ML19249E134
| ML19249E134 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 09/20/1979 |
| From: | Shineflug M ILLINOIS SAFE ENERGY ALLIANCE |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7909260437 | |
| Download: ML19249E134 (3) | |
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l.S.E.A.
ILLINOIS SAFE ENERGY ALLIANCE P.O. Box 469 Antioch, Illinoic 60002 Meetings:
407 South
Dearborn,
Room 370 Chicago, Illinois 60605 September 20, 1979 PETITION FOR HEARINGS ON DECOMPAMINATION OF DRESDEN I. Morris. Ill.
Dr. Harold Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Connission Washington, D.C.
20555
Dear Dr. Denton,
Under the provisions of the U.S. Nuclea-Regulatory Commission Rules and Regulations, Part 2.206, I, Marilyn Shineflug, with the support of members of the Illinois Safe Energy Alliance, request that public hearings be held on the decon-tanination of the Dresden I nuclear reactor near Morri. Ill. Since there is no assurance that the N.R.C. will decide to complete a formal Environmental Impact Statenent for this experimental project, public hearings are needed to: 1) answer previously unanswered or inadequately answered questions; and 2) investigate the significance of new inforntion regarding possible environmental and health effects of decontamination. Accurate, complete answers are needed to the following questions:
1.
What effect(s) will the admittedly corrosive solvent NS-1 have on the reactor's piping system? As stated under Category A Technical Activity No. A-15. "The primary NRC concern related to the decontamination is to assure that the decon-tanination method does not degrade the intogrity of the prinary coolant system boundary. This consideration involves both immediate degradation during de-contanination and latent effects that could cause degradt. tion during subsequent operation of the reactor." How can all the crucial welds, valves and joints, etc.,
many of which are inaccessible, be inspected to assure decontamination has not caused damage?
2.
What standards or guidelines will be utilized for "' baseline' inscection and appropriate followup inscections to provido a high degree of confidence that no degradation has occurred"? Reliance on existing Technical Specifications and "stecial inspections" seems inadequate in light of the folicwing NRC admission:
"Since this is an area @econtaninatior-] where the NRC staff has limited exoertise and experience with comnercial nuclear power plants, it will be difficult to establish the necessary meaningful guidance-and criteria for the decontanination of operating reactors in advance of these anticipated licensee submittals."
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on Decontaminatian and/or a Regulatory Guide which identifies acceptable methods of decontamination and establishes materials testing criteria that must be satisfied to qualify each decontamination method for licensing approval.
Whether or not a Regulatory Guide has been published may be-moot if Regulatory Guides are not enforceable. However, since the integrity of the primary coolant system is essential for protection of the public health, decontanination should not eroceed until this imnortant unresolved generic safety issue is resolved.
3)
Whether or not decontamination wastes can accurately be classified as " low-level" remains unanswered. What radionuclides and in what concentrations are expected besides cobalt 58 & 60, cerium, manganese, zirconium and cesium? According to NRC information, 3000 curies of radioactive material will be removed and eventually placed in 1200 55 gallon drums. E the radioactive materill is uniformly distributed throughout the solidification agent, one can conclude each barrel will contain 2} curies of radioactivity of 12,500 nanocuries per gram. Can waste with this concentration of radionuclides be defined as low-level? What assurances does the public have that significant amounts of transuranics won't be present? According to Mr. Steve Iange of Commonwealth Edison, "transuranics are not expected," but apparently their presence cannot be ruled out. If the waste contains 10 or more "nanocuries of transuranic. contaminants per gram of material," where will it be buried? Or will it remain at the Dresden site forever as stated by Mr. Lange?
4 What is the long term environmental impact of combining radioactive waste with chelating agents? As you know, Drs. Means, Crerar and Duguid found chelating agents to be the very agents responsible for radionuclide mobilization at Oak Ridge,Tenn. (See Science, Vol. 200, June 30,1978) The NRC response that decon-tamination wastes from Dresden I will be buried in " dry" areas is not adequate in light of man's inability to predict climatic conditions over the long time scars this waste remains dangerous to life. Furthernore, radionuclides can leach out (in a manner similar to the operation of a flea collar) even in dry areas and be carried fron original turial sites by scant amounts of rain water. At least one recent study shows radionuclide-chelate complexes are persistent over time and can readily be taken up by plants, etc.
5 How stable will the vinyl ester plastic resin be which is supposed to encapsulate the decontamination wastes? According to NUREG-0471, "There are no current criteria for acceptability of solidification agents." Therefore, what is the basis established by the NRC (and not Dow Chemical or Connonweal;h Edisen) for concluding this solidification prtcess will be acceptable? What consideration has been given to the fact that organic solvents present in much radioactive waste can dissolve the Dow solidificativa agent?
6.
What are the maximum levels of radiation exposure workers could receive while carrying out decontamination? What are the expected levels of radiation exposure workers ray receive? If NS-1 is regarded as corrosive or a " strong chemical decontaminant," (NUREG-0410), how can it be claimed that "it is essentially non-idtating when applied directly to the skin or eyes..."?
(LetterfromD.O.E.)
6 How many truckloads of waste will have to be shipped and at what risk? This question has not been adequately answered because it is possible NS-1 w31 have to be flushed through the system more than once. According to Mr. Lange, the absorntion capacity of the solvent nay be taken up by iron instead of " crud" resulting in the production of twice as much waste.
7.
What is the status of the NRC's consideration of the need for an Environnental Incact Statement for the Dresden I decontamination?
An early consideration of this request wiU1 b appreci t d.
Phone:
312/395-1353 Marilyn Shineflue, Oc-Chrm.
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P00ROR8101 l.S.E.A.
ILLINOIS SAFE ENERGY ALLIANCE P.O. Box 469 Antioch, Illinois 60002 Meetings:
407 South
Dearborn,
Room 370 Chicago, Illinois 60605 VEMBER CROUPS APPLESEED, 3raidwood, Ill.
ASSOCIATED CITIZE:iS FCR PROTECTICN CI' CHE F.NVIRONEEliT, Sheffield CITIZENS AGAINST NUCLEAR POWER, Chicago CITIZENS OFPCSED TO RADICACTIVE FOLLTION, Highland Park CHICAGO WCEN FOR PEACE DEKAL3 AREA ALLIANCE FOR REGEONSIELE E!:EROY ILLINCIS CCNSCRTIUM ON GOVErC:'9?AL CONCFDNS, Springfield ILLINOIS LEGISLAIIVE CCEEITTEE OF THE NATICNAL COUNCIL OF Jr.:ISH.;CE:.
PCHENRY COU::TY DEFENDERS PEACE AND JUSTICE CENTER, Wheston ICLLUTIO:s AND ENVIRCNhENTAL PROBLFJS, Palatine PRAIRIE ALLIANCE, Chanraign, Elconington, Charleston, Peoria and Snringfield RELIGIOUS dDUCATIC:. COMI.U iITY, '.lheaton SINNISSIP I ALLIn:.CE FOR THE J:.VI:t0N: INT, Rockford WAUEGAN CITIZENS ACTION P:10 JECT 8TH DAY CENTER FOR.:U3TICE CU* 0? STATE AFFILIATES:
LEAGU:. AGAINST SUCLE,3 DnNGsRS, Stevens Pt. Wis.
SAFE HAVEN, Sheboygan, Wis.
1017 003