ML17174A178
| ML17174A178 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 11/19/1979 |
| From: | Berick D ENVIRONMENTAL POLICY INSTITUTE |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7911210518 | |
| Download: ML17174A178 (1) | |
Text
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Mr. Herald Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Connnission 1717 H Street N.W.
Washington, D.C.
20555 Dear Mr. Denton; Environmental Policy Institute 317 Pennsylvania Ave. S.E. Washington, D.C. 20003
~Q2/544-8200
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November 19, 1979
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'° The Environmental Policy Institute urges you to accept the September 20, 1979 petition of the Illinois Safe Energy Alliance requesting public hearings on the decontamination of the Dresden Nuclear Power Station, Unit 1(44 F.R. 64577, Novem-ber 7, 1979).
As the Institute connnented in its response to the Advance Notice of Proposed Rulemaking on 10 CFR Part 61 concerning Management and Disposal of Low-Level Wastes by Shallow land Burial and Alternative Disposal Methods(43 F.R. 49811, October 25, 1978), a number of concerns have been raised about the disposal and migration po-tential of low-level wastes resulting from decontamination operations.
- Means, Crerar, and Duguid(Science, Vol. 200, 30 June 1978) identified mobilization of radionuclides from shallow disposal trenches due to organic chelating agents in-corporated in the disposed wastes.
We-note that NRRts response to such concerns has been to reconnnend that decontamination wastes be sent to "dry" disposal sites.
This seems to be an unsatisfactory resolution of the problem.
Our concern is heightened by recent work done at Brookhaven National Lab by Dr. Hersh Manaktala on the solidification process and corrosion potential of the Dow Chemical "NS-1" decontamination solution.
While the preliminary in-formation made available by Brookhaven indicates a substantial amount of leeway in the actual solidification process, a significant potential for corrosion of steel waste containers exists from the solution itself.
Additional data on the leachability of contained radionuclides and chelating agents from the solidified NS-1 waste forms has yet to be released.
We believe that the NS-1 solidification process and durability of the re-sulting waste form(including container)is sufficiently untested and uncertain to warrant the requested hearing.
The NS-1 decontamination solution i ss.i1~
is not only pertinent to Dresden but to all solidification and disposal situations where similar chelating agents are used.
NRR must address the issue of ultimate disposal of these materials, not simply the on-site application of them.
cc:R.E. Browning
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