ML20003C849

Affidavit in Response to M Cherry Petitions to Suspend Const of Facilities & RB Hubbard & Gc Minor Affidavit Alleging Deficiencies in Facilities Const

ML20003C849
Person / Time
Site:	Byron
Issue date:	12/19/1980
From:	Deress J COMMONWEALTH EDISON CO.
To:
Shared Package
ML20003C847	List: ML20003C846 ML20003C849
References
80-0760, 80-760, NUDOCS 8103180577
Download: ML20003C849 (15)

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.. EXEIBIT C 1

fh STATE OF ILLINOIS ILLINOIS COMMERCE COMMISSION

)

In the Matter of ) b-

) O Commonwealth Edison Company ) 80-0760 *, 9 Application to Halt Construction ) oo0dF,'

of Byron Nuclear Power Station, ). 'I M'#' -

Units 1 and 2

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MAR 61981 >

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AFFIDAVIT OF JAMES D. DERESS l\

'My name is James D. Deress. I am employed by Com-monwealth Edison Company as the Project Engineering Manager of the Byron and Braidwood Projects. I hold a B.S. in Mechanical Engineering from the Illinois Institute of Tech-b nology. I have been employed by Commonwealth Edison since 1941 and have held various positions in the construction, commercial and financial areas of the Co=pany and, more recently, in the Station Nuclear Engi?eering Department and

- in.its predecessor department, the Mechanical and Building Engi~neering Department. .

In 1967, I became the Zion Project Engineer and 1

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was responsible for the review of the design and specifica-l tions for Zion Units 1 and 2 during their construction. In 1972, I became Section Engineer in charge of all pressurized

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~ water reactor plants in operation or under. construction in --

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the co==cnwealth Edison system. This entailed' supervisory

. responsibility for engineering and design of the Byron and.

D Braidwood plants and for modifications on the Zion plant. ,

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0' fy In 1980, I attained my present position, Project Engineering Manager for Byron and Braidwood. I have supervisory control of the engineering work in progress and ensure that the plants will be safe, reliable and efficient, will satisfy industry codes and standards, will satisfy NRC regulations.

and licensing requirements and will satisfy contractual com- ,

mitments and specifi' cations. In addition, I maintain cur-rent knowledge of industry and regulatory deve16pments which may affect the design of the Byron and Braidwood plants.

I have reviewed the " Affidavit of Richard B. Hub-bard and Gregory C. Minor" (the " Affidavit") to determine whether and to what extent the Affidavit suggests the need for modifications to the Byron Station which are not cur-rently included in the budget for that Station and which would likely be required to meet NRC or other regulatory

.equirements. Based on my review of the Affidavit, I con-clude that no plant modifications involving signficant capital expenditures additional to those already budgeted will be required to meet NRC safety requirements.

It is not possible to estimate with any reasonable degree of accuracy the need for potential design and equip-ment r.odifications at a nuclear power station without first carefully reviewing the design, specifications and capability of the equipment one proposes to modify. .The design of the Byron Station is a joint effort of three large organizations with vast engineering expertise and experience. Commonwealth

. Edison Company supervises the overall design; Westinghouse

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["% has designed the Nuclear Steam Supply System and much of the associated equipment; and Sargent & Lundy is the architect-engineer responsible for all balance-of-plant itens. In order to design, fabricate, construct and analyze all of the' various components which go into a nuclear power plant, it-

, is necessary to marshall the technical expertise of many qualified individuals in at least all of the following areas: Nuclear Engineering, Mechanical Engineering, Struc-tural Engineering, Materials Engineering, Envirc.nmental Engineering, Systems Engineering, Electrical Engineering, Instrument and Controls Enginee' ring, Chemistry, Metallurgy, Seismology / Geology, Hydrology, Radiology, Health Physics and Thermodynamics. Any credible review of the adequacy of the O design of a nuclear power facility would have to be done by persons qualified in all of these areas. The NRC, which reviews in detail the design of all nuclear power stations prior to authorizing their construction and again prior to authorizing their operation, has staff personnel and access-to personnel within various National laboratories ,and other.

federal agencies qualified in all of these areas. The.

analysis which Messrs. Hubbard and Minor report in their Affidavit does not appear to have been in any adequate depth at all. I say this because of the extremely superficial level of information regarding the design.of.the Byron.-  :.

- Station reported in the Affidavit.

In reviewing the Affidavit, two significant defi ...

O ciencies in the overall approach became immediately apparent.

D mg I first noted that the discussion contained in the Affidavit regarding potentially expensive modifications to the Byron Station was not in fact based on a review of the Byron Station design or of the budget for future construction ex .

penditures. Messrs. Hubbard and Minor appear to have con-I ducted a review of various NRC generic documents which did not analyze the Byron Station specifically and developed very judgmental estimates of the cost.of correcting certain design deficiencies if they existed. What Messrs. Hubbard and Minor have not done is determine whether these design deficiencias existed at the Byron Station. As I explain below, those design deficiencies identified in the Affidavit may exist at some other plant, but do not exist at the Byron

[ ~ Station, or to the extent modifications, if any, will be required, they will not require significant capital expendi-tures in excess of those already budgeted for the Station. ,

The second thing I noted was that it is impossible to trac'e from the discussion of particular design deficiencies to the cost estimates provided.in Table 5.1-1 on page 80 of

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the Affidavit. The' conclusion of the Affidavit, that large i additional expenditures equivalent to " comparable increase in capital cost" ranging from a low of $785 million to a high of $2.119 billion, was developed from Table 5.1-1. I will, therefore, direct my comments to the Table primarily and only secondarily to the discussion contained in the text

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of the Affidavit.

Specifically, I address the question of .

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( whether those costs which are actually claimed to represent k

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additional construction expenditures under the headings

" Generic Issues" and " Safety Improvements" contained on Table 5.1-1 represent expenditures which may be required at the Byron Station.

The issues are addressed in the order that they appear in the Table. .

A. Generic Issues

1. ATWS (Anticipated Transients Without Scram)

Nuclear. power plants have safety and control systems that limit the consequences of abnormal operating

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conditions, so-called " anticipated transients." Some of

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these transients require the rapid shutdown (" scram") of the f nuclear reactor in order to reduce the amount of heat gene-

- rated in the reactor core. The failure of the reactor to scram following a-transient is the event " Anticipated Tran-sient Without Scram" or ATWS. The consequences of such an event,'if not mitigated, could include core damage. -

Analysis of ATWS events entails the use 'of com-

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puter codes that model core hydraulics, reactor coolani system hydraulics, nuclear core parameters, fuel. rod tem-There has been some disagreement perature and neutron flux.

surrounding the ATWS issue since 1973 when the NRC published '

WASH-1270 " Technical Report on Anticipated Transients With-The indust $y ~ ~

out Scram for Water-Cooled Power Reactors."

maintains that the probability of the event is much lower than.that calculated by the NRC. Vendors and owners have h

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extensively analyzed the reactor protection systems with i a -

regard to common mode and random failures.

The Westinghouse plants, of which Byron is one, are recognized to be least susceptible to an ATWS event.1/ ,

It does appear that the NRC will require additions to the plant protection features, though the additions are fewer

and the cost much less for Westinghouse plants than for reactors manufactured by other vendors. In anticipation of such additions, Commonwealth Edison has conservatively budgeted S1.2 million, which we expect will cover the costs associated with these modifications. It is impossible to tell from the Affidavit what, if any, capital expenditures Messrs. Hubbard and Minor propose as appropriate to modify the

("5 design or operating procedures to mitigate ATWS events.

2. Ecuipment Qualification The issue of environmental qualification of Class lE (sa f ety-related) electrical equipment has been the subject

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of increased NRC attention over the past few years. The NRC

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' Staff'has required that nuclear plant owners develop quali-fication programs based on the requirements of IEEE-323-1971

. or IEEE-323-1974. The Byron program is fairly well established, though actual testing is not completed. The program tests

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equipment to the following conditions, among others:

-1/ NRC Staff document SECY.80-409 " Proposed Rulemaking to '

Amend 10 CFR Part 50 concerning Anticipated Transients

('I Without Scram (ATWS) Events."

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a. Temperature and pressure conditions postulated to be

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present inside and outside the containment following e loss of coolant accident (LOCA) or a main steam line break (MSLB) accident;

b. Containment conditions following chemical spray;

c. Radiation conditions postulated to be present inside and outside the containment following a LOCA; and

d. The effects of aging.

We have submitted the format of our program to the NRC, and we are awaiting a Staff response. There is currently S3.5 million in the budget to cover the testing costs over and above testing costs-that are included in the purchase og price of specific equipment. We anticipate that this budget will be sufficient to meet the costs of equipment testing,-

and do not believe-that the $10 million figure suggested in the Affidavit is justified.

3. Steam Generators ,

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The Steam Generator issue concerns the operational problems which have occurred in the Westinghouse designed,

. recirculation-type steam generators. These problems are

-outlined . in the NRC document NUREG-0523 "Su= mar of operat-ing Experience with Recirculating Stea= Generators" (January, 1979).

The types of operational problems expe ienced are:

. 1. Caustic stress corrosion and wastage; b 2. Denting and U-bend cracking; .

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f8% 3. Tube support plate cracking; and

4. Anv.1-vibration for wear or fretting. )

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We originally addressed these problems in the design of our steam generators as is outlined in Section 5.4.2 of the Byron Final Safety Analysis Report (FSAR). The following design measures are intended to remedy the problem.

1. Inconel-600, a metal which has been shown to be highly resistant to corrosion, was chosen as the steam generator tube material;

2. Tubes are roll expanded to the full depth of the

, tube sheet to eliminate crevice areas in the tube sheet which can cause denting; (og 3. The adoption of all volatile treatment (AVT) chem-istry to minimize tube wall thinning and denting;

4. State-of-the-art design, which has been substan- -- ---

tiated by extensive analyses, to minimize mechani-

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cal and flow induced vibration;

5. A preheat section to evenly distribute flow and

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increase heat transfer; and

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6. A separate auxiliary feedwater nozzle provided in . .

the upper shell to avcid introducing cold water l

into the preheat section, thus avoiding adverse thermal effects.

1 In addition, it.is Commonwealth Edison's practice to limit the use of copper in the secondary systems, thus - ,.

eliminating the introduction of potentially reactive and,

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1 therefore, corrosive copper icns into the water which flows past the steam generator tubes. This is accomplished by replacing the copper alloy, the heat exchance material more commonly used at other facilities, with stainless steel.

We are confident that the operational problems encountered by Westinghouse steam generators have been adequately addressed by the above design features. Our con-fidence is reinforced in view of our excellent experience with the Westinghouse steam generators at the Zion plant where AVT chemistry, sound operational procedures, cleaning methods and frequent inspection have prevented any signifi-cant steam generator tube degradation. The $100 million og additional cost for ; team generator replacement quoted in the Hubbard-Minor Affidavit is a cost we do not expect to incur.

4. Fire Protection Protection against damaging fires is incorpcicted throughout the. design of the Byron Station. Fire Protection issues have been addressed in the FSAR for the Byron Station and again in our response to Appendix A of NRC Branch Tech-nical Position APCSF, 9.5-1, submitted to the NRC for review in October, 1977. This-latter submission has yet to be reviewed by the NRC. However, the NRC has required the operating plants and plants that are close to obtaining an operatir.g license to perform a Safe Shutdown Capability

( analysis in the event of a fire, and the same type of analyses .

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1 f"\ will be done for tb> Syron Station in 1981. In significant part, the analyses ct.:tain the following elements:

1. Identification of the primary systems and support systems and components that are necessary for safe  !

shutdown.

2. Identification of all equipment locations and i

determine'which fire areas contain components and electrical cables necessary for safe shutdown.  !

3. Determination as to which ftre areas contain com-ponents and electrical cables of redundant safe shutdown primary and support system and co=ponents.

4. Determination as to what modifications, if any, are necessary to ensure that all plant areas have  ;

(*\ one safe shutdown method independent of the area.

The analysis which will be performed with respect

, t to the Byron Station-is substa-tially similar to the analysis ~ .

performed at the other nuclear st'ations on the Commonwealth - - --

Edison system. The modifications resulting from these other- . -

analyses, which have been incorporated into the Byron Station, -  :

design, are. approved by the NRC. We do not anticipate any ,

major expenses associated with further modifications which may be required to address the Fire Protection issue.

5. Systems Interaction As a. result of a Westinghouse investigation into.

t system-interactions, four areas were identified where environ-f"\

mental conditions due to control-system failures following a

high energy line break had the potential to adversely affect

("h the performance of safety systems. The four scenarios were reported to the NRC anc an II Information Notice was issued to all utilities to investigate control failures. We revieged the four scenarios and performed the evaluations necessary-

, to predict the effect on safety-related systems. Our con-clusion was that no ' modifications were required.

Additional systems interaction evaluations may be required. The Zion plant, which is similar to the Byron Station, has performed such a study, and the modifications that resulted were minor. We do not anticipate that any additional system interaction study will show a need for significant additional expenditures.

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. 6. Three Mile Island Issues The requirements resulting from the Three Mile Island incident have been fairly well defined by the NRC

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documents NUREG-0578, NUREG-0660'and NUREG-0737. There are still some elements that are under discussion, such as sit-ing and shielding requirements for the Emergency operations Facility and qualification requirements of in,strumentation.

Based on the published requirements and allowing for some uncertainties, the Byron Station budget was increased by

$75 million to cover the anticipated cost associated with Three Mile Island-induced modifications. Some of the major items in the budget consideration were:

1. The addition of a reactor vessel level measurement f*h system

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("% 2. Construction of a Technical Support Center

3. Modification of the post-accident sampling system

4. Plant shielding review and plant modifications.

The testimony and exhibits which Mr. Byron Lee, Jr.,

filed in Docket No. 78-0646 addressed the Three Mile Island issues and related budget modifications in detail. As pre-viously stated, Edison has budgeted $75 million for such i

I modifications. The Hubbard-Minor Affidavit states that the expense associated with Three Mile Island modifications will total $30-50 million. Although I consider the Edison esti-3

, mate more realistic, whichever estimate is correct, the Byron budget will not have to be adjusted upwards.

B. Safety Issues The two items listed in this portfon of Table 5.1-1 overlap and are both encompassed within the concept of Class 9 modification.

Messrs. Hubbard and Minor discuJs all ~

1 of these issues as if they are totally independent,-indicat- .

ing that they do not fully understand the issues. The five - -

2 research programs / described on page 69 of the Affidavit are specifically aimed towards mitigation or prevention of a 2/ Although.the Table refers to the " Fire Research Programs,"

I am assuming that the authors of the Affidavit actually

, . intended this category to refer to the "Five.Research__'

'rograms." This assumption is consistent with the dis- _ _ . _

cussion at page 69 of rhe Affidavit referring to the five research projects undertaken by the NRC and the

_. fact that the Table includes " Fire" as one of the'sub-f")

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categories under " Generic Issues."

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l f"% core melt type Class 9 accident, and the discussion of Class 9 accident requirements includes the concepts of those research programs. The NRC has recently issued an Advanced Notice of Proposed Rulemaking (4 5 T.R. 65474) to " determine' to what extent . . . nuclear pcwer plants should be able to cope with reactor accidents beyond those considered in the current ' design basis accident' approach." The Notice lists

, a series of 18 questions to be considered by the industry.

The issues dealt with in this proposed rulaqaking cover, in part, the following:

a. Additional decay heat removal systems

b. Hydrogen control

c. Core retention system O d. Engineered safety system fcilure to operate

e. Controlled filter venti:.g of the containment

f. Operator training and procedures

g. Design, quality and seismic criteria .

h. The use of probabilistic analysis .

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Commonwealth Edison is involved in preparing' a~ - - ' ~~

probabilistic ri'k s assessment study for the Zion plant. The-l analysis incorporates, in part, the follow.'.ng elements:

1. Component and system analysis and interaction;

2. Analysis of core mel phenomana and resultant

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radica:tive material release;

3. Structural analysis of containment features;

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g!h 4. Release radioactive plume analysis;

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• mg 5. Calculation and application of probability numbers with a resultant probability of release; and

6. Detailed seismic analysis of the plant structures.

Based on preliminary results from this study, it appears that major equipment modifications or additions are not required to prevent or mitigate a core melt accident.

In summary, it is my opinion that the cost esti-mates presented in that portion of the Hubbard/ Minor Affi-davit under the heading " Outstanding Safety Issues," and summarized under the headings " Generic Issues" and " Safety Improvements" on Table 5.1-1, were not based on any review of the specific design of the Byron Station. The detailed a design of the Byron Station has progressed significantly over the course of its construction, and the Company has carefully monitored developing NRC licensing requirements. ..

, In my opinion, the current total budget for the Byron Station -

will not increase by any significant amount due to addi- -

tional desiya modifications or equipment additions.

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• L. STATE OF ILLINOIS ILLINOIS CO.vy.ERCE COMMISSION

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In the Matter of ) ,

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Commonwealth Edison Company ) 80-0760 Application to Halt Construction )

of Byron Nuclear Power Station, ) g

• Units 1 and 2 g

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YE 31981 > .

AFFIDAVIT OF J10'.ES D. DERESS '

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COUNTY OF COOK )

I, James D. Deress, being first duly sworn on oath O state that I have prepared the attached Affidavit of James D.

Deress and that the statements contained therein are true and correct to the best of my information, knowledge and belief.

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James D. Deress SUBSCRIBID AND SWORN TO before me this 19th day of December, 1980. - -

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• Q Norary Public My commission expires: , spe .N '

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