ML19256E894
| ML19256E894 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 10/30/1979 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19256E893 | List: |
| References | |
| NUDOCS 7911150511 | |
| Download: ML19256E894 (1) | |
Text
7590-01 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION CO E NWEALTH EDISON COMPANY
}
(Dresden Nuclear Power
)
Docket No. 50-10 Station, Unit 1)
}
REQUEST FOR ACT. ION UNDER 10 CFR'2.206 Notice is hereby given that by petition dated September 20, 1979, the Illinois Safe Energy Alliance requested public hearings be held on the de-contamination of the Dresden Nuclear Power Station, Unit 1.
This petition is being treated as a request for action under 10 CFR 2.206 of the Comission's regulations, and accordingly, action will be taken on the petition within a reasonable time.
Copies of the petition are available for inspection in the Commission's Public Document Room at 1717 H Street, N.W., Washington, D. C. 20555 and in the local public document room at Morris Public Library, 604 Liberty Street, Morris, Illinois 60451.
FOR THE NUCLEAR REGULATORY COMMISSION AiW$/
Harold R. Denton, Director Office of Nuclear Reactor Regulation Dated at Bethesda, Maryland this SoNay of Odok
, 1979.
1335 356 7911150
. l.S. E. A.
ILLINOIS SAFE ENERGY ALLIANCE P.O. Box 469 Antioch, Illinois 60002 Meetings:
407 South
Dearborn,
Room 370 Chicago, Illinois 60605 September 20, 1979 PETITION FOR HEARINGS ON DEONTAMINATION OF DRESIEN I. Morris. Ill.
Dr. Harold Denton, Directer Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Connission Washington, D.C.
20555
Dear Dr. Denton,
Under the provisions of the U.S. Nuclear Regulatory Concission Edes and Regulations, Part 2.206, I, Marilyn Shineflug, with the support of nenbers of the Illinois Safe Energy Alliance, request that public hearings be held on the decon-tanination of the Dresden I nuclear reactor near Morris, Ill. Since there is no assurance that the N.R.O. will decide to complete a fornal Environnental Inpact Statenent for this experimental project, public hearings are needed to: 1) answer previously.tnanswered or inadequately answered questions; and 2) investigate the significance of new information regariing possible envirennental and health effects of decontani-ation. Accurate, complete answers are needed to the following questions:
1.
What effect(s) will the admittedly cor::csive solvent NS-1 have on the reactor's piping systen? Ar, stated under Category A Technical Activity No. A-15. "The g nary NRC concern related to the decontanination is to assure that the decon-tanination method does not degrade the inteMty of the primary coolant systen boundary. This consideration involves both inmediate degradation during de-contanination and latent effects that could cause degradation dur W subsequent d
operation of the reactor." How can all the crucial welds, valves and joints, etc.,
nany of which are inaccessible, be inspected to assure decentem%xtion has not caused danage7 2.
What standaris or guidelines will be utiliced for "' baseline' inspection and approMate followup inspections to provide a high degree of confidence that no degradation has occurred"? Reliance on existing Technical Specifications and "special inspections" seens inadequate in lignt of the following NRC adnission:
"Since this is an area @ecentaninatiog where the NRC staff has limited expertise and experience with connercial nuclear pcwer plants, it will be difficult to establish the necessary meaninzful guidance and criteria for the decentanination of operating reactors in acvance of these anticipated licensee subnittals."
(Enphasisadded) To ny knowledge the NRC has not yet ublished a NUREG Document g 1335 357790928 32.
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on Decontamination 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 noot if Regulatory Guides are not enforceable. However, since the integrity of the primary coolant system is essent A1. for protection of the public health, decontanination should not eroceed until this imoortant unresolved renerie safety issue is n solved.
3)
Whether or not decontamination vastes can accurately be classified as " low-level" remains unanswered. What radionuclides and in what concentstions are expected
'besides cotalt 58 & 60, cerium, manganese, zirconium and cesiu::1? Accortiing to NBC information, 3000 curies of radioactive material will be removed and eventually placed in 1200 55 gallon drums. E the radioactive material is uniformly distributed throughout the solidification agent, one can conclude each barrel will contain 2 curies of radioactivity or 12,500 nanocuries per gram. Can waste with thi> :oncentration of radionuclides be defined as low-level? What assurances doe.s the public have that significant amounts of transuranics won't be present? According to Mr. Steve Lange of Commonwealth Edisen, "transuranics are not expected," but apparently their presence cannot be ruled out; If the waste contains 10 or more "nanocuries of transuranic. con.aminants per gran 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 envirenmental impact of combining mdioactive waste with chelating agents? As you know, Drs. Means, Crerar and DNuid found chelating agents to be the very agents responsible for radionuclide mobilization at Cak Ridge,Tenn. (See Science, Vol. 200, June 30, 1978) The NSC nsponse that decon-tanination wastes from Dresden I will be buried in " dry" areas is net adequate in light of man's inability to predict cli:atic conditions over the long time spans this waste renains dangerous to life. Furthermore, radionuclides can leach out (in a =anner similar to the operation of a flea collar) even in dry areas and be ca d ed from original burial sites by scant amounts of rain water. At least one recent study shows radionuclide-chelate complexes ara 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
'casis established by the NRC (and not Dow Chemical or Cocmonwealth Edison) for concluding tnis solidification process will be acceptable? What consideration has been given to the fact that organic solvents present in =uen mdioactive waste can dissolve the Dow solidification agent?
6.
What are the maximum levels of mdiation exposure workers could receive while carrying out decontanination? What are the expected levels of radiation exposure workers nay receive? If NS-1 is regarded.as corrosive or a " strong chemical decontaminant," (NUSEG-0410), how can it be clained that "it is essentially non-i:-itating when applieci directly to the skin or eyes..."?
(LetterfronD.C.E.)
6.
How nany truckloads of waste will have to be shipped and at what risk? This question has not been adequately answere:i tecause it is possible NS-L uill-have to be flushed through the system more than once. Accer: ling to Mr. Lange, the absorption capacity of the solvent nay be taken up by iren instead of " crud" esulting in the production of twice as much waste.
~.
What is the status of the NRC's consi:leration of the need for an Environmental Inpact Statement for the Oresden I decentamination?
An early censideration cf this recuest will be atpreciateti.
1 3 3'5 3 5.R" -
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Sincerely,f&,;U.w/h' enone n2h95-1353 y.a-ilyn Shineflug, c-chri.
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ILLINOIS SAFE ENERGY ALLIANCE P.O. Box 469 Antioch, lilinois 60002 Meetings:
407 South
Dearborn,
Room 370 Chicago, Illinois 60605 MEMEER GROUPS t
APPLESEED, 3rsidwood, Ill.
ASSOCIATED CITIEDiS FCR PROTE:: TION CT THE OiVIRCNKE:iT, Sheffield CITIECTS AGAINST NUCLEAR M4ER, Chica60 CITIZENS OPICSED TO RADICACTIVE MLLIJrION, Highland Park CHICACO WCtri FOR PEACE DEKAL3 AREA ALLIANCE FOR P2S E NSI3LE C!ERCY ILLINCIS CONSCRTIUK C:t COVEP.NPSiTAL CONCERNS, Springfield ILLINOIS LEGISLATIVE COEEIITEE OF IKE NATICNAL COUNCIL OF JI'.;ISH 'JCMEN MCHENRY COU:.TY DEFENDERS PEACE A:TD JUSTICE CE.SH, Wheaton MLLLTION AND CIVIRCNSENTAL PROSLDS, Palatine FRAIRIE ALLIANCE, Channai6t., 31cenington, Charleston, Peoria and Snringfield
?2LICICUS d3'.1 AIIC5 CCE!.'.~;ITY, 'Jheaton SINNISSIPPI ALLIALCE FCR THE I:.VIRCNhENT, Rockford
'4AUKECAN CITIECIS ACTION ??.0 JECT 8TH DAY CE:;TER FOR JUSTICE F
CtJ" CF STATE AFFILIA.5:
LEACUE ACAINST ;;UCLEa3 Da::", RS, Stevens Pt. Wis.
SAFE HAVEN,' Sheboygan, Wis.
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