ML20081A804

Provides Comments on Des (NUREG-1026).Justification for Not Providing Design Analysis of Seismic Event Requested

ML20081A804
Person / Time
Site:	Braidwood
Issue date:	02/22/1984
From:	Etchison D ILLINOIS, STATE OF
To:	Office of Nuclear Reactor Regulation
References
RTR-NUREG-1026 NUDOCS 8403060313
Download: ML20081A804 (3)

Text

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Illinois Department of Xuclear Safety 1035 Outer Park Drive Springfield, Illinois 62704 (217)5468100 Don Etchison Terry Lash Director Deputy Director February 22, 1984 Director, Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 RE: Braidwood Station Units 1 & 2 Docket Nos. STN50-456, STN50-457 Draft Environmental Statement (NUREG-1026) Operating License Stage

Dear Director:

After a review of the Braidwood Environmental Statement, the following questions and comments are directed to your attention:

A. 5.9.4.4 (1) - Environmental Impacts of Postulated Accidents - Design features

1. How does the Braidwood Station's radioactive waste gas decay tank system design differ from the Zion Station design which experienced an unplanned accidental release of nchle gases on May 26, 19807 Please provide information as to how Braidwood Station's waste gas decay tank design would prevent such an accidental radioactive gas release.

2. 5.9.3. - Radiological Impacts from Routine Operations Whar has been done at Braidwood Station to preclude unmonitored and/or unplanned radioactive releases, both gaseous and liquid? An example of such is the past unmonitored liquid tritium release at Zion Station.

3. 5.9.3.1.1. - Occupational Radiation Exposure _for 1 cessurized Water Reactors Does the range of annual man-rems anticipyred for the occupational I 1

radiation exposure include the radiation exposure received for 8403060313 840222 PDR ADOCK 05000456 D pyg DiscoverTheMagnificentMileso (g IQ

Dir:ctor, Divielon of Licensing February 22, 1984 Page 2

3. special considerations such as steam generator tube repa1r and maintenance on the reactor coolant pump seals?

4. IBID (3)

Did the staff take into account the proposed revision of 10CFR20 in developing this section on occupational radiation exposure?

5. 5.9.4.5 - Accident Risk & Impact Assessement (7) Uncertainties (Page 5-69)

This section indicates that sequences initiated by natural phenomena, such as seismic events, are not included in the sequences being '

evaluated. The staff also indicates this, as well as other natural phenomena effects, would not contribute significantly to risk. Please provide justification as to why, at least for the seismic event, design analysis was not provided for the Braidwood Station.

B. General Comments

1. Does Braidwood Station have the capability to handle radioactive chemical decontamination waste?

2. The staff relied heavily upon the Reactor Safety Study (Wash.1400),

and the Zion and Indian Point probabilistic risk assessment studies in Section 5.9.4.5, " Accident Risk and Impact Assessment", in its analyses.

In light of the high degrees of uncertainty associated with the probability valuca in Wash. 1400, should not a more realistic study be performed for Braidwood Station in order to be able to place a higher degree of confidence in the risk assessment results?

3. Please provide an explanation an to why there arc differences in the following tables:

Type of Document Release Type FES-CLS DES-OLS Liquid Table 3.5 Table D-4 Gaseous Table 3.6 Table D-1

4. "It is the qualitative judgement of the staff that the uncertainty bounds could be well over a factor of 10, but not as large as a factor of 100".

(Page 5-72).

WhatLis the basis for the staff's qualitative judgement?

6 *

• Director, Division of Licensing

-February 22, 1984 Page 3

5. Some of'the isotopic values given in Table D-1 are lower by a factor of 10-100 than the c.orresponding release rates per reactor as given in the Table on Page B23 of Regulatory Guide 1.BB, which are used in the NRC PWR/ GALE computer code to determine the off-site gaseous doses

'for normal operations.

Please provide an explanation for the reduction of the gaseous release rates.

Thank you for the opportunity to review the Braidwood Station's Draft Environmental Statement - operating permit stage. Your consideration of the above comments is appreciated.

Very truly yours, FA -d Don Etchison Director DE:RBM:jt

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