ML20042A624
| ML20042A624 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 03/10/1982 |
| From: | Tramm T COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 3608N, NUDOCS 8203230622 | |
| Download: ML20042A624 (19) | |
Text
{{#Wiki_filter:*
- h Commonwealth Edison
) One First Nitionit Plata, Chictgo. Ithnois C-- ~) Addrsss Reply to: Post Office Box 767 (Ng Chicago, Ilhnois 60690 March 10, 1982 s
REC 3VED Mr. Harold R. Denton, Director 4) Of fice of t4uclear Reactor Regulation MAR 2219825 '71 Bacar w U.S. Nuclear Regulatory Commission m Washington, DC 20555 *mr$7 8
% tp
Subject:
Byron Station Units 1 and 2 i Draft Environmental Statement NRC Docket Nos. 50-454 and 50-455 Reference (a): February 11, 1982, letter from B. J. Youngblood to L. O. DelGeorge.
Dear Mr. Denton:
This is to provide responses to comments on the Byron Draft Environmental Statement whi;h was sent to Commonwealth Edison in reference (a). Attachment A to this letter contains those responses. Please address questions regarding these responses to this office. Very truly yours, T/L TA4~ T.R. Tramm Nuclear Licensing Administrator im Attachment 3608N V fo0y\ 0203230622 820310 PDR ADOCK 05000 h D
ATTACHMENT A Commonwealth Edison Responses to Comments On The Byron DES from: Army Corps of Engineers Department of Agriculture Department o f Interior Environmental Protection Agency Patrick Carnahan Deparment o f Human Services Illinois Department o f tOclea r Sa fety Department of Energy 3608N
s . . Department of the Army Corps of Engineers i Comment: Paragraph 2, sentence 1 - Please add 33 USC 1344 to both entries for permits required from the U.S. Army Corps of Engineers. Response: 33 USC 1344 has been added to both entries for permits required from the U.S. Army Corps of Engineers in Table 12.0-1 of the Byron ER-OLS, Amendment 3. United - States Department of ' Agriculture, Forest Service Comment 1: Paragraph 3 "On page 5-1, in the last paragraph, the last sentence states, " ... . some low quality agricultural land will be removed from production and allowed to revert to a natural state." We would recommend that some estimate be included on the amount of land that is involved and that the statement, " allowed to revert to a natural state." be modified to indicate some form of management will be applies to this land, i.e., wildlife habitat, woodland." I Response: The applicant proposes to convert approximately 325 acres of low quality farmland to wildlife habitat by a combination of natural succession and the planting of permanent ground cover. I i 2853a
i 'r > United States -Department of Interior 1 i Comment 1: Surface and Groundwater The hydraulic conductivities determined by tests in two i domestic supply wells that tap the Galena-Platteville dolomites are 2.2 1pd/m2 and 7.8 1pd/m 2 . These units ! i (1pd/m ) are customarily used for the expression of the 2 field coefficient of permeability, whereas hydraulic conductivity is expressed in meters per day (m/d). - (See Lohman, S. W., 1972, Ground-water hydraulics: U.S. Geological Survey Professional Paper 708, p. 5). Because the ratio of hydraulic conductivity to the field coefficient of permeability is 1 to 7.48, the two characteristics differ j considerably in numerical magnitude. Classification is needed as to which characteristic, hydraulic conductivity or field i. coefficient of permeability, is meant on page 4-35. a i Similarly, we believe that the units given for transmissivity l in Section 5.3.1.2 may also be in error. The transmissivity is given as 13,650 liters per minute per meter (imp /m) whereas the customary units are square meters per day (m2 /d). In this case the use of the units given on page 5-2 would , indicate an unbelievable high transmissivity. These [ discrepancies should be clarified in the final statement. Response: The above comments are valid in that the units quoted in the DES are not correct. The hydraulic conductivities determined by tests in two domestic supply wells that tap the Calena-Platteville dolomite like should be 0.26 m/ day and 0.90-m/ day, rather than 2.21 1pd/m2 and 7.8 1pd/m2 , ! respectively in the first paragraph. In response to the comments in the second paragraph, 2 the coefficient of transmissivity should be 211m / day rather than 13,650 1pm/m. Note that the reported transmissivity should read 17,000 gpd/ft, rather than 17,000 gpm/ft. 1 Comment 2: Intake Ef fects, -Paragraph 1, Sentence 4.
"We would appreciate the applicant keeping the Rock Island Field Of fice of the U.S. Fish and Wildlife Service informed of the monitoring activities and findings."
Response: The applicant will inform the Rock Island Field Office of the Fish and Wildlife Service of the findings of _ the special study addressing the Illinois Department of Conservation concerns and the NPDES monitoring program. 4 i 2853a i i
, , _ - - , - - . ,,.,-r, - , , - , m _ , . ,.sy... .,,,_y..m- , m- g,-, . ,, , . - - e , ..--.-,..,-r-,m ,
linited States Environmental Protection Agency - Region V Comment 1: Page 1 (attachment) - Exposure Pathways "The final environmental impact statement should discuss the reasoning for not assessing the drinking water pathway." Response: The DES discusses the drinking water pathway for the Byron Station in terms of the " Liquid Pathway Generic Study" and also discusses where the anticipated effects would likely be far less based on mitigation actions that likely would be taken (last paragraph, page 5-57). Five additional reasons are pat forth on page 5-59 of the DES that indicate the estiraates are conservative. It is CECO's position that: 1) the updated Reactor Safety Study grossly overstates the probability for penetration of the basemat of the containment building which would result in the release of molten core debris into the strata beneath the structure; 2) the factors discussed above indicate that the DES estimates of consequences is ,onservative if penetration were to occur; and 3) therefore, additional analysis of this scenario is not warranted. Comment 2: Page 1 (attachment) - Radiological Impacts on Man - paragraph 1 "This station (Byron) will have to limit radioactive releases to the environment to those specified in 40 CFR 190. Since this station is not an operating station, information on how other similar stations operated by the Commonwealth Edison Company have complied with these regulations should be provided. The final environmental impact statement should l indicate under what, if any, circumstances compliance with the regulations (40 CFR 190) will not be achieved." Response: Commonwealth Edison Company is committed to meeting the dose limitations of 40 CFR 190 at its operating nuclear power stations. The Zion nuclear power station, which is similar in design to E,ron, has operated since 1973 with an average calculated whole body dose to a hypothetical individual living at the site boundary of less than one millirem per year. Consequently, we feel that the requirements ot 40 CFR 190 will be achieved at Byron. We Jo not anticipate than any normal plant operations will cause noncompliance with the regulation.
Comment 3: Page 1 (attachment) - Radiological Impacts on Man paragraph 2 "The final environmental impact statement should indicate the levels of radiation which an individual could expect to receive from the Byron Station to substantiate negligible impact." Response: In appendix C of the DES, calculated dose commitments to a maximally exposed individual for Appendix I and RM-50-2 guidelines are contained in Tables C.7 and C.8, respectively. These calculated doses are well below their respective design objectives as indicated in Tables C.7 and C.8 and a small fraction of CECO's 135 mrem / year estimate for.the average dose to an individual from natural background radiation (Table 5.2.-11, Byron ER-OLS). P Comment 4: Page 1 (attachment) - General Characteristics of Accidents - paragraph 1 "We suggest that the environmental impact statement include a map which shows the Exclusion Area, Low Population Zone, Emergency Planning Zones, etc. This would provide an indication to the general public where these areas are in relation to their town, homes, schools, etc." Response: Attached is a figure that indicates the site exclusion area and the 10 mile emergency planning zone on a map showing the roads in the area. Local residents should be able to locate points that are of interest to them. We did not show the low population zone because of its lack of significance to an operating station. If the staff wants to include a figure showing the 50 mile radiological assessment area we recommend using a figure from the Byron ER-OLS - Figure 2.1-10. I 7 l
9 Comment 5: Page 1 (attachment) - General Characteristics of Accidents - paragraph 2 "A full review of the Radiation Emergency Response Plan for the Byron Station has not been completed, tested or reviewed by the Federal Emergency Management Agency (FEMA) and the Regional Advisory Committee. We note that a thorough evaluation of the ability of all parties to handle accidents is not feasible at this time, and will have to await future actions by FEMA." Response: CECO is in agreement with this assessment. Comment 6 : Page 2 (attachment) - Accident Risk and Impact Aasessment - paragraph 1 "The Final Environmental Impact Statement should discuss why the staff believes "a factor of about three times higher than those of the LPGS small river site; in light of the above figures, was selected and determined to be conservative." Response: Response to Comment I above applies equally to this comment. Comment 7: Page 2 (attachment) - Radiological Monitoring "One of the (radiological) programs to be discontinued is vegetable sampling. We assume the reason for stopping this monitoring program is because there are no vegetable farms near Byron Station, but the final environmental impact should indicate the reason why vegetable monitoring will cease." Response: The deletion of vegetable sampling in the third year of the final monitoring program is for conformance with the Standard Environmental Monitoring Program being conducted at the operating CECO nuclear sites. This program was negotiated with and approved by the NRC staff, for use at the CECO facilities. Deletion of vegetable sampling was justified on the basis of a lack of positive results attributable to nuclear plant operations on ruffage samples analyzed through 1977. Consequently, the NRC staf f agreed to the deletion of vegetable sampling, on a case-by-case basis.
. . - __ - -.- - -~ -. - _ _ _ .-
i
-Comment 8: Page 2 (attachment) - Decommissioning "A statement should be made here that decommissioning of a
.! commercial nuclear power plant has not yet occurred in this l country, even though the technology may be available to handle .; it. Therefore, this section should reflect this as a judgment i, of the Nuclear Regulatory Commission staf f not as an j accomplished event." Response: CECO is in general agreement with the DES assessment of environmental impacts from decommissioning and that the ! technology is available to decommission nuclear facilities. t I f i i i i I l 2853a l l l 1
Patrick Carnahan, 92 Lawrence-Drive, Longmeadow,-Massachusetts--01106 Comment 1 Paragraph 2, sentences 2 and 3 "I would like to know just what kind of herbicide is to be, or planned to be, used, and, how much and how often it will be used. I would like to point out that the herbicide 2, 4, D, an herbicide commonly used by power companies, is a harmful chemical agent that af fects not only animals, birds and plants but also humans as well." Response: The maintenance program used to control tall growing trees on the Byron Station transmission line right-of-ways includes the use of some herbicides. 24D is an approved herbicide and may be used in this program but it is not one of the primary herbicides. Materials such as Banvel 720 which does contain the Dimethylamine Salt of 24D and Hyvar X-L are the commercial names of two of the currently used herbicides. Banvel 720 is used on the stumps of trees which have been cut to prevent their regrowth and Hyvar X-L is used on a selective basis as a It is not possible to estimate the l brush and tree killer. volume of herbicide that will be used as that is dependent on the number of trees that resurge and threaten to interfere with the transmission lines. It is estimated that the r i gh t-o f-ways included approximately 128 acres of wooded land all told so with the selective control methods described above the volume of herbicides used will be minimized. The f requency of application is planned to be about once every five years. All herbicides used in the control programs will . he applied in accordance with the restrictions stated on the registered container labels. Comment 4: Paragraph 5, sentences 1 and 2 "I also disagree with you(r) s ta temen t in Section 3.1, on alternatives. You say "at the operation license stage it is not rational to consider dif ferent sites, extensive plant modifications, or the construction of new and different energy sources as alterna-tives to the existing nuclear facility." Response: We are in agreement with the statement in the DES that alternative sites, alternative energy sources and extensive plant modifications are not ripe for reconsideration at the OL review. These matters were resolved during the proceedings for issuance of the construction permit for Byron Station. The issue now at hand is whether an operating license for Byron Station should be issued or denied rather than should another facility be constructed at a different site or utilize a dif ferent design or energy source or a combination of these factors. The commentor, Mr. Carnahan, did nc' ,ffer any new
f information that would indicate consideration of such alternatives are likely to justify denial of an operating license for Byron Station. l I t 2853a
Department of Human Services Comment 1-Item (3) The evacuation model presented in Appendix F.1 is based on Par. 1: assumed conditions and capabilities to evacuate people to specific downwind directions. Since evacuation involves early and expeditious movement of people to avoid exposure of the passing cloud and acute ground contamination following cloud passage, it would be helpful to include references to show that studies either have or have not been made to verify the model and to demonstrate that evacuation is feasible for the specific facility covered by the EIS". Response: The model referred to in Appendix F.1 is a NRC evacuation model and we are not .able to provide the details requested. Comment 2 - Item (3) "In our view Section 5.9.4.4 (3) on emergency prepardness is Par. 2: not adequate to meet planning needs." Response: As stated in this section, the emergency preparedness plans are not yet fully completed. On this basis CECO agrees that a final decision on this issue cannot be made at this time. Comment 3 - Item (3) "The accident risk and impact assessment presented in Section Par. 3: 5.9.4.5 is considered to be an adequate analysis of potential accidents in relation to the dose and health impact on the population from atmospheric releases." Response: CECO considers the accident risk and impact assessment presented in Section 5.9.4.5. to be conservative as per our comments on ER-OLS Q371.10 ( Amendment 3). 4 i i
-, . - . - - - - - - . . - - . - c ,
r- . . . - - - , , ,7- . - . ..
1 Comment 4: In view of the monitoring problems that were identified during Item (4) the Three Mile Island - Unit 2 accident, we suggest that the plan be modified to address the particular problems of monitoring radiohalogens (especially radioiodine) in the presence of radionoble gases. This could be accomplished by reference to FEMA -REP-2, a document on instrumentation systems prepared with considerable input from NRC. Furthermore, it would be helpful to cite specific studies at operating plants that would verify that the instrument systems for making such measurements actually perform as expected and meet the technical requirements. Response: In the event of an accident at one of the Commonwealth Edison Company's nuclear stations, specific procedures which have been developed for environmental monitoring would be implemented. These procedures include (1) the use of alternate sampling media to reduce noble gas interferance with l radioiodine measurements and (2) designated instrument systems to be used for these analyses, based on NRC guidance. t Comment 5: "Section 5.10 and Appendix G contain a description of the i Item (5) environmental impact assessment of the uranium fuel cycle. The environmental effects presented are a reasonable i assessment of the population dose commitments and the health ef fects associated with the releases of radon-222 from the Uranium Fuel Cycle. Response: CECO is in agreement with this comment. i i 2853a
}
l Illinois Department of Nuclear Safety Comment 1: A. Circulsting Water and Non-Essential Service Water Systems - Section 4 2.3.4.1 This section indicates that sponge rubber balls will be used to wipe the condenser tubes clean of biological growths as an aid to biofouling control. What analysis has been performed examining the af fects of the introduction of these sponge rubber balls into both the Rock River via normal blowdown and into the pumping and internal system of the natural draft cooling tower? How does this system compare to that system already in use at the Zion Nuclear Power Station? Response: The Amertap System utilizing non-toxic sponge rubber balls for cleaning condenser tubes is used at both our Zion and Collins Stations. We are not aware of any problems caused by released balls in any piping or pumps or in the environment. The Byron system is similar to that at Zion Station with some improvements, however, that should reduce the number of balls released. Presently at Zion we lose about 3000 balls on a three shif t cleaning cycle. At our Collins Station, we lose from 200 balls every 6 months on the best unit to 500 balls every 45 days on the unit with the least effective reclaim system (all units are 500 MW). Comment 2: B. Radioactive-Waste Managment System - Section 4.2.5
" Item 3 in this section indicates a change in the design of the ventilation system filtration path for the main condenser air ejector and auxiliary fuel and waste buildings' discharge exhausts. This design change, since the construction stage permit, utilizes only a HEPA filter. The new design does allow the discharge paths to be diverted, presumably by operator action, to a path containing a HEPA filter, charcoal absorber and another HEPA filter, all in series, if a high radiation signal is present. In Section 5.9.4.4, " Mitigation of Accident Consequences", it appears that credit is taken for the use of the former design ventilation pathway of a direct filter-absorber-filter series. What controls, commitments, equipment qualitifcation or technical specification requirements will be imposed to assure that the rediverting actions are tanen for nitigation of
~
accident consequences?"
s . .
/
Response: The transfer to the HEPA filter, charcoal absorber, HEPA filter is done automatically upon sensing of high radiation levels. This sytem is similar to that installed in our Zion Station. Comment 3: C. Radiological - Section 5.9 (1) Section 5.9.1 discusses the Regulatory requirements used in the assessments for protection against radiation. The present version of 10CFR20 is cited, but what consideration or assessments have been made for this evaluation in light of the proposed revision of 10CFR207 Response: C.E.Co. is following the development of the proposed revisions of 10CFR20. The draft revisions are not to the state where we can anticipate the final regulations and assess their impact on Byron Station. Comment 4: C. Radiological - Section 5.9 Subparagraphs (2), (3), and (5). Response: These considerations deal with the NRC staff's analytical techniques and evaluations. CECO's position is spelled out in responses to Byron ER-OLS Q371.10 where we state that we are in agreement with the conclusions reached but believe the assessments are overly conservative. Comment 5: Sections 5.9.4.4, " Mitigation of Accident Consequences", and 5.9.4.5., " Accident Risk and Impact Assessment" indicate that ' this report does not take credit for the TMI-2 related requirements specified in NUREG-0737 and NUREG 0660, which apply to the Byron Station. Please provide a brief synopsis of the applicable requirements and a schedule for completion. Response: The NUREG-0737 and NUREG-0660 requirements as they apply to Byron Station are adequately covered in the Byron FSAR - Appendix E and the Byron SER. 2853a
r . . U.S. Department of Energy Comment 1: Reference DES Section 2.1, paragraph 1, sentence 3 "Should this be 1975?" 4 Response: The period in question was from the Construction Permit Environmental Report and 1973-1982 is correct. Comment 2: Reference DES Table 2.1 - (a) llow does grouping relate to the grouping in Table 2.27 (b) What % of energy came from hi and 10 sulfur? (c) What percent of energy came from these sources? (d) Where is the cost of purchased energy? (e) This implies that gas was not used in steam plants in 1980. Is this implication true? Response: (a) There is a direct relationship except that high and low sulfur coals are combined in Table 2.2. (b) Referring to Table 2.2, the total energy generated by coal is shown as 29,559 GWh of which 23,849 GWh came from low sulfur coal and 5,710 GWh came from high sulfur coal. (c) Steam cycle oil produced 6,808 GWh and combustion turbine oil produced 153 GWh. (d) The 1981 cost of purchase - economy was 40.2 mills /kWh (see response to Q320.8). (e) 52,205,000 therms of gas was used in steam plants in 1980, 491 GWh was generated from this fuel source (see Table 2.2). Comment 3: Reference DES Table 2.2 - (a) What % is high sulfur, low sulfur? (b) What % is steam, C.T.? Response: (a) See response to Comment 2(b). (b) As listed in Table 2.2 Steam Cycle Oil and combustion turbine oil are shown separately.
t J Comment 4: Reference untitled table at the top of page 2 How was this table computed? Where is the source of data? Response: The 1980 fuel costs, provided in the Response to Q320.3, were escalated as stated in the last sentence on page 2-1. See CECO comments on DES page 2-4, Section 2.2 for expansion of fossil fuel categories and costs. Comment 5: Page 2-4, paragraph 1, sentence 1 "Should this word be
" constant?" or is it intended to say that the escalation rate is equal to the discount rate?
Response: " Cons tant" is preferrable. Comment 6: Page 2-4, paragraph 3, sentence 5 "Immediately on retirement?" and "1978 dollars?" Response: CECO provided revised estimates of decommissioning costs in Section 5.8 of the ER-OLS, Amendment No. I which are stated in 1981 dollars. Comment 7 : Reference Table 2.3 "how was this table obtained from the source material with preceding tables? The procedure is not apparent." Response: Fuel costs are from table on page 2-4,' see response to Q320.8 for replacement energy estimates. Comment 8: Re ference Table 2.3 "296 MW rather than 29.6 MW." Response: 296 MW is correct, see CECO comments on DES which contain this correction. _- . . ~ . . . , , . - . ._
, e . . Comment 9: Reference Table 2-5 "Should this be " Energy Generated" or
" Energy for Load?" and "according to Table 2.2 energy ' for load was 66,946 GWh and energy generated was 62,819."
Response: As shown in DES Table 2.2 and in CECO response to Q320.3, 66,946 GWh is the total energy for load and 62,819 GWh is the total energy generated. i Comment 10: Page 2-9, paragraph 3, sentence 1 "do any of the Reserve Margins in Table 2.6 have the same definition as this?" Response: Line 10 of Table 2.6 represents the CECO projected reserve margin with Byron Units 1 and 2 in service. See CECO's comments on the DES for corrections to Table 2.6.
"How do you know, this is Comment 11: Page 209, paragraph 4, sentence 2 speculation and what are they?"
Response: In 1982, CECO is purchasing power to make up the reserve deficiency. Comment 12: Reference Table 2.6 "Can any of the reserve margins shown here be properly compared with the CECO 15% installed reservu margin?" Response: Line 10 of Table 2.6 as corrected by CECO's DES comments represents the projected installed reserve capacity. Comment 13: Reference Table 2.6 "The margins are af ter scheduled outages, i Is the CECO 15% margin also after scheduled outages?" Response: Yes it is.
i a e . 6 Comment 14: Page 2-11, Section 2.5, paragraph 1, sentence 3 "you have not shown:
- 1) What the capacity mix is in terms of percentages of (coal, oil, gas, nuclear) and
- 2) What is considered a desirable mix and why."
Response: 1) The capacity mix is shown in Chapter 1, page 1.1-1 of the Byron ER-OLS.
- 2) The long term achievement of a desirable mix of generating capacity is an objective that goes beyond the abort term ef fect of the contemplated action. When the next capacity addition is planned all technically proven and economic options will be considered.
2853a
\.
I WW,_ l g 3 o ' m w-+s, %#bgabia
" 3 5-4m . 13c
-{jQ
- r ; i % '
p ff~.=f'
$- Y L ef ']La y __ # ..
j g a %4 r.
,10 Mid'Z
- -' A / 'd dg w kgj 4E h '>x, M,otEv -# '
-__Jfi=7 j f .
w m'. y%T , > iRh}1 l M, +d
,gA z- A t -
-4 .
~
r ',fw( -I - - r 9 ,,,, m A 'Ik 6mdS l bi _%.w' 5 gI
/
\~' '] 4;j, v " "
f-Q= - [V
- c' irom N9,M< ,L *e d q 1 j dl r;. ,2 - ,
3 31 -)WW, Y l i
/d i r o ,--1 '
~
A 8T .,"
- _~
g?. %.mAm "* g , 1h3 t 4,6i. fl ,- <- E%CwStod man iq=r :
,s I
a h' __ I 5hi
-- l .
4 c,i s It - 5C=43_ (' -t_ L JL k> B h-b l.w[. so
- - ~
# N. < -
h
# \
LMt , . . m-7 () p 1 s b =r N J- A '1 P - f 11 . TV E Er ,
-h ,. - 7
* "" t k i b k
" %. qca j.
u. dJ - 4M
/ .
- ~
Pino n==
.- s'- ~
/ g s,
y, a r i N ._ gr M N f" \ ~~ 3 ) i d_ - h,m 1 m; ' i
~__7 _ , t . _, , bg f - m
)'c-(I sa J "
# Itw:EST Z \y -
a r 67 dm
~, 'fy
,W '
l .,a* .. D a g[ r ' pf ) - , ,, _
\ MN C 6
~
[k,.d, a -
)~ q ' '- k /
./ -
,~
' -= %.N
~
~~
c e V l h . _. &n* G~S - 1 l Y _ 1 %
"' "~
If1 [3N i b G- 2
~ "
l L' F l" r-
~
1 s g'g'T"'"y].- , L:!. e wery=rc%[ . . , a
- -'~' -
3 [ ( ql t _i N
'E s i s
~
i . i I *
/ v. ) jb ~
U s f" ~
,~s a
\
f
)%
y I u, W r
/
0 d
'* ~~~
3 s a ms D h:. l ', , - k, bb, _ , [l<n.... G e] W % , y -- W_ - b i Ph~ ~C SCALE se
'" f
- 24 kliemeters e a se g
ITION EICLEAR GER_ERAllNC STA110M E 51T 5 1&2 BYRot4 STATION ExtwsiO4 : AREA AND 10 MILE EMERGENC.4 PLANN14G Z.ONE
- . ._ _ .}}