as a second method of interdiction. The radioactive groundwater would seep into the wells, be pumped to the surface and disposed of as liquid waste. Both methods involve routine engineering concepts and the applicant has experience in certain interdiction techniques (Findings 359-360.)
The Board finds that the NRC Staff's evaluation in the FES of the liquid pathway task at the Byron site is highly conservative. The Board further finds that the FES, as supple-mented by the testimony of the NRC Staff, contains adequate
information to permit an evaluation of the environmental conse-quences from radionuclide releases to the liquid pathway.
These consequences are acceptably small.
Conclusions The Board concludes that the Applicant has performed an adequate investigation of the Byron site, that the site was thereafter adequately characterized, and that the Applicant's evaluation of the design basis accident, a failure of a boron recycle holdup tank, demonstrates that the radionuclide releases will not exceed the concentration limits specified in 10 C.F.R. Part 20. Accordingly, the Board concludes that such radio-nuclide releases to the groundwater system underlying the Byron site will not endanger the health and safety of the public.
The Board further concludes that the FES, as supple-mented by testimony in this proceeding, contains an adequate evaluation of the environmental consequences of release of radioactive materials to the groundwater system from a core melt accident. These consequences are acceptably small. Based upon the foregoing conclusions, Consolidated Contentions 39 and 109 are dismissed.
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FINDINGS OF FACT III. CONTENTIONS F. Rockford League of Women Voters' (League) and DAARE/ SAFE Consolidated Contentions 39 and 109 -- Liquid Pathway 307. Consolidated Contentions 39 and 109, as liti-gated, provide:
Since the ground water system underlying the Byron site has not been characterized adequately,'the consequences of radio-nuclide releases to the underlying aquifer cannot be predicted with confidence. In consequence, no proper NEPA analysis of this important subject can be made. In addition, as a result of this serious and unresolved problem the findings required by 10 C.F.R. 50.57(a) (3)(i), 50.57(a)(6), and 10 C.F.R. 50.34(b)(4) cannot be adequately made.
308. To address the contention, Applicant presented the testimony of three witnesses. Mr. Lawrence Holish, of l
l Sargent & Lundy, described the measures taken to characterize the site geology and hydrogeology for the purpose of determin-ing the nature of the ground water system underlying the Byron site, and he explained the assumptions used in determining the l time it would take radioactive contaminants released to the groundwater system to travel to drinking water sources. Mr.
karald P. Lahti, also of Sargent & Lundy, analyzed the conse-t j quences of a postulated design basis accident involving the i
release of radioactive contaminants to the hydrosphere. Mr.
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George C. Klopp, of Commonwealth Edison Company, assessed the adequacy of the NRC Staff's Final Environmental Statement (FES), NRC Staff Exhibit No. 2, as it relates to risk from the liquid pathway.
The NRC Staff presented the consolidated testimony of Dr. Richard Codell and Mr. Gary Staley, who together sponsored the FES liquid pathway risk evaluation, and also addressed the adequacy of the characterization of the groundwater system underlying the Byron site.
Intervenors presented the testimony of Dr. Bernard Wood, a professor of geology at Northwestern University, who addressed the characterization of the groundwater system under-lying the Byron site.
309. To characterize the groundwater system underly-ing a nuclear power plant site, it is necessary to invest.igate and identify the geologic and hydrogeologic properties of the underlying rock formations. These rock formations will influ-ence the travel of radioactive materials resulting from postu-lated accidents. (Holish, Applicant's Prepared Testimony at 3-4, ff. Tr. 6750; Holish, Tr. 6782.)
310. A detailed site investigation was performed for the Byron plant. (Holish, Applicant's Prepared Testimony at 4, ff. Tr. 6750.)
311. The Byron site investigation included more than four miles of geophysical surveys. (Id.) A geophysical survey identifies properties of the bedrock, including its stratigraphic variation. (Holish, Tr. 6751, 6824-5.) This is accomplished
by measuring the time it takes an implanted wave to travel through the bedrock. These geophysical surveys encompassed the i
entire plant ares. (Holish, Tr. 6825.)
312. The Byron site investigation also included the drilling, sampling and selective water pressure testing of 154 borings of the foundation bedrock varying in depth from 10 to 330 feet. (Holish, Applicant's Prepared Testimony at 4, ff.
Tr. 6750.) It is probable that each of these borings inter-sected a joint fracture. (Holish, Tr. 6751.)
313. In addition, the Byron site investigation in-cluded measurement of geologic features over the surface of the site area, such as outcrops and site linements. (Holish, Applicant's Prepared Testimony at 4, ff. Tr. 6750; Holish, Tr.
6782-83.)
314. The site investigation also included the installa-tion and measurement of observation wells throughout the site and adjoining properties. (Holish, Applicant's Prepared Testi-mony at 5, ff. Tr. 6750.) The wells have been continuously monitored since the inception of the site investigation in 1972, and they are being monitored at the present time. (Holish, Tr. 6752-53.)
315. The Byron site investigation included detailed i measurements and mapping of exposed bedrock features found in structure excavations. The behavior of structure foundations was also monitored. (Holish, Applicant's Prepared Testimony at 5, ff. Tr. 6750.)
l 316. The Byron site investigation was multiphased and structured in accordance with sections 2.4 and 2.5 of Regulatory
Guide 1.70, which was in effect at the time of the investiga-tion. (Holish, Applicant's Prepared Testimony at 4, ff. Tr.
6750). The NRC Staff provided further guidance in 1978 in Regulatory Guide 1.138, entitled " Laboratory Investigations of Soils For Engineering Analysis and Design in Nuclear Power Plants," and in 1979 in Regulatory Guide 1.132, entitled " Site Investigations For Foundation of Nuclear Power Plants." (Id.
at 5) The site investigation methodology used for Byron was consistent with that suggested by these two regulatory guides.
(Id.)
317. The NRC Staff testified that Applicant's site investigation was adequate to characterize the hydrogeologic properties of the site. (Staley, Tr. 6559.) Intervenors' witness testified that he had no criticism of the site inves-tigation either in terms of hydrogeology or in terms of general geology (Wood, Tr. 6913-15.)
318. The Board finds that the Byron site investiga-tion was adequate to determine the hydrogeologic and geologic characteristics of the Byron site.
319. The four most significant hydrogeologic units l underlying the Byron site are the glacial drift, the Galena-Platteville dolomites, the sandstone units of the Cambrian-Ordovician Aquifer (the St. Peter, Ironton and Galesville Sandstones), and the Mt. Simon Sandstone. (Holish, Applicant's l
Prepared Testimony at 6, ff. Tr. 6750.)
320. The Byron site area is covered with a mantle of glacial drift consisting largely of glacial till covered by a
few feet of windblown silt. The thickness of the drift aver-ages 16 feet. Due to the low permeability and thinness of the till, it is not possible to develop ground water wells by drilling into the drift. The drift is recharged by precipita-tion. ENo ground water wells exist within the glacial till, except where surface erosion has exposed the bedrock and allow-ed underground springs to form. (Id. at 7) 321. Beneath the glacial drift are dolomites and limestones of the Ordovician-age Galena and Platteville Groups.
Borehole logs indicate that the thickness of the Galena-I Platteville dolomites at the site ranges from 100 to 225 feet below the 16 feet of glacial till. (Id. at 7) 322. In the Byron site area, the Galena-Platteville dolomites are recharged by precipitation through the overlying glacial drift. They discharge into the Rock River and its
) associated tributaries.and into shallow domestic wells. (Id.
at 7-8) 323. Regionally, the' Galena-Platteville dolomites are hydraulically continuous with the lower sandstone units of the Cambrian-Ordovician aquifer. However, within the Byron site area, groundwater in the Galena-Platteville dolomites is perched
' on the Harmony Hill Shale Member of the Glenwood Formation, which has low permeability. The low permeability of the Har-mony Hill Shale Member was demonstrated by comparing the hydro-static head relationships measured in observation wells. Thus, the Glenwood Formation acts as a hydraulic barrier, preventing contamination of the lower aquifers. (Id. at 8) d
-, ,- e ---.. . - - - - . . . . 4 -
---y-
324. The next series of lower bedrock formations supply most of the drinking water for municipal users. These water supply aquifers are hydraulically separated within the area of the Byron site by the Harmony Hill Shale Member of the Glenwood Formation. (Id. at 8) 325. The Board finds that any groundwater contamina-tion which might escape from the Byron Station will travel only through the glacial drift and upper formations of the Galena-Platteville dolomites. The Glenwood Formation will prevent the contamination from reaching the lower bedrock aquifers which serve as the main source of drinking water for the region. (Id.
at 10) 326. The Dunleith Formation, located within the Galena-Platteville dolomites, is the upper bedrock unit of the Bryon site area. It provides the foundation for all plant safety-related structures. During foundation preparation activities, 154 bedrock borings were made. The boring results indicate that the Dunleith Formation is fractured, jointed, and thin bedded. The results do not indicate any large openings along joints or bedding planes. (Holish, Applicant's Prepared Testimony at 10-11, ff. Tr. 6750.)
327. The extent of the fracturing of the Dunleith Formation is greatest in its uppermost 25 to 30 feet. (Holish, l Applicant's Prepared Testimony at 7, ff. Tr. 6750; Wood, Tr.
6887-88.)
328. At the Byron site, the most highly fractured
! portion of the bedrock has been excavated. (Holish, Tr. 6743-44; Wood, Tr. 6906.) This bedrock excavation was part of the i
general excavation which resulted in placement of the reactor basemat at a depth of approximately 70 feet. (Holish, Appli-cant's Prepared Testimony at 11, ff. Tr. 6750; Wood, Tr. 6906.)
The reactor basemat is resting on essentially fresh bedrock which shows very little weathering, and which is only slightly to moderately fractured. (Holish, Tr. 6743, 6746.)
329. The results of the site investigation do not indicate the presence of continuous fractures or joints beneath the reactor basemat which lead directly to the Rock River or any other surface water pathway. (Staley, NRC Staff Prepared Testimony at 14. ff. T1. 6649; Staley, Tr. 6655.)
330. Both the Applicant and the NRC Staff have con-cluded that it is appropriate to treat the bedrock underlying the Byron site as equivalent to porous media. (Holish, Tr.
6766, 6864; Staley, Tr. 6595.) Their conclusions are based on the results of the Byron site investigation, which measured the amount of jointing in the bedrock, the aperture size of the joints, and the orientation and distribution of the joints.
These measurements indicate that it is appropriate to treat the l fractured bedrock as porous media. (Holish, Tr. 6766, 6864.)
331. The Board finds that it is appropriate to treat the bedrock underlying the Byron site as equivalent to porous media.
332. Groundwater velocity is principally a function l of tne permeability of the bedrock, the imposed hydraulic l
gradient, and the effective porosity of the aquifer. (Holish, L Applicant's Prepared Testimony at 16, ff. Tr. 6750.)
333. To calculate the permeability of the bedrock, Applicant water pressure tested 31 boreholes drilled to various depths throughout the thickness of the Galena-Platteville aquifer and located in and around the main plant area. Appli-cant calculated an average permeability of 0.52 feet per day.
(Holish, Applicant's Prepared Testimony at 17, ff. Tr. 6750; Codell, Staley, NRC Staff Prepared Testimony at 11, ff. Tr.
6649.)
334. Maximum hydraulic gradients were determined by the Applicant based on water level measurements taken in and around the site. The maximum hydraulic gradient from the base of the Byron plant to the nearest well is 1.861 x 10" . Since this well is owned by the Applicant, the hydraulic gradient to the nearest off-site water source was also determined. This water source is a spring along Walnut Creek, and the maximum
-2 hydraulic gradient is 1.1 x 10 . (Holish Applicant's Prepared Testimony at 17-18, ff. Tr. 6750.)
- 335. Applicant determined the effective porosity of the Galena-Platteville aquifer through geophysical logging performed during the Byron site exploration. Logging values were compared to values published by the Illinois Geologic Survey. The effective porosity of the aquifer varies between 2 and 10 percent (Holish, Applicant's Prepared Testimony at 18, ff. Tr. 6750.)
336. To calculate groundwater velocity, Applicant combined the values obtained for average permeability, hydraulic gradient and effective porosity in a function known as the
.g.
Darcy Equation. This equation is appropriate for calculating groundwater velocity if the aquifer is porous media or the equivalent of porous media. (Wood, Tr. 6941-43; Holish, Tr.
6766.) Travel time is then calculated by dividing the distance to be traveled by the groundwater velocity. (Codell, Staley, NRC Staff Prepared Testimony at 11, ff. Tr. 6649.)
337. The NRC Staff also used the Darcy Equation to calculate groundwater velocities and travel times. (Id) 338. All major solution enlarged joints, bedding planes and other planar features of the Dunleith Formation bedrock underlying the Byron site have been filled and sealed by pressure rock cement grouting. (Holish, Applicant's Pre-pared Testimony at 13, ff. Tr. 6750.)
339. The grouted bedrock beneath the Byron site has a permeability about a factor of 10 less than the ungrouted bedrock. (Staley, NRC Staff Prepared Testimony at 15, ff. Tr.
6649; Holish, Applicant's Prepared Testimony at 14-15, ff. Tr.
6750.) As a result, the travel time of postulated radioactive liquids through the groundwater system underlying the Byron site has been increased by several months. (Holish Tr. 6829-31, 6863.)
340. The travel times calculated by both the Appli-cant and the NRC Staff conservatively ignore the effects of the grouting. (Codell, Staley, NRC Staff Prepared Testimony at 11, i ff. Tr. 6649; Holish, Tr. 6733-34.)
341. To determine whether the potential release of radioactive material to the groundwater system underlying the i
i
Byron site endangers the health and safety of the public, the NRC Staff required the Applicant to analyze such a release as a postulated design basis accident. The postulated accident involves the rupture of a 125,000 gallon boron recyle holdup (BRH) tank, located in the auxiliary building. The accident assumes that the 125,0000 gallon tank is full, ruptures, and that its radioactive contents percolate onto the foundation bedrock through a .1 inch wide crack along the entire width of the auxiliary building floor. (Lahti, Applicant's Prepared Testimony at 4, ff. Tr. 6750.)
342. The leak rate of the BRH tank fluid through the
-8 crack is calculated to be 2.03 x 10 cfs per foot of crack.
(Id. at 5) Thereafter, the radioactive fluid would mix with the groundwater, resulting in dilution of the radioactive concentration by a factor of 2,200. (Holish, Applicant's Prepared Testimony at 18-19, ff. Tr. 6750.) The travel time of the contaminated flow from the point of release to the nearest
, well, which is owned by the Applicant, is approximately 30 years. (Id. at 18; Lahti, Applicant's Prepared Testimony at 5, ff. Tr. 6750.) The travel time to the nearest off-site water
, source, a spring along the Walnut Creek, is approximately 62 years. (Holish, Applicant's Prepared Testimony at 13, ff. Tr.
6750.)
343. In the 30 years it would take the contaminated water to reach the nearest well, the vast majority of radio-nuclides released by the accident would decay to negligible levels. Radionuclides which would not decay to such levels are l l
Cs-134, Cs-137, H-3 and Sr-90. Because of the dilution of the BRH tank fluid by the groundwater, concentrations of these radionuclides would be well within the limits established by 10 CFR Part 20, Appendix B, Table II Column 2. (Lahti, Applicant's Prepared Testimony at 6, Table 1, ff. Tr. 6750; Lahti, Tr.
6837.)
344. The Board finds that the consequences of the postulated BRH tank rupture do not endanger the health and safety of the public.
345. The evaluation of liquid pathway risk in the FES relies upon a d7 tailed analysis of risk for generic nuclear sites presented in the Liquid Pathway Generic Study (NUREG-0440).
The LPGS concludes that the risk from the liquid pathway for generic sites is acceptably small. (NRC Staff Exhibit No. 2 at 5-56; Codell, Staley, NRC Staff Prepared Testimony at 6-7, ff.
Tr. 6649.) To evaluate the Byron liquid pathway risk, ground-water travel time, drinking water use, fish catch and shoreline use for the Byron site were compared with those of a generic small river site which was considered in the LPGS. Based on this comparison, and also based on several highly conservative assumptions, the NRC Staff concluded in the FES that the con-tribution to population dose of an uninterdicted core melt liq-uid pathway release from the Byr6n plant would be approximately a factor of three greater than that calculated for the small river site. (Id., Codell, Tr. 6614-17.) Since the Byron site liquid pathway contribution to population dose is of the same order of magnitude as that predicted for the LPGS small river i
site, the NRC Staff concluded that the risks from a core melt, and thus the risks from the liquid pathway, are also acceptably small. (NRC Staff Exhibit No. 2 at 5-59; Codell, Staley, NRC Staff Prepared Testimony at 7, ff. Tr. 6649; Codell, Tr. 6552, 6553.)
346. The assessment in the FES of the Byron-specific consequences of a core melt accident is based on a travel time of radioactive contaminants consistent with the hydrogeology of the Byron site. The NRC Staff, in determining the permeability of the bedrock underlying the Byron site, originally relied on pumping test data presented in the Applicant's Final Safety Analysis Report (FSAR). This data yielded an average permeabil-ity of 1.82 feet per day. (Codell, Staley, NRC Staff Prepared Testimony at 10-11, ff. Tr. 6649.) Based on this value, and also based on hydraulic gradient and effective porosity values similar to those determined by the Applicant, the NRC Staff calculated a 24.4 year travel time for radioactive contaminant to reach the nearest spring in the event of a core melt release to the underlying aquifer. (Id. at 11.)
347. The Applicant recently determined that the use of the pumping test data referred to in the FSAR was inappropri-ate to determine groundwater travel times. Water pressure test data was used instead, and new rravel times were calculated and included in the FSAR. (Id. at 11; Holish, Applicant's Prepared Testimony at 15-16, ff. Tr. 6750.) The NRC Staff subsequently recalculated the average permeability of the bedrock using the water pressure test results from 12 of the 31 boreholes tested
by the Applicant. On this basis, a revised average permeabil-ity of 0.42 feet per day was calculated. This revised value, -
in conjunction with the Darcy Equation, yields a much longer travel time than 24.4 years. The NRC Staff has continued to rely on 24.4 years in the FES as a highly conservative travel time estimate. (Codell, Staley, NRC Staff Prepared Testimony at 11-12, ff. 6649.)
348. The FES analysis conservatively postulates that all contaminated groundwater will travel from beneath the reactor directly to the nearest surface spring 3600 feet down-gradient. In fact, it is very unlikely that more than a small fraction of the contaminated groundwater will take such a direct path. Since other groundwater sinks are much further from the reactor, portions of the contaminated groundwater which do not travel directly to the nearest spring will have considerably longer travel times, thereby facilitating greater decay of the radionuclides. (Codell, Staley, NRC Staff Pre-
! pared Testimony at 8-9, ff. Tr. 6649.)
l 349. In the FES core melt analysis, no retardation of l
radionuclides by the underlying bedrock was considered. It is l likely that retardation even in fractured rock would be measur-l able and would slow the effective speed at which the radio-nuclides would travel. (Codell, Staley, NRC Staff Prepared Testimony at 8-9, ff. Tr. 6649.)
l 350. The FES analysis conservatively assumes that 25 ,
p( rcent of the recharge to riverside wells comes from the Rock River, even though many wells are screened into deeper hydro-
logic units unaffected by the river recharge. Moreover, no retardation of radionuclides in the river alluvium or sandstone is taken into account, even though sorption in these media is known to be appreciable. (Codell, Staley, NRC Staff Prepared Testimony at 9, ff. Tr. 6649.)
351. In the FES analysis, groundwater gradients were conservatively based on the preconstruction surface as deter-mined during a year of abnormally high recharge. Plant con-struction, paving, improved surface drainage and grouting has significantly reduced recharge and resulted in an almost flat gradient in the Byron site area. Since groundwater velocity is directly proportional to gradient, a much longer travel time than that calculated in the FES is to be expected. (Id. at 10.) ,
352. The Byron FES conservatively assumes that each and every postulated core melt event results in containment basemat penetration with subsequent groundwater release. The vast majority of postulated core melt events would net result in containment basemat penetration. (Klopp, Applicant's Pre-pared Testimony at 6-8, 10, ff. Tr. 6750.)
353. The FES did not calculate a specific source term for the Byron site. Instead, the FES relied on the LPGS source term. (Codell, Tr. 6567-68.) The LPGS source term is based on an assumption that highly contaminated sump water will follow the molten core through the penetrated basemat. The presence of such sump water following basemat penetration increases the source term by a factor of 100 to 1,000. (Klopp, Applicant's Prepared Testimony at 10-11, ff. Tr. 6750.)
354. At Byron the sump water source term can be eliminated. Basemat penetration will not occur with signi-ficant sump water present, because a molten core of sufficient temperature to ablate concrete will not permit water to remain in contact with it. The water will flash to steam. (Id.;
Klopp, Tr. 6806-07, 6839.) Conversely, if it is possible to maintain water in contact with the core, through recycling of the steam by fan coolers or containment sprays, the core will cool sufficiently to prevent basemat penetration. (Klopp, Tr.
6806, 6839-40.)
355. If basemat penetration does occur, sump water driven off as steam will contain significant amounts of radio-nuclides, including all the noble gasses. (Klopp, Tr. 6807-08.)
In addition, all volatiles, including cesium and iodine, will be released as aerosol gasses from the molten core during the penetration. This is due to the extremely violent chemical and thermal reaction taking place between the molten core material and the basemat concrete. (Klopp, Tr. 6741-42.) Neither the noble gasses nor the volatiles will be part of the groundwater source term. (Klopp, Tr. 6807-08.) The source term used in 1
the Byron FES is, therefore, overstated by a factor of 100 to 1,000. (Klopp, Applicant's Prepared Testimony at 10-11, ff.
Tr. 6750.)
356. The FES core melt analysis conservatively ignores the possibility of interdiction. (Codell, Tr. 6625.)
357. The Board finds that the NRC Staff's evaluation in the FES of the liquid pathway risk at the Byron site is highly conservative.
= . _ .-_ __
358. Based on the assumption that no significant amount of sump water will follow the melted core through the basemat, the Applicant calculated a travel time to the nearest well of approximately 92 years. (Holish, Applicant's Prepared Testimony at 24-25, ff. Tr. 6750.)
359. Two general methods of interdiction could be appropriate in the event of a core melt release. (Staley, Tr.
6632.) First, additional grouting could be performed to con-tain the radioactive liquid. (Codell, Tr. 6633.) Thereafter, the radioactive liquid could be pumped from the contained area.
(Codell, Tr. 6633.) A second method of interdiction would involve drilling wells around the area of the release. (Staley, Tr. 6641.' The radioactive liquid would seep into the wells, and from there could be pumped out. (Id.) Both methods of interdiction consist of very routine engineering work, although the presence of radiation may impose additional difficulties.
(Staley, Tr. 6640-41.)
360. Applicant has experience in the successful interdiction of radioactive spills. (Klopp, Tr. 6727-29.)
361. The Board finds that the FES contains adequate information to permit an evaluation of the environmental con-sequences from radionuclide releases to the liquid pathway.
Based on this evaluation, as supplemented by the testimony of NRC Staff and Applicant, the Board finds that the environmental risks from the liquid pathway are acceptably small.
The foregoing document, " Commonwealth Edison Company's Proposed Findings of Fact and Conclusions of Law Regarding Liquid Pathway" is respectfully submitted by the undersigned attorneys for Commonwealth Edison Company.
]J/
/ jooseph Gallo f .
Mark C. Furse ISHAM, LINCOLN & BEALE 1120 Connecticut Avenue, N.W.
Washington, D.C. 20036 (202) 833-9730 ISHAM, LINCOLN & BEALE Three First National Plaza
. Chicago, Illinois 60602 (312) 558-7500 Dated: June 24, 1983 L
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454 OL
) 50-455 OL (Byron Nuclear Power Station, )
Units 1 & 2) )
CERTIFICATE OF SERVICE The undersigned, one of the attorneys for Common- '
wealth Edison Company, certifies that he filed the original and two copies of the attached " COMMONWEALTH EDISON COMPANY'S PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW REGARDING LIQUID PATHWAY" with the Secretary of the Nuclear Regulatory Commission and served a copy of the same on each of the persons at the addresses shown on the attached service list.
Service on the Secretary and all parties, unless otherwise indicated, was made by deposit in the U.S. Mail, first-class postage prepaid, this 24th day of June, 1983.
M One of the attorneys for Commonwealth Edison Company ISHAM, LINCOLN & BEALE I
l Three First National Plaza Chicago, Illinois 60602 (312) 558-7500 l
L >
1 SERVICE LIST COMMONWEALTH EDISON COMPANY -- Byron Station Docxet nos. 50-454 and 50-455 Mr. Ivan W. Smith Secretary Administrative Judge and Chairman Attn: Chief, Docketing and Atomic Safety and Licensing Service Section Board Panel U.S. Nuclear Regulatory Commission Room 428 Washington, D.C. 20555 East West / West Towers Bldg.
4350 East West Highway Ms. Betty Johnson Bethesda, MD 20114 1907 Stratford Lane Rockford, Illinois 61107 Dr. Richard F. Cole Atomic Safety and Licensing Ms. Diane Chavez Board Panel SAFE U.S. Nuclear Regulatory Commission 326 North Avon Street Washington, D.C. 20555 Rockford, Illinois 61103 Atomic Safety and Licensing Dr. Bruce von Zellen Board Panel Department of Biological Sciences U.S. Nuclear Regulatory Commission Northern Illinois University Washington, D.C. 20555 DeKalb, Illinois 60115 Chief Hearing Counsel Joseph Gallo, Esq.
. Office of the Executive Isham, Lincoln & Beale Legal Director Suite 840 U.S. Nuclear Regulatory Commission 1120 Connecticut Ave., N.W.
Washington, D.C. 20555 Washington, D.C. 20036 i
Dr. A Dixon Callihan Douglass W. Cassel, Jr.
Union Carbide Corporation Jane Whicher P.O. Box Y BPI Oak Ridge, Tennessee 37830 Suite 1300
- 109 N. Dearborn
! Mr. Steven C. Goldberg Chicago, IL 60602 l Ms. Mitzi A. Young Office of the Executive Legal Ms. Patricia Morrison Director 5568 Thunderidge Drive U.S. Nuclear Regulatory Commission Rockford, Illinois 61107 Washington, D.C. 20555
- Mr. David Thomas -- -
Atomic Safety and Licensing 77 South Wacker Appeal Board Panel Chicago, IL 60621 U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Via Messenger J