ML19318C117

Responds to Re Facility Chemical Decontamination. Questions Re EIS Purpose Not Required

ML19318C117
Person / Time
Site:	Dresden
Issue date:	04/09/1980
From:	Mccullough E MCCULLOUGH, E. R.
To:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML19318C116	List: ML19318C115 ML19318C117
References
NUDOCS 8006300687
Download: ML19318C117 (3)

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I) v Law cmCE:ur EDWIN R. M CCULLOUGH 1 NORTH LA SALLE STREET CHICAGO. ILLINOIS 60602 PHONC 312-752*9831 April 9, 1980 Mr. William J. Dircks Acting Executive director for Operations United States Nuclear Regulatory Commission Washington, D. C.

20555 Re:

Dresden I Docket 50-10

Dear Mr. Dircks:

This letter is'in response to your letter of March 28, 1980 to Representative Sidney R. Yates, in which you commented on statements of the Illinois Safe Energy Alliance (ISEA) about the proposed chemical decontamination of the Dresden I reacton.

ISEA stated that the experimental procedure at Dresden I is the first of its kind in the world.

You cited other decontamination projects in the world that are different in either quantity and quality.

Only the last two - Dresden Unit 1 test loop and Peach i

Bottom regenerative heat exchanger - use the DOW NS-1 solvent that is proposed for Dresen I.

No project of this magnitude has ever been undertaken before.

In fact, Commonwealth Edison has organized this a demonstration project, and received Federal funding from the Depart-ment of Enerty.

In my opinion, a more appropriate response would be for the NRC to detail the quantities and qualities of previous decontaminations undertaken and demonstr. ate with facts and figures in what ways they

.are similar to the Dresden I demonstration project and the scores of larger decontamination projects planned for the future.

The second concern raised is that NRC has not conducted adequate studies of the environmental consequences of this prototype decontam-ination project.

The NRC response is conclusionary,and clearly no substitlte for an environmental impact statement which would require rigorous analysis of all phases of the project, consideration of

'; nijernatives, and conclusions supported by proven facts and reasoning.

I do not find it reassuring for the NRC to state the radioactive and chemical nature of the waste is similar to other wastes, when there are open questions about the durability of the solidified waste.

Tin.;

L has shown the problems of disposal of wastes, particularly at the Oak

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Ridge burial sites.

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,- As to the concern that NRC has not conducted any independent tests of the clean-up process, including waste transportation and disposal, it is still unknown what tests have been conducted on the i

long-term stability of the solidified wastes.

Does the NRC know i

the probability that the wastes could escape from the containers i

and possibly enter into the environment and food chain?

I would like to know how any confirmatory research is independent.. It is generally accepted that scientific methodology proceeds with no preconceived results.

Please explain what Brookhaven National Laboratory is doing.

I do not understand the reasoning of the NRC as to why an environmental impact statement (EIS) is not required, or if now if a new determination is being made.

Under pre-July 30, 1979 regulations, is an EIS not required?

If so, why not?

Are you now following the procedures under the regulations _ promulgated by CEQ effective July 30, 1979 Your. attention to this matter wi.'-

be greatly appreciated.

Very truly yours,

[M k

EDWIN R. McCULLOUGH ERM/sw cc:

Hon. Sidney R. Yates V

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