ML19256B616
| ML19256B616 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 05/21/1979 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Hansell D ILLINOIS, STATE OF |
| References | |
| NUDOCS 7908140498 | |
| Download: ML19256B616 (16) | |
Text
K9t ?Da UNITED STATES
[
.- [ j NUCLEAR REGULATORY COT.1M!SSION
- , f.y.,y WASHINGTON, D. C. 20555
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e Decket No. 50-10 MAY 211979 Mr. Dean Hansell Assistant Attorney General Environmental Control Division 188 West Randolph, Suite 2315 Chicago, Illinois 60601
Dear Mr. Hansell:
This is in response to your letter dated April 18, 1979, which requested answers to sixteen questions relating to the chemical decontamination of the Dresden Nuclear Power Station Unit No. I primary cooling system. Our responses to the specific questions are contained in Enclosure 1.
Questions 5, 7, and 8 relate solely to the activities of the Department of Energy (DOE). is a copy of a letter referring those questions to DOE for response.
With respect to your request that the Dresden decontamination not go forth until the need for an environmental impact statement or appraisal is resolved, please be assured that we will resolve all questions relating to the issuance of an environmental statcment or appraisal prior to the Dresden decontamination which is currently scheduled for August 1979.
I hope that this information is responsive to your request.
If we can be of further assistance, please call us.
Sincerely, Original Signed By Boger S. Soy.d c
.!:JHarold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosures:
1.
Answers to Cuastiens 2.
Letter to DOE b
b 2Ek i
7908140pg g
ENCLOSURE 1 RESPONSE TO STATE OF ILLIN0IS QUESTIONS RELATED TO THE DRESDEN DECONTAMINATION What procedures will be o' served to insure that the reactor is 1.
A.
o safe before bringing it back on line?
Before returning Dresden 1 to service following decontamination of the primary cooling system, a cocprehensive pre-service inspection will be performed to assure the integrity of the primary coolant system and assess the effect of tne chemical cleaning on safety-related components that have beer N contact with the cleaning solvent.
In addition to these spe:1ai inspections, all the normal inspections and tests required by the Dresden Technical Specifications oefore returning the reactor to service fo~llowing each refueling outage will be performed.
B.
What specific standards will be employed to insure that the reactor is safe before bringing it back on line?
Facility Operating License No. DPR-2, issued to Dresden Unit 1, requires that Commonwealth Edison operate the facility in accordance with detaMed operating standards called Technical Specifications. Th_se specifications establish limits on operating parameters related to safety and establish the minimum complement of safety-related equipment needed to assure that these limits are not viviated.
Commonwealth Edison must comply with all the requirements of the facility Technical Specifications before returning the facility to service.
2.
What alternatives to the current decontamination process were examined?
Why were they rejected?
Four alternative approaches were considered for decontaminating Dresden 1.
These methods were:
1.
Mechanical cleaning 2.
Water Flushing 3.
Operational Techniques 4.
Chemical Cleaning Evaluations of the varicus techniques in tnese alternatives are listet in aale.1, 835 247
TABLE I I
ALTERilATIVE fiETIIODS FOR REDUCIf1G RADIATI0ft LEVELS I fl D R E S D E ft - 1 Reduction fi n t. h o t...
Advantages Disadvantages Evaluation 1
fiechanical Cleaning a.
Brushing, wiping, Simpl e - tio chemical waste flot highly effective Cannot be used as scrubbing & scouring Filtration disposal Access not possible a solution to in many areas total problem liigh personal exposure b.
poly-piq (pumped Waste handling eased Applies only to pipino Does not meet scouring projectile)
Technique available fligh radiation expo-program goals sure for reduction Access not possible of radiation in many areas levels leaves residue c.
Ultra,onic cleaning No system modifications liigh radiation expo-Does not meet required sure program goals Waste handling eased Access not possible for reduction D
in many areas of radiation g
D Gives only localized levels u
D effect os
~^
d.
Component replacement Achieves minimum D
Expensive Cannot be used as C'
radiation level liigh radia tion expo-a solution to the g
sure total problem Partial solution only Consider supple D
Waste disposal diffi-mental use for b
cult certain problen F*
areas
TABLE I (Continued)
, I Reduction Method Advantages Disadvantages Evaluation 7
Uater flushinq a.
Fill
?.
drain Simple - No significant Ineffective on scale Does not meet additional equipment and crud traps program goals for reduction of'ra-diation level s Waste handling eased Piping access diffi-Does not meet b.
liigh pressure cult or impossible program goals for jetting without major changes reduction of Not effective without radiation levels chemical addition Requires extensive Airborne contamination Pressure boundary problems disturbance 3.
nnerational Techniques a.
On-1ine chemical No or minimum outage Proven or even prom-Not feasible at addition (transport Provides on-going solution ising method unknown this time deposit to cleanup for future at this time Licensing / safety systen)
T questions difficult D
to answer g
b.
Improve feedwater Minimize future buildup Long response time Does not meet N
Q Does not remove scale program goals for M
or crud trap material reduction of 4
Does not affect pri-radiation levels k
mary system generated g
corrosion products br----
TABLE 1 (Continued)
I Reduction t!ethod Advantages Disadvantages Evaluation 4.
Chemical Cleaning F l u',h i ng wi th ex i s ti ng Techniques well known Extensive corrosion Does not meet a.
solvents shown below:
Treats total system testing required goals for re-fio substantial system Large waste disposal duction of radi-modifica tion required problem ation levels Low decoritamina tion factors Lower solubility than desired EVALUATION 0F DECONTAMINATI0ft SOLVEtlTS DESCRIBED Ill Tile LITERATURE WITH DRESDEf1 1 SPECIMEN Code fla m e Chemical Formula g/l Conditions cf Use D_e c o n t am i n a t i on Factor for Cobalt 60 APAC (Shippingport 1964)
(AP)
KMn0 13 24 hrs. - 121 C 1
4 tla 0ll 100 (AC)
( Nil 4)2HC N 0 13 MM. - 121%
1.15 6 S 7 AP-C i t r ox (PRIR 1965)
(AP)
KMnD 30 2 hrs. - 10S*C 1
T tia oll 100 C
26 Q
(Citrox) T ll,., C.,04 u
50 3 hrs. -
81 C 1.15 (till4 )',,IIC II 0S7 O
6 IV I"2(S04)3 wco diethyl thiourea 1
Q
- a:
60% If PO4(Oresden 1968) 4 2.0 Il P0 600 4 hrs. - 121 C y
3 4
EV ALU ATI0fl 0F "KNOWil" DEC0flTAMINATI0fl SOLVEllTS USIllG C0flDITI0flS DIFFERIrlG FROM " Tile LITERATURE" Conditions Decontamination Reason For Code fla m e
(. h em i c a l Formula 3/l of Use Factor f or Cobal t 60 Rejection __
AP fla 0!!
10 12 hrs. - 97 C 1
Low DF Kittt0 30 4
0 100 pli 5 450 Insufficent removal ACE
( flH4)gilC "5 7 6
of fission produ~ cts &
0.4 100 hrs. - 13 0 C sloughing EDIA&flH,,0ll inhibitor 24 pH 2.4 780 Corrosion li C 0,)
Citrox 2 2
( f!Il4)2ilC h 0 50 100 hrs. - 130 C 657 F e ( fl03)3' "20 2
inhibitor AC (till4)2ilC N 0 100 100 hrs. - 130 C 45 Sloughing and low DF 6 57 inhibitor Sulfox cc l1 S0 30 100 brs. - 130 C 928 Corrosion 2
4 u
9 ll C0 224 inhibitor t r.
Each used in sequence; formulated etc, 547 g
2-stage system and as above AP and AC g
Each used in sequence; formulated etc, 230 2-stage system and sludging as above AP and ACE g
(AP)(Citrox) Each used in sequence; formulated etc, 1350 2-stage system and sludging as above AP and Citrox ZPr
I b.
Itew ",olvent flushing Techniques well known Extensive corrosion Effectiveness (NUfEK-L106)
Treats total system testing required questioned Ho substantial large waste disposal Test results not modification required problem (demin r2 sins) available Low decontamination Cannot consider factors at this time Lower solubility than desired c.
New solvent flushing Same as 4.b Extensive corrosion Appears to be the Dow r,olvent NS-1 Single phase system Testinq required best alternative Close to 100% solu-Waste Processinq to achieve pro-bility required gram goal lligh decontamination factors Liquid waste problem reduced by factor of 2 to 3 over known solvents d
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( 17 I\\ )
-. Commonwealth Edison established the following considerations. as the criteria for selecting a decontamination method:
1.
Greatest possible reduction in radiation levels 2.
Complete dissolution of the oxide film 3.
No reprecipitation and redeposition 4.
Low corrosion rates 5.
Gne-solution treatment Based upon Commonwealth Edison's evaluation of these al ternative methods of decortamination the DOW NS-1 solvent was selected to decontaminate the Dresden Unit 1 primary cooling system.
3.
What role has the NRC played in the Dresden decontamination project?
NRC performed a comprehensive review of the proposed Dresden decontamination to assure that the chemical decontamination will not adversely affect the integrity of the primary cooling system and thereby constitute an unreviewed safety problem.
Based upon our review, we concluded that the Dresden Nuclear Power Station Unit I could be subjected to the chemical cleaning without undue corrosion or other celeterious materials compatibility effects that would adversely affect the integrity of the primary coolant system and conn-: *ad systems.
We also concluded that the effluent treatment system would be capaole of handling the types and quantities of radioactive wastes
~
exoected to be generated by the decontamination program and that the radiological safety program is adequate to assure that the health and safety of the public and the onsite personnel will not be endangerec by the Dresden I decontamination program.
During our review of the proposed program three items were identifi'.
as unresolved.
They will be resolved as follows:
1.
The testing program will be completed and the results submitted for the review and approval of the NRC staff prior to performing the proposed chemical cleaning.
2.
A pre-service inspection program for the primary coolant boundary will be formulated and submitted for our review and aaproval orior to returning the reactor to service.
836 253
P00R ORGIN!d 3
3.
A post-cleaning surveillance program which includes additional surveillance spec { mens and a specimen withdrawal and examination schedule will be submitted for our review and approval prior to returning the facility to service.
Items I and 2 have been completed by Commonwealth Edison and were submitted by letter dated February 5,1979, for our review.
4.
Did NRC perform an environmental assessraent within the meaning of the National Environmental Policy Act? If not, why was this not done?
NRC did not issue an environmental impact statement or appraisal in connection with this matter. However, we did consider the environmental impact of the decontamination in our December 9,1975 Safety Evaluation.
The results of that review were as follows:
Environmental Impact:
The chemical decontamination of the Dresden 1 primary coolant system will be performed entirely within a closed decontamination system.
The system has been designed so that no chemical or radiological wastes will be released to the environment from the decontamination process.
All wastes generated in the process will be either solidified for offsite burici at a licensed burial ground or reprocessed for reuse onsite. The solid wastas produced are sinilar in type and quantity to those handled routinely at the site. Therefore, no acverse environmental impacts are anticipated due to the decontamination.
5.
What role did the Department of Energy play with Commonwealth Edison Company (Commonwealth Research Corporation) in the Dresden decontamination project?
Referred to the Department cf Energy (DOE) for response (see Enclosure 2).
5.
What role did the Department of Energy play with the NRC in the Dresden decontamination project?
The Department of Energy (DCE) played no role in the NRC review of the Dresden Unit No. I decontamination.
A representative of DOE was present as an ooserver during NRC meetings with Commonwealth Edison out was not an active participant in the NRC review process.
835 254
P00R BRIBM 7.
State the reason why DOE has provided partial funding for the project?
Referred to the Department of Energy for response (see Enclosure 2).
8.
Did tne Department of Energy perform an environmental assessment within the meaning of the National Environnental Policy Act?
If not, why was this not done?
Referred to the Department of Energy for response (see Enclosure 2).
9.
What safeguards are being taken to insure that no radioactive material escapes into the environnent beyond the allowaale limits?
The decontamination of the primary system and the processing of the liquid waste into a solid form will take place inside of a confined volume where all potential paths for the release of airborne or liquid radioactive material are monitored.
In addition, the air exhausted from areas of high potential for airborne radioactivity is fil+ered through hign efficiency particulate filters to remove airborne particulate radioactivity.
These provisions will assure tnat no unmonitored, untreated ef fluents are discharged to the environment.
10.
How will the radioactive " crud" which is to De flushed from the system be handled, stored and transported?
The radioactive " crud" that is flushed from the system will be evaporated to reduce its volume in the radioactive waste facility.
Af ter evaporation the concentrated liquid waste will be solidified using Dow Chemical's Solidification Process for Low Level Radioactive Wastes. Af ter solidification the waste will be transported by a commercial radioactive waste disposal carrier in appro:imately 1200 55 gallon drums.
The waste will be packaged and shielded to meet all applicable transportation requirements.
- 11. Where will the radioactive crud be disposed?
The solicified racioactive waste will be transported to a commercial low level waste burial site, such as Seaty, Nevaca or Hanford, Washington.
835 255
m
?00ROR8EL 12.
What are the characteristics and quantity of the radicactive c rud ?
The " crud" exists as a thin, tightly adhering oxide film on the interior surface of the primary cooling system. After removal, the " crud" containing approximately 3000 curies of racioactive material will be uniformly distributed throughout a solic vinyl ester resin solidification agent in 55 callon drums.
In this form the waste is a free standing monolith with no free liquids.
13.
How has the oossibility of the long term effects of the decontamination been tested for?
The 1ong-term effects of the decontamination will be moni cored by an ongoing program of inservice inspection of pumps, valves and welds to assure the continued integrity of the primary cooling system. A new program utilizing reactor materials surveillance capsules will also monitor the behavior reactor materials af ter the cleaning.
14.
What procedures are being observed to minimize worker exposure?
The occupational exposure to the workers at Drescen i is being minimized by carefully planning the decontamination program and training the workers to carry out their tasks cs cuickly and efficiently as possible.
Comnonwealth Edison has estimated the. radiation exposure that is expected to be receivec curing each discrete task involved in the cleaning procedure. The high exposure tasks have been evaluated to minimize operator exposure by shielding and preplanning. Emergency procedures have been developed to minimize personnel exposure in tne event c f a mal function.
We have reviewed the licensee's submittals regarding occupational exposure and have concluded that Commonwealth Edison has taken appropriate measures to assure that occupational exposures will be maintained as low as reasonably achievable during the decon-tamination and waste treatment operations at Dresden Unit 1.
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15.
What will be done to minimize corrosion due to the decontamination?
An extensive materials test program has been completed b.v the licensee to provide assurance that the decontamination solution will not cause excessive corrosion to the prinsey cooling system components.
This program evaluated the corrosion resistance of the materials that wi)1 be cleaned by the Dow Solvent.
Eased on the results of thew studies we have concluded that the corrosion of the primary cooling system components will be acceptably 1cw.
The NRC staf f will require the licens7e to closely monitor the time, temperature, and chemical composition ano concentrations to assure that' the actua? Dresden 1 cleaning process is performed within the range of vari >.bles of the material test program.
- 6. Will any of the techniques lea ned in decontaminating the Three Mile Island nuclear power piantJe applied to the Dresden decontanination project?
tio. The decontamination Et Dresden is expected to precede any decontamination activities at T5'ree Mile Island.
Mcwever, i' is very likely that tSe Dresdea dectatamination program will provide valuable coniimatory ugeritice and background in large scale reactor system deccvitamisttien that will be useful in any Three Mile Island decot? amination.
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,,. 1 NUCLE AR REGULATORY COMMIS.SION I. (D 14 WASHINGTON. D. C. 20555 f
May 15,1979 Dccket No. 50-10 Mr. "hris Kouts NEPA Affairs U. S. Deparu.ent of Energy 20 Massachusetts Avenue Rocm 4211 Washirgton, D. C.
205:5
Dear Mr. Kouts:
The enclosed request for information relating to the Chemical Decontamination of the Dresden Nuclear 90wer Station Unit No. I has been received by NRC from the Attorney General's Office of the State of Illinois.
Questions 5, 7, and 8 relate solely to actions taxan by the Department of Energy and cannot be answered by the NRC.
We will inform the Attorney General that we have referred these three questions to DOE for separate responst Please provide your agency's response directly to the State e' Illinois Attorney General with copies to the NRC.
j Sincerely!,
[
I
' /weea?v:0
,'J Richard H. Vollmer, As7i.. ant Director for Systems & Projects Division of Operating Reactors
Enclosure:
Letter dtd. 4/18/79 frca State of Illinois - Attorney General s
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WILLIAM J. scott ATTo RN EY o EN E R AL STATE oF !! UNolS too peomfM La s a L LE sT *
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April 15, 197 9 Joseph M.
- Hendrie, Cha ir:.an Nuclear Fec.ulaterv. Ccmmission Wa s hin g t:n,
D.C.
20555
Dear Chairman Hendrie:
The Federal Register contains notice of a receipt of a Petition the Dresden (Illinois) to perform an EIS on the proposed decontaminacion at Nuclear Power Station.
The proposed decontamination project which is the subject of the Petition is the first of its kind and raises a nurber of important environmental rad safety questions.
On the basis of our inves-tigation of the project we have a nurler of questions regarding the decentamination to which we would appreciate your response.
1.
A.
What procedures will be observed to insure that the reacter is saie before brincinc it back on line?
3.
What specific standards will be employed to insure that the reactor is safe before bringing it back on line?
2.
What alternatives to the current decentaminatica process were exa-inedi Why were they rejected?
3.
What role has the NRC played in the Dresden decoatamination project?
4.
Did NRC perfor an envirc. mental assessnent wichi meaning of the National Environmental Policy '.ct?
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Where will the radioactive crud be disposed?
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What will be done to minimize corresien due to the decon-
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