ML19289F482

Petition for Preparation of EIS Prior to Use of Dow Chemical Solvent to Flush Out Corrosive Products from Piping

ML19289F482
Person / Time
Site:	Dresden
Issue date:	03/19/1979
From:	Drey K AFFILIATION NOT ASSIGNED
To:
Shared Package
ML19207A162	List: ML19207A160 ML19289F479 ML19289F480 ML19289F481 ML19289F482
References
NUDOCS 7906080032
Download: ML19289F482 (5)

Text

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e 19 March 1979 tot President Jin=y Carter, and to Messrs. Douglas C: s t le ( Admini s t ra to r,

Environeancal Protection Agency), Jacob-Dumelle(Chairman, Illinois Pollution Control Board), Joseph Aendrie(Chaire.an, Nuclear P.egulatory Commission), Charles Percy(U.S. Senator fro = Illinois), James Schlesinger (Secretary, Department of Energy), Willia: Scott (Attorney General of Illinois), Adlai S t e v e n s o n (U. S. Senator from Illinois), Jaces Thompson (Covernor of Illinois), and Charlei-Warren (Chair:an, President's C o u n'c il an Environmental Quality) ron: Kay Drey, 515 West Point Avenue, University City, Missouri 63130

'A PLEA FOR AN ENVIRONMENTAL IMPACT STATEMENT ON A MAJOR FEDERAL ACTION PRO POSED TOR THIS SPRING, 1979 IN ILLINOIS:

The U.S. Department of Energy is presently contributing $8.2 million toward the first of a series of decontamination ' experiments designed to dissolve and flush out radioactive corrosion products from nuclear reactors. In April or June (?), 85,000 gallons of a propri'etary Dow Chemical solvent are to be flushed through an estimated five miles of piping for 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> within our nation's oldest active commercial reacter(Commonwealth Edison's 2004 megawatt Dresden plant, Unit one, on the Kankakee River).

naar Morris and 1o1113, Illinois,

[This solvent may be chemically similar to, even identical with, the very compounds which have been found to be causing the unexpectedly rapid migration of radionuclides out of the Oak Ridge burial trenches j

kand possibly into the human food chain.

The claim contained in a letter I received last month from the Department of Energy that there is " reasonable evidence that it(the solvent) will not contribute to the escape of the radioactive material, nor will it cause migration of radioactive substances through the environment" is not con-vincing. Once the Dow Chemical solvent has bound the radioactive materials, we may lose all hope of keeping those substances isolated from the biosohere.

I I have obtained inf ormation and suggestion s f rom prof essors of geoem sistry, physics, biophysics, biology, biochemistry and radiation oncology. E ery one of thsh is as concarned about this experiment as I em. They h:ve he21:d formulate (and explain) the questions that follow, and all believe that an environmental impact assessment is imperative. To quote one of the men from a letter Jated March 9, 1979:

"I think it is unac'ceptable that the DOE assure you that their chelating preparation is environmentally safe and, at the same time, refuse to divulge the-nature of the material. We still knos relatively little about the movement of radio nuclides in the environment, but there is increasing evidence that natural ligands may contribute to the process.

I should think that one would need to take care that the artificial ligands provided by Dow would not enhance the mobility of nuclides in the biosphere and result in their concentration in the food chain."

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Before this action is undertaken the public is entitled to the assurance that physical and biological scientists who are not financially and/or emotionally committed to this project will have studied questions similar to those which follow, and will have conclusive evidence that the proposed Dresden experiment can be performed without jeopardizing the human environment. If not, the project should not proceed.

l.

First. is it possible that an environmental impact assessment and e negativa declaration have already been written regarding the proposal to decon:aminate Dresden Unig Oaa? I have ashed this question several times of the CSE, but have not received an answer. If an assessnent was cade, which individuals of the Depart =ent of Energy =ade the decision that thic project vill not affset the quality of the beczn Snvironment, and there-fore did not require an e nv i r o n.a c a t a l impac: state ent under 40 CT2 150G?

That is, uns a negative declaration made by the DCE, and if so, by whom an-when? 18 a copy available? Did it addresa the f ollowing questions ?:

2.

t ua: do fic14 or laboratory tests d er.c a s t r a t a to be the migrition poter:i:-

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from disposal pits and trenches in the Oak Ridge National Laboratory. In a personal communication from Dr. Crerar, the environ ental implications are described as follows:

"While chelates are used because of their powerful metal-binding properties, it is this same characteristic which may have undesirable environmental consequences. For example, EDTA, which is used in nuclear decontamination operations, is causing the migration of some 60Co from intermediate-level liquid vaste disposal pits and trenches in the Oak Ridge National Laboratory burial grounds. Because it forms extremely strong complexes with rare earths and actinides, EDTA and similar chelates may also be contributing to mobilizction of these radionuclides from various terrestial radioactive vaste disposal sites around the country. EDTA is relatively resistant to decomposition by radiation, thermally stable up to about 200-2500 C, and rather slowly biodegradable. Consequently, it is persistent in the environment. Indeed, the presence of significant concentrations of EDTA in 12 to 15 year old radioactive vaste at ORNL attests to its persistence. Therefore, wherever EDTA and similar compounds have been introduced into the natural environment, the aqueous transport of transition metals, rare earths, and transuranics, which character-istically form the most stable complexes with chelates, vill be expected to occur....

Degradation rates of all three chelates (NTA. EDTA, and DTPA) were not rapid enough, even under ideal laboratory conditions, to preclude.

concern about their release to the environment. Heavy metal mobilization can occur at extremely low chelate concentrations, as witnessed at ORNL. Biodegradation, if slow or incomplete, may be an inadequate barrier to their various undesirable environmental consequences. Destruction of chelates by thermal or chemical means (such as ozonation) prior to environmental discharge appears to be j

much more efficient than biodegradation af ter discharge."

l 3.

For how many years hsve radioactive corrosion products, bonded with the proposed Dow Chemical solvents, remained free of water after being 6

solidified by the Dow Chemical polymer process?

According'to Dow Chemical's publication entitled " Solidification Process for Low-Level Radioactive Wastes", (Form No. 173-1026-78), only a few descriptions of the solidification process, which I understand is to be used for the Dresden vastes, are included:

"The Dov Solidification Process consists o' che combination of a binder -- a modified vinyl ester resin -- with small amounts of a catalyst and a promoter. The process encapsulates the low-level radioactive vastes into a stable, solid and homogeneous matrix.

The. Process, using polymer chemistry, dictates that it must solidify aqueous and slurry wastes, including ion exchange resins, evaporator bottoms, spent decontamination solutions, and filter sludges.

The Dov Process solidifies radioactive vaste with no free liquid.

The Dov definition of ' free liquid' is liquid in or on the specimen or in the container upon completion of solidification or after 3-7 days of aging."

a.

Has the Dov solidification process been tested on' reactor corrosion products comparable to those which will result from the Dresden experiment? What assurance is there that the en-l capsulated waste is going to be low-level?

i b.

When did Dow Chemical first develop its solidification process for low-level radioactive vastes? What is the longest duration period fur one of its " monoliths" or matrixes -- t ha t is, how lev has such a solidified Dow substance re:ained free of liquid?

What would be the long-term stabilit' of the solid polymer over a period of thousands of years?

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c.

What is the Icach rate of the polyner under burial conditions, ort g

the potential for diffusion'and release of encapsulated radio-j nuclides. solvents, etc.?

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During the evaporation step, is the solvent volatile, and if so, will an ion exchange resin cocpletely scrub chelated radionuclides from the evaporate? (I am told by one person that his experience indicates it will not).

4.

F o r 7 Tov many years have the barrels designed for burying the solidified vastes been found to remain resistant to corrosion from both the proposed contents and from surrounding environmental impacts 7 a.

According to a letter I received from Mr. Paul Pettit(Light 'ater Reactor Section, Division of huelear Power Development, DOE) dated February 6, 1979, the solidified vastes from the Dresden experiment are to be shipped in drums to a commercial low-level vaste disposal site.'Since additional vastes are no longer being accepted at the nearby Sheffield. Illinois burial site (in fact, the licensee has just walked away, with the NRC in hot pursuit),

i vill the vastes be s h ip'p e d to Nevada, South Catolina, or Wash-ington? Were the drums designed to comply with the Department of Transportation's packaging and shipping regulations for low-level or high-level vastes(49 CFR Parts 170-178), or to comply with the NRC transit regulations for fissile materials (10 CTR 71 and 73)? And/or were the drums designed for indefinite burial?

b.

What is the estimated lifespan of the barrels? What precautions are going to be taken at the life-end of the barrels to ensure i

continued containment of the residual radioactivity? have any metals been found that will resist the corrosive action of the proposed contents for even a decade? Is there apt to be any chemical reaction between the compounds going into the barrels and the materials of which the barrels are composed?

c.

In the June 30, 1978 Scienca article. Dr. Crerar and colleagues describe the accelerated dispersal through the groundwater and the increased uptake by vegetation of the radionuclides when bonded to nonbiodegradable chelates. If the buried drums with the solidified Dresden afflueet were to corrode and the matrix were to come into contact with water, would the radionutlids-chelate complex not become sol ble again? Could this solution then migrate through the envircnment in the same manner found i

at the Oak Ridge burial site

• d.

If chelates are to be used, can they

's deactivated thermally, chemically, or biologically before e,aporation and solidification?

5.

Is it possibir that any of the solvent with or without dissolved radio-nuclides may remain after the principal effluent and first rinse water have been removed for evaporation and solidification -- and then be flushed into the Illinois River? If so, might the radionuclides absorbed by the river's sediment near the plant's cooling water outfall in years past become resuspended and migrate into the food chain?

a.

How much radioactivity and residual chelating agent are expected in the first rinse? How many additional rinses will there be?

Scientists have told me that they did not think that chelated.

radioactive metal ions would be removed by a demineralizer; although domineralizers have a high affinity for naked estal ions, I have been informed that they generally do not remove chelated forms. Or vill the chelating agent perhaps be charged,

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and thereby be removable by the demineralizing step? People with whom I have spoken seem surprised to learn that the purification of the first rinse -- the removal of the residual chelating agente and chelated metal ions -- was to be done with a deminerali:er.

i What is the explanation for this apparent departure from traditional practi:.e?

b.

According to Mr. Pettit's letter of February 6, 1979, "the forculation of the Dov Ch e r. i e a l solvent is known t,

DOE staff.

but is protected from release to the public by a proprietary cireement." Solvents used for decontamination purposes at nuclear facilicies have been described elsewhere, however, by OVEF-2075 M4 i

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l 6t III, Oov and Consonwealth Edison represents:ives as being "chelaci g agents" (; r on oun c e d key-lay-ting) that is. a cne:ical ec:;ound(typically organic) ta;ai.e cf f r=ing clavlike cultiple bonds with a =etal icn. Ty;ically these agents are also ncn-irritating to skin :: eyes, a characteristic of the solvent which Mr. Pettit happened to cention.

Assuming the compenents of the solvent fit the definition of a chelating agent, is there any likelihoed that there vill be enough residual after the primary efflya t and first rinse water have been removed, that sc=e 1ght be flushed into the 5

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!01 Illinois River along with future routine releases of the coolant l

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='jy vater? (The coolant-water discharge canal e=pties into the i

i Illinois River at the confluence of the :es Plaines and Kankakee d

(

Rivers at Illinois River Mile 272.4). How tightly does the solvent bond metals? That is, if some were to pass through the sediment near the canal's discharge point, might it leach out additional radionuclides which have accumulated in the sediment near the outfall? Or if it is a relatively weak agent, might the sediments attract radioactive metals out of the chelate solution, thereby increasing the amount of radionuclides in the sediment and the potential for.urther contamination of the bentbos? (The IPA report entitled " Radiological Surveillance Studies at a Boiling Water Nuclear Power Reactor". BRH/DIR 70-1, describes the contents of the Dresden Unit One liquid vaste affluents during tests in 196, and 1968. Two later companion studies at reactors in Massachussettes and Connecticut describe the significance of the concentration of radionuclides in the sediments).

6.

What will be the impact of the solvent on the future safe operation of the Dresden plant?

)

According to the book, Dangerous Properties of Industrial Materials, by N. Irving Sax, published in 1963:

l "One fallacy in the initial concept of stainless steel or other

' impervious' surfaces is that they are truly impervious. This has I

been shown to be false. Stainless steel after one vigorous cleaning a

is found to deteriorate in that more and = ore material may be absorbed or, adsorbed and retained on the surface. Successive cleanings have been found to become more difficult and to require more vigorous methods of decontamination." (p. 149) a ". I understand that the NR; is responsible for making certain that this project will not compromise the integrity of the reactor vessel and its parts. What assurances, hevever, does either the NRC or the DOE have that this massive cleaning effort will not increase the surface fouling of the reactor system in the future, causing an acceleration in the buildup ef crud in its many nooks, crannies and blind holas? Will even stronger chelating agents be needed at Dresden Unit One for future decontamination efforts, assuming the stainless steel properties quoted above frem the Sax book are correct?

b.

Could an acceleration in the race of buildup of crud after the decontamination project increase the potential for pipe c r a c ki.i g j

or rupture? And also increase the radiation hazards to workers?

7.

What assurances are there that the men who participate in the Dresden decenta:ination experi=ent will not suffer fro = ex;esure to the combination ef the selvent and the radicactive materials suspended in t.2 e solvent in either :he aqueous er gaseous forms?

C:e of :he possible reascas for the increased incidence of leuke=ia and ca::er at ?ortsmouth and othe-naval shipyards whi:h Drs. Thc=4s Najarian 4:4 The:dore Colton =ention in their co==unicati:n ;ublished in he Lance:,

"ay 13, 1978, is that: "Other factors (asbestos, s:: king, industrial s: rents) tay have interacted syner51stically with radiatien c cause

. :eaths from cancer and leukemia that radiatice alene vould have

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a.

According to a l a '.i e : dated March 13, 1979, from Mr.

A.

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Rossin(System Naclear Research Engineer, Commonwealth Ediscs),

thirty workers vill be needed during the presently proposed 100-hour project. And although I was told by Mr. Paul Pettit of the DOE that his agency is not concerned ebout the toxicity 2

of the Dow solvent itself during the decontamination operation, I

uhat hazards may it pose to workers when it is in comoination with radioactive materials?

b.

What procedures are to be taken to nake certain that the radionuclide-chelating agent is totally contained and vill i

not in fact come in contact with the workers? What is the radiation dose exp ected per hour at ons meter from the reactor containment vessel, the effluent piping, the evaporation and solidificacion equipment, and the drums preparatory to and during shipping? What shielding vill be erected to protect t h-workers?

These are questions of profound import. To proceed with the Dresden experiment Vhile they remain unanswered would be egregious folly. For the s a.f e t y of the public and the workers, and for the pro tection of our country, can we count on vou to demand that a full environmental impact statement be prepared immediately?

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