ML20081C315

Forwards Comments on Des (NUREG-1026).Comments Submitted for Consideration by Commission Per 10CFR51

ML20081C315
Person / Time
Site:	Braidwood
Issue date:	03/12/1984
From:	Mcdonough C COMMONWEALTH EDISON CO.
To:	Office of Nuclear Reactor Regulation
References
RTR-NUREG-1026 4342E, NUDOCS 8403140001
Download: ML20081C315 (13)

Text

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.1 ) Commonwealth E:~ son 72 Wist Ad+.ms Strnt Chicago, khnois Address Reply to: Post Othee Box 767 7

Chicago, Ittinois 60690 s

4 March 12, 1984 Director-Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.

20555 9

Subject:

Braidwood Station Units 1 and 2 Docket Nos. STN 50-456 and STN 50-457 1

Dear Sir:

Enclosed are Commonwealth Edison Company's comments pertaining to i

the Braidwood Station Units 1 and 2 Draft Environmental Statement (NUREG-1026). These comments are being submitted for consideration by the Commission in accordance with 10 CFR Part 51.

Sincerely,

.e, C. L. McDonough

' Director of Envir nmental Assessment 4342E BBB:CLM:ds Enclosures 0403140001 840312 PDR ADOCK 05000456 D-PDR GcP

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Commonwealth Edison Company's Comments Pertaining to the Braidwood Station Units 1 and 2 Draft Environmental Statement Page / Section Comments vi/ Summary Due to revision of the construction schedule for Braid-Item (3) wood Station the last sentence in Item 3 should be revised to read:

"The applicant estimates fuel-loading dates of August, 1985 for Unit 1 and August, 1986 for Unit 2."

1-1/1.1 For the reason stated in the preceding comment the last (Par. 2) sentence in Paragraph 2 should be revised to read:

" CECO. estimates that Unit I will be ready for fuel loading in August, 1985 and commercial operation in April, 1986; Unit 2 is estimated to be ready for fuel loading in August, 1986 and commercial operation in April, 1987."

4-1/4.1 The last sentence of the second paragraph should be changed to read as follows:

"The originally planned connection to the Joliet Generating Station has been eliminated and the only new right-of-way from the plant is to the Crete Substation."

4-2/ Figure 4.1 Figure 2.1-4 will be revised in Amendment 6 to the Braidwood Station ER-OLS. An advance copy of the revised figure is attached to these comments for inclusion in the FES.

4-5/4.2.3.1 The fourth from the last sentence in the Section should read be revised to read:

. 180.7 m (592.8 ft.) MSL."

The third from the last sentence in the Section refers to historic river flows on the Kankakee River and the possible restrictions on station operation. The period of record for the response to Question E240.4 was 66 years,1915 through 1982 rather than from 1946 though 1976. Based on that historic flow record (1915 though 1982) there was only one occurrence, 1936, when the stations power production would have had to be curtailed because of Irw Kankakee River flow below 495.5 cfs.

4-7/4.2.3.4 Paragraph one should be revised to read: " Scale (Par. 1) buildup in the condenser cooling system will be controlled by a combination of chlorination and mechanical cleaning ( Amertap).

If scale cannot be controlled with chlorination and mechanical cleaning t5en either carbon dioxide or polymers will be used.

Carbon dioxide. would be added at the rate of 1600 kg (3500 lb) per hour."

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Page/Section Comments 4-7/4.2.3.4 (Cont.)

The second, third and fourth sentences should be (Par. 2) revised to read:

" Sponge rubber balls, sized to the

(

inside diameter of the condenser tubes will be i

continuously injected into the system at the inlet to the condenser. The balls will clean the tubes as they pass though the system and will be collected by a series v baffles and screens at the outlet of the condenser and returned to the inlet.- The balls will be. removed and sorted periodically."

4-8/4.2.3.4 In the third sentence - the value for chlorine (Par. 3) concentration should be changed from 0.1 mg/l to 0.5 I

ag/1.

(Par. 4)

In the first sentence - the number of times per day that the service water system will be treated should be changed from three times daily to twice daily.

(Par. 5)

The second sentence should be revised to read:

"The water passes through a chlorine retention tank, clarifiers and a' clear well before passing through two parallel lime softenerJ and three parallel sand filters.

In the fif th sentence - the size of the filtered water storage tant is 150,000 gallons. In the sixth sentence

" cycler" should be changed to

" cycle."

The eighth sentence should be revised to read: "The demineraliser train pa-Ses the water through a strong-acid cation exchange unit, a strong-base anion unit, and a mixed bed unit."

(Note:

the above changes, relating to water treatment, will be included in revisions to ER-OLS sections:

3.6.1.1, 3.6.1.2 and 3.6.2 in Amendment 6 to the ER-OLS).

4-9/4.2.4.2 The first senter.ce should be revised to read:

(Par. 2) 3.0 m (9.0 f t), and a maximum depth of 5 m (15 ft.)."

(Par. 3)

The first sentence should be revised to read:

"A smaller (3.8 x 105 2 (99 acre)) cooling m

pond... ".

(Par. 4)

The fourth sentence should be revised to read:

" Water is drawn through two 4.9-m (16-ft.) - diameter pipelines to the condensers, then through two other 4.9-m (16 ft.) - diameter pipelines to the discharge outfall structure and back into the pond at a 3

continuous flow of 92 m /sec (3250 cfs) for the two units."

}

1 i Page/Section Comments 4-11/4.2.4.3 In sentence seven reference is made to Table 4.1 and in sentence eight values for average temperature above the ambient are given from Table 4.1.

The values shown are the differences between the outlet temperature from the station to the cooling pond rather than the plant inlet and pond blowdown temperature. If the intention is to illustrate the difference between blowdown and river ambient temperatures, then the sentence should read.

"The average temperature excess above ambient is 70C (12.60F); the extremes are 3.60C (6.50F) in August and 10.10C (18.10F) in February".

If the intention is as stated (outlet discharge minus ambient river temperature) than the maximum extreme should read: ".

in August and 21.20C (38.10F) in February." In the ninth sentence the excess 50F isotherm ranges between 0.10 and 0.45 acres not 0.45 to 0.85 acres.

4-12/ Table 4.1 The average flow rate for May should be 6288 cfs.

4-14/4.2.7 In the third sentence "Burham" - should be changed to "Burnham".

In the fifth sentence - the maximum width of the right-of-way is "139 m (455 f t)."

(See ER-OL Figure 3.9-2).

In the seventh sentence -

reference is made to a "possible future 765 kV line".

It should be pointed out that there are no plans for the 765 kV line in the forseeable future and the necessary right-of-way for such a line is not continuous.

4-15/ Figure 4.5 The Legend symbol for new 345 kV lines appears to be solid rather P.han dashed.

4-26/4.3.2 In the fourth and sixth sent-nces - the ER-OL section (Par. 3) is 2.4.1.4.2.

4-27/4.3.3 The third sentence should be revised to read:

"For the 4 year period, 1979 through 1982,.

4-27/4.3.4.1 In the third sentence - delete " marshlands and".

(Par. 2)

In the fourth sentence - the acreage of small discontinous marshlands is 40.

4-27/4.3.4.2 The first sentence should be revised to read:

"cie (Par. 1) aquatic biota of the Kankakee River and Horse Creek in the site vicinity were sampled during 1974-75, 1977-79 and 1981-82, as part of the baseline and/or construction phase aquatic monitoring.

, Page/Section Comments 4-28/4.3.4.2 The third sentence should be revised to read:

(Far. 1)

"The results of the 1974-75 and 1977-1981 monitoring programs are discussed in detail in Section 2.2.1 and Section 4.7 respectively of the ER-OL."

(Par. 2)

First sentence should be revised to read:

"A total of five phytoplankton phyla were collected during the 1974-75 program." In the fifth sentence - change "fif ty five" to " forty five".

(Par. 6)

The first sentence should be revised to read:

"A total of 2221 fish representing 46 species was collected from the Kankakee River and Horse Creek during the 1974-75 program."

4-31/4.3.4.2 The first sentence should be revised to read:

(Par.7)

" Sampling for fish eggs and larvae was performed as part of the 1974-75 monitoring program."

5-2/5.3.1 In the fifth senten_e, the committment to limit (Par.1) the maximum withdrawal of water to 10% of the river flow (FES-CP) was a design objective. This objective was superceded by the water withdrawal agreement summated in the last sentence in the paragraph (also see response to Question E240.4, Amendment 3 Braidwood ER-OLS). This agreement was formulated in response to the Illinois Department of Conservations concerns of potential effects on the river during low flow conditions.

In the sixth sentence "518 a*=" should be changed to "495 c f s".

(Par. 2)

In the first sentence - the 10% maximum withdrawal criterion has been superceded by the agreement with the Illinois Department of Conservation described in the preceding paragraph.

The last sentence in the paragraph should be revised to read:

"At present there are no downstream uses of water from the Kankakee River.

The Joliet Arsenal has the capacity to withdraw 38 cfs but is presently in a standby status."

5-3/5.3.2 In the thirteenth sentence - the acreage of the 20F (Par. 2) isotherm should be changed frem 1.46 acres to 5.4 acres.

In the fourteenth sentence - ER-OL section should be changed from 2.4.2.4.2 to 2.4.1.4.2.

5-4/ Table 5.1 The value for " Ambient River-Chlorides" should be changed from 27 to 22.

ER-OL Table 5.3-1 will be revised in ER-OL Amendment 6.

f i

t 9 Page/Section Comments 5-9/5.5.1.1 The third sentence should be revised to read:

(Par. 2)

"The applicant is working with the county soil conservationist to revegetate about 15 ha (36 acres) in the northeast portion of the site, part as native prairie and part as wildlife habitat (ER-OL, response to NRC staff question 290.4)."

5-12/5.5.2.2 The first sentence should be revised to read:

(Par. 2)

"... August [260C (79.50F)]... "

5-15/5.5.2.2 in the first sentence - a value of 2.6 m /sec 3

(Par. 4)

(90.8 cfs) is shown for " normal intake flow from the Kankakee River." That value is for the " average annual intake flow."

The correct value for " normal 3

intake flow" is 3.0 m /sec (107 cfs).

5-42/5.9.4.4 The third sentence should be revised to read:

(Par. 2)

"The exclusion area, located within the site boundary, is a rectangular area with a minimum distance of 485 m (1478 f t.) from the outer edge of the containment wall to the exclusion area boundary."

5-46/5.9.4.5 Based on S. Levine's uncertainty analysis testimony (Par. 1) submitted on Byron Station during the ASLE hearing and the similarities between Byron and Braidwood plants, this approach and the resulting numerical value is too conservative.

5-47/5.9.4.5 Parameter: Probability per reactor year (Table 5.10)

Under release category B, the value should be no greater than 2 x 10-7 for Braidwood based on the risk studies done for Byron, which has similar design features.

Under release category F, the value should be essen-tially zero, again based on these studies done on Byron.

Parameter: Release time (hr)

Under release category B, the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> value is overly conservative.

Since the 4 high-head ECCS pumps will continue to supply water to the core for just about I hour, a release time of 2 to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> would be more realistic.

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Page/Section Comments 5-47/5.9.4.5 Under release category F, using the NRC's conservative (Table 5.10)

H2 burn scenario, it would seem very unlikely that (Cont.)

enough core-concrete attack cou'd occur by 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to boost H2 inventory high enough to have a containment failure. Core melt and vessel failure would likely take 2 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Parameter:

Release Duration (hr)

- Under release category B, there is no driving force for such a rapid release time of 0.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. A duration time of 2 to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> would be more realistic.

Footnotes An additional footnote should be added to this table to indicate that the current work on sourc 2 terms indicate that the values herein are likely to be conservetive.

5-52/5.9.4.5 Figures 5.7 and 5.8, referred to in these paragraphs, (Par. 3 & 4) indicate complementary cumulative distribution functions which are more severe than those contained in WASH-1400. We believe these tables overstate the risks associated with Braidwood.

Braidwood is not a high population site. Removal of some of the

~ WASH-1400 conservatises should yield lower effects.

5-66/5.9.4.5 Under Regional Industrial Impacts, the first sentence (Par 1) should be revised to read:

"A severe accident that requires the interdiction and/or decontamination of land areas will force a few industries to temporarily

. or permanently close." As shown on the ER-OLS Table 2.1-7 there are only 10 industries within a radius of 10 miles, therefore, even if an accident affected out to 10 miles tiiere would not be " numerous businesses" affected.

5-84/5.12 The last sentence should take into consideration that (Par. 1)-

the noise levels of the power, unit auxiliary and system auxiliary transformers that were provided as responses to' staff questions E 290.11 and E290.20, Amendment 4 to ER-OLS, include noise of both transformers and associated fans.

(Par. 2)

The.first sentence should take into consideration that the term " transformer fans" with reference to noise levels means the noise produced-by the transformers and its associated fans et full load.

This comment is applicable to each instance in which the term

" transformer fans" is used in this section.

(

Page/Section Comments 5-84/ Table 5.15 The title to this table should make reference to the purpose of the table which is the calculated sound levels at nearest residences utilizing anbient noise levels and noise from the " main transformer fans".

The sound power levels for main transformer fans at 2000 Hz should be 98 rather than 90.

The sound levels at the receptors R7, RS, R12 and R13 are defined as " sound power levels" Noise at receptors are generally cited as " sound pressure levels" as are utilized in Table 5.16 for receptor P4.

5-85/(Table 5/16)

The A-weighted and estimated nighttime residual sound levels presented at receptor P4, are integrated overall values, not only at 1000 Hz as could be interpreted from the column heading.

5-86/5.12 In sentences two and three - a note should be added to (Par. 4) this paragraph to indicate that the impacts of 10 dBA and 6 dBA, respectively, apply only to an embient noise level of 30 dBA.

The impacts would be less for higher ambient noise levels and greater for lower ambient noise levels.

(Par. 5)

In sentence one "140" should be "240".

5-87/5.14.1 With regard to the committment to continue the aerial (Pat. 1) infrared photographic program until 2 years after Unit 2 begins operation, a proposal for teridnation of this prograr was made in the ER-OLS Amendment 5 to Section 6.2.2.

The ' reasons given there are that the program was designed to detect any off-site effects resulting from filling the cooling pond and, that no of f-site ef fects have been observed that could be attributable either to the filling of the pond or to the presence of the pond.

5-88/5.14.3 The first sentence should be revised to read:

(Par. 1)

. 573 m (0.4 mi) northeast of the Unit I reactor building since November 1973."

Under the column heading

" Level of Measurement," the following should be revised to read:

Meteorological Parameter Level of Measurement Wind speed and wind direction 34 ("L 10 m) and 203 ft. (3,62 m)

Temperature difference between 30 (q,9.1 m) and 199 ft. (60.6 m)

Dewpoint temperature 30 (1.9.1 m) sud 199 ft. (60.6 m)

Ambient air temperature 30 ft. (1,9.1 m)

U t Page/Section Comments 6-1/6.1 See comment regarding 5-87/5.14.1 (Par. 1) above.

(Par. 2) 6-2/ Table 6.1 Under " Benefits":

The quantity of electrical energy is shown as 11 billion KWh/yr, which is based on an average annual capacity factor of 55%, with reduced generating costs of $49 million/ unit /yr (1986 dollars). This estimate is low.

Recent studies based on an sverage annual capacity factor ranging from 55 to 58% for the years 1988 (first year with both units in service for the full year) through 1992 show increased production costs without Braidwood as shown below:

Increased Production Cost Year without Braidwood Units - $aillion*

1986 83 1987 196 1988**

224 1989 262 1990 294 1991 307 1992 335

• Costs are in late 1983 dollars

• • First year with both units in service full year Under " Costs":

The values shown for fuel costs and operation and maintenance costs were derived from ER-OLS Table 8.1-1 and are discussed in DES Section 6.4.3 where the Table is said to present "10 year levelized cost".

The title of ER-OLS Table 8.1.1 is

" Estimated Total Generating Costs for Braidwood Unit 1 for First 12 months of Commercial Operation."

~

Estimates have been made for each Braidwood Unit for total generating costs for the first ten years levelized and are presented below:

_ _ _ _ _ _ _ _ - - - _ - - - - - - - - - - - - - - - - - - - - " - - - - - - - - - - - - ^ - - - - ' - - - - - - - - - ' - - - - - ' - -

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Estimated Total Generating Cost for Braidwood Station Unit 1 for First Ten Years Levelized Do11arsa Mills per a Cost Component (thousands) kilowatt hour Fuel

$ 78,838 14.61 Operating and Maintenance 48,619 9.01 Carrying Charges 394,297 73.07 Other 38.690 7.17 Total Generating Cost

$560,444 103.86 Note: Values are based on commercial operation starting October,1985.

acosts are in 1986 dollars and are based on 55% capacity factor (generating 5,396,160 MWH per year)

Estimated Total Generating Cost for Braidwood Station Unit 2 for First Ten Years Levelized Do11arsa Mills pera Cost Component (thousands) kilowatt hour Fuel

$ 83,964 15.56 Operating and Maintenance 51,803 9.60 Carrying Charges 279,251 51.75 Other 32,647 6.05 Total Generating Cost

$447,665 82.96 Note: Values are based on commercial operation starting October,1985, aCosts are in 1987 dollars and are based on 55% capacity factor (generating 5,396,160 MWH per year)

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. Page/Sectior Comment s 6-3/ Table 6.1 Under " Adverse socioeconomic effects" the loss of (Continued) historic or archaeological resources" impacts is judged to be " moderate". Since no impacted historic resources have been identified and since there have been only a small number of archeological sites identified (none of which were impacted by construction) a rating of "none" or at most "small" vould seem more appropriate.

Under " Adverse nonradiological health effects", no impact quantification is shown for " air quality changes".

In view of the circumstances a rating of "none" would be appropriate.

6-4/6.4.2 Decreased costs are shown as $49 million (1986 (Par. 2) dollars) per unit per year. See above comments on Table 6.1.

6-4/6.4.3 The ' discussion of generating costs on the basis of (Par. 1) 10 year levelized costs was commented on, see above comments on Table 6.1.

D-2/ Appendix D In the column headed " Air-Ejector Exhaust - Continuous" Table D the value for I-131 should be revised to 0.0028 and I-133 should be revised to 0.0041. The " Total" column should reflect these changes, 1-131 = 0.0868 and I-133

= 0.0721. The reason for these revisions is that apparently no credit was given for the charcoal filter system present in the steam jet air-ejector exhaust stream of the Byron /Braidwood design.

E-2/ Appendix E It should be pointed out that Indian Point 2 has some (Par. 3) unique design features that, given specific external events, led to a significant probability of early containment failure. ' These design features do not exist at Braidwood. Braidwood is much like Zion in this regard and early containment failure is unlikely for either station.

E-4/ Appendix E -

Line 8

" shutdown cooling system (SCS)": should be (Par. 1)-

changed to " residual heat removal system" (RHR).

Change "SCS to RHR".

Line 10 - Change SCS to RHR.

Line 11. - delete "and a closed motor-operated valve".

This valve is not normally closed.

'(Par. 2)

The sequence discussed in this paragraph is not valid in that the assumed steam spike, if it were to happen, could not be of suf ficient magnitude to have containment failure due to over pressure.

v......

. d Page/Section Comments E-4/ Appendix E Given that sprays are still available, it is not (Cont.)

possible to generate enough H2 to result in (Par. 5) containment failure from burning H. Even 100%

2 Zr/H O reaction would not give enough H 2

2 to cause containment failure. The sprays and fan coolers would keep the debris cooled and minitaize H 2 formation from core / concrete interaction.

E-5/ Appendix E The assumption that 10% of all core-melt-accident (Par. 3) sequences not accounted for by release catagories B, C, and F are assumed to result in release catagory H is over estimated. Only TMLB or sequences without sprays and fan coolers could result in base mat penetration after a cure-melt-accident.

E-5/ Appendix E It is stated that the range of probabilities for (Par. 5) core melt accidents resulting from internal events for reactors for which probabilistic risk assessments were performed to be in the range of 10-3 to 10-5 per reactor year. For the newer plants, however, the range is 10-4 to 10-5 per reactor-year. Therefore the 10-4 considered for Braidwood is at the high end of the never plants and is therefore conservative.

F-3/ Appendix F Based upon the most recent evacuation time estimates (Par. 2&3) study (ETES) for the area around Braidwood Station, applicant has determined that an effective evacuation speed of 2.83 m per second [6.32 mph] would be more appropriate than the value of 1.1 mph developed by the NRC staff. The Braidwood ETES (currently scheduled to be submitted April, 1984) indicates that the average evacuation travel time to clear the Braidwood EPZ is 95 minues or less for most of the scenarios evaluated by the ETES.

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