ML19320B084
| ML19320B084 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/01/1980 |
| From: | Crerar D PRINCETON UNIV., PRINCETON, NJ |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0686, RTR-NUREG-686 NUDOCS 8007090269 | |
| Download: ML19320B084 (2) | |
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-Princeton University otraarutur or crococicao ano czoenrsicat sciruczs GUYOT IIALL, PRINCETON, NEW J ERSEY 08344 Pl{ 0 N E: 609 452 4ror July 1, 1980
- Director, Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Sir:
I wish to comment briefly on the draft environmental statement for decontamination of the Dresden nuclear power station, NRC report NURE G-0686, Docke t No. 50-10, May 1980.
I have participated in several research projects relating to disposal of organically chelated radionuclides and disposal of chelating agents in general.
'As a result, I have become concerned about the prospect of burial of large quantities of chelating agents in low level radwaste repositories. This problem extends, of course, beyond Dresden Unit No. 1 to all decontamination operations, present and future.
I am encouraged by the recommendations =ade since initiation of thf s project that (1) all waste be disposed of in desert repositories with low precipitation, deep water tables, etc., and (2) all chelated waste be seg-regated physically by an effectively impermeable barrier from other radio-active wastes in the same repository.
I urge that these points be adopted as firm requirements for this and all similar operations in the future.
However, I am surprised that the alternative of physically or chemically degrading chelating agents after reactor decontamination and prior to disposal is treated in only the most cursory fashion in this report (as a brief response to question 4d, Appendix A, pg.12, and not even mentioned in Section 2.4 which evaluates alternatives). This recommendation has now been made quite strongly in print (Means et al. (1978) Sci., v. 200, pp. 1477-1481, and Means et al. (1980)
Environ. Pollution, v. 1, Ser. B., pp. 45-60), in reports (Means and Alexander (1980) "The Chelate Problem" Battelle Columbus Lab. Rpt. BMI-X-701, DOE con-tract W-7405, ENG92, Task No.119), and by letter to the NRC (letter from me to Dr. J.M. Hendrie dated June 25, 1979). I note, for example, that the NS-1 chelating egent decomposes at approximately 3000F (pg.14, Appendix A), only 500F above the proposed temperature of the decontamination procedure (pg. 3-1),
and is also chemically degradable. Chelate degradation would obviate many objections raised regarding disposal of these and similar wastes, and should warrant much more rigorous consideration. Whern data are unavailable programs should be undertaken to design and evaluate specific degradation procedures applicable to large-scale decontamination operations.
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- Director, Division of Licensing July 1, 1980 page two -
I also find it unfortunate that in this report the NRC should have con-sistently de-emphasized the significance of chelating and other strong com-plexing agents in the migration of radioactive wastes.
It is the very presence of large quantities of such compounds to be contained in the waste generated from decontamination operations that has created much of the present public conce rn.
Surely this issue should be addressed directly in your impact state-ment (where the word " chelating" is now mentioned only once in a passing reference to the Hanford disposal license, Sect. 4.2.3).
The NRC response to several questions in the Appendix notes, quite rightly, that observed migration
- at ORNL is attributable to fracture flow and high precipitation, btt tacitly de-emphasizes the parallel importance of organometallic complexing and chemical controls in general.
Obviously the NRC is aware that waste migration is both a physical and chemical problem, yet this report suggests otherwise: the chemical problem is not fully acknowledged; pertinent fundamental properties of the solvent are not noted and discussed. These properties include biological, physical, and chemical degradability; complexity constante-for selected radio-nuclides; aqueous solubility; uptake and metabolization by organisms; influence on distribution coefficients, K, for selected adsorbent substrates as a d
function of solvent concentration.
Finally, one purpose of reports such as this must be to communicate clearly with a concerned public. Unfortunately, the numerous grammatical errors in this report, repetition and scrambled pagination, and the incomplete responses to queries such as those noted above do not prcject an image befitting the NRC.
Sincer ly,
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%y vid A. Crerar Associate Professor, Geochemistry DAC:jo copy: Paul O'Connor NRC, Washington, D.C.
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