ML19321A057
| ML19321A057 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/16/1980 |
| From: | Drey K AFFILIATION NOT ASSIGNED |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0686, RTR-NUREG-686 NUDOCS 8007220386 | |
| Download: ML19321A057 (9) | |
Text
i 515 West Point Avenae University City, MO 63130 July 16, 1980 Director, Division of Licensing U.S. Nuclear Regulatory Comission Washington, D. C. 20555 Dear Sir Thank you for giving citizens the opportunity to comment on the proposed NRC/DCE/Dow/
Comonwealth Edison chemical decontaMnation demonstration project at Dresden Unit One, as described in the Draft Environmental Statement (Draft EIS), NUREG-0686, issued in May 1980. However, I must protest once again that the public is being asked to forego answers to questions affecting haalth and safety because of Dow's proprietary rights. The only soientists who know the ingredients of Dow's Nuclear Solvent-1 are those employed by Dow Chemical, Commonwealth Edison, DOS or the NRC -- and these are the very soientists who have been committed to the Dresden project and NS-1 for at least several years. I continue to believe that scientists without a financial or emotional comsitment to this project should be given access to the data necessary to evaluate its potential impact.
My conecrns about the Draft BIS and the proposed decontamination center around both facts that are known and those that are not.
A. How can anyone be sure an accident will not occur during the decontamination?
We know that, centrary to basio design and operating guidelines for nuclear power plants, some areas of the Dresden reactor coolant pressure boundary have not been in-spected for seven years. Because of extremely high radiation fields at Dresden One, caused by the mooumuh tion of crud, Commonwealth Edison "reguested and was granted relief from soma inservice inspection requirements in 1973.
(Draft EIS, p. 2-5)
That is, for five years prior to the shutdown in Novembe* 1978 for the proposed de-contamination and NRC-mandated retrofitting, the NRC had " waive (d) inspection require-ments for safety-related components in plant locations where significant radiation exposures could occur."
(" Identification of Unresolved Safety Issues Relating to Nu-olear Power Plants," NUREG-0610, January 1979, p. 44). As a result, oritical nossles, an estimated 40 to 50 primary coolant pipe welds, beltline welds on the reactor pressure vessel itself, and no doubt oQer safoty-significant components have not been inspected for several years. (Draft EIS, pp. 4-1 and 5-2).
How, then, can anyone accurately prediot the potential volume or locations of leakage during the proposed 100-hour flushing? Who knows what will happen when five cr ten tons or more of a caustio, chelate-based solvent come in contact with an embrittled i*enty-year-old vessel, corroded heat exchangers and pumps, five miles of convoluted piping, etc. - with valves, welds and components fabricated out of literally countless different metals and alloyst If this system-wide demonstration project is not an experiment, as the NRC olaims on the first-page-four of the Appendix, why is the federal govornment helping to fund it? If it is not an experiment, why are there so nany unknowns?
As "dooontamination of remotors" was desoribed by the NRC's Advisory Committee on Reactor Safeguards in its March 21, 1979, list of unresolved generio items of safety significance:
"At this time the information on full scale decontamination (of primary reactor systems) is limited. Examplos of potential problems include such products, enhanced corrosion and crud formation following decontamination, and the 0p1 items as handling of decontamination solutions, potential hideout of radioactive possible incompatibility of the different alloys in the pressure boundary with the deoontamination solutions."
5 B. In the event of an acoident during the decontamination, what will be the effect upon l
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. NUREG-0686:
o the workers and the publio nearbyf Apparently no one has studied the synergistic effects of industrial solvents mixed with radiation. Although chelates are administered to workers who have ao-cidentally swallowed plutonium or mercury, oto., essential trace elements normally found in biological tissues or cells are subsequently provided to replace those materials inadvertently removed. And the quantities involved in the therapeutio use of chelates are of course miniscule compared to this project.
No one has denied there will be leakage within the plant -- there always has been.
Workers will therefore be exposed to unknown health risks, not only during the flushing, but during the evaporation, solidification, and shipment of the wastes, as well. Furthermore, if the chelates are broken down, as they should be to protect the publio, this additional step will also increase the workers' risks. At this point I am absolutely unwilling to participate in the benefit / risk game. I firmly believe i
that neither the workers nor the publio should be placed at risk!
C. What radioaotive wastes and other toxio chemicals are apt to be released to the at-mosphere during the evaporation, and in what quantities?
There seems to have been some debate among soientists at the EPA, NRC and ERDA about whether the presence of radionuolides in unexpected places at the Maxey Flats, Ken-tucky, radioaor.ive waste burial site could be blamed on the ability of nuolides to migrate at subsurface levels (perhaps, it was hypothesized, because of the presence of chelates) or whether the evaporator plume from the solidification process wem responsible for the dispersion. (EPA /ORP 520/3-75-021 andEPA-520/5-76/020)
D. Doea anyone really know what it is inside the primary cooling system that you want to let out? Is this perhaps the ultimate Pandora's box? What is the composition of the crudi Answers to these questions are important because they affect the reliability of the NRC's prediction that "the lon6est lived significant isotope that will be solidified after the decontamination is Co-60 with half-life of 5.2 years. Tests have been per-formed to demonstrate that the stability of the solid polymer will not sr.bstantially alter for over 50 years, corresponding to 10 half-lives of Co-60."
(Appendix, second-page-five).
- 1. Fission products:
{
Although a few fission products are listed on page 2-2 among the radionuolides expected to be present in the Dresden crud - namely, oerium-141 (half-life of 32 days), oerium-144 and protactinium-144 (290 days), and rubidium-103 (41 days),
l plus three additional curies of "MFP" or mixed fission products -- is it not highly probable that a far greater variety of isotopes is present, and a great deal more radioactivity? And is it not possible that some of the corrosion products, fissior.
products, and actinides in the crud may have half-lives longer than cobalt-60'st
- a. Assuming the amount of fisaton products deposited along the inre r surfaces of the Dresden piping is dependent in lar6e part upon the amount of fuel rod cladding failures, the prognosis for Dresden's crud is not good. In several publications oladding failures at Dresden One are specifically mentioned.
(1) In the first place, stainless steel cladding, used at least in the initial years at Dresden, is virtually obsolete. The only boiling water reactor still using stainless steel clad fuel is the tiny 47 MNe remotor at Lacrosse, Wisconsin.
" Stainless steel is no longer the preferred cladding material for most light water reactors because it absorbs more neutrons than does Zirca-
loy.... In boiling water reactors, stress corrosion oracking of stainless steel during normal operation is an additional incentive to use Ziraaloy which is not susceptible to this problem." (from a letter to me from Harold Dentos, Director, Office of Nuclear Reactor Regulation, dated July 30, 1979; signed by Edson Case.)
(2) In an analysis in a GE report of iodine leakage rates at BWRs, the stainless-steel-clad fuel at Dresden One was oited as having experi-enood " severe" defoots" in March 1965. (J. M. Skarpelos and R. S.
Gilbert, " Technical Derivation of BWR 1971 Design Basis Radioactive Material Source Terms," NEDO-10871, General Ele trio, March 1973, p. 4-1) c I do not know in what year the switch i:o Zirealoy cladding occurred, l
nor do I know what percent of the oladding has failed each year since.
(3) Dresden One is not unique in having oladding problems, of course. But why is this history of cladding failure and leakage not reflected in the NBC's projections of the composition of the crud?
As explained by B.C.J. Neil of Ontario Hydro at a conference on radia-tion shielding several years ago: " Volatile and gaseous fission prod-uots such as radiciodines will diffuse to and escape from the minutest holes and oracks in a fuel sheath (cladding). Water soluble fission products will dissolve in any water which enters the fuel sheath through a hole or orack especially when the fuel is temperature oyoled (i.e.,
at power changes, shutdowns, or startups)." (from "The Contribution of Fission Products to Radiation Fields in a Pressurized Heavy Water Reactor,"
PP. 402-3. Although the title refers to a heavy water reactor, much of the paper deals with problems common to all water-cooled reactors.)
While much of the escaped fission products, as well as byproducts of tramp uranium, solid daughters of noble gases, etc., will stay suspended in the cooling water and will be filtered out for burial or will be re-leased to the environment, scue will settle out and become deposited as a part of the crud. According to Neil, at one plant which had experi-enood fuel rod oladding failures, the radiation fields during shutdown were increased in some parts of the reactor more because of the presence of fission products (such as siroonium-95 and its-daughter, niobium-95, and Lanthanum-140, daughter of barium-140) than because of corrosion products.
(4) Cladding failures during the first decads of operation at Dresden are also desoribed in a Bureau of Radiological Health study:
"At Dresden, much of the fission product activity in primary coolant water is attributed to uranium that had entered the primary coolant several years previously from failed fuel elements." {B. Kahn, et al., " Radiological Surveillance Studies at a Boilin6 Water Nuolear Power Reactor," EPA: BRgDER 70-1, March 1970, p. 6)
- b. Just as there are hundreds of isotopes within a fissioning uranium core at any one time, so may a great variety of these have escaped during the operating life of a remotor to seek refuge in the crud. And they are of all ages. Some examples:
(1) Cesium:
According to a private ocemmioation sent in June '.975 to the authors of an EPRI study on the buildup of radioactivity, about 10% of the radiose-tivity released from a specimen of nickel-iron spinel deposited in the stainless steel clean-up pi ing at Dresden One (found during a decontami-nation of the clean-up loop was attributed to oesium-34 (with a half-life of 2 years) and cesium-137 30 years). The major portion of the radioao-
~ 'NtiREG-0686.
tivity came frca cobalt-60. (S. G. Sawochka, et al., "Prinary System Shutdown Radiation Levels at Nuclear Power Generating Stations, EPRI f 404-2, p.18.4, based on communication from J. S. Scott.. Dec.,1975).
I IVhile attempting to extrapolate say meaningful projections from just ces small specimen of crud at Dresden may seem grossly unscientific, appar-ently the few isotopio analyses available to the nuclear industry are not ruoh more inclusive. One of the few primary loop crud deposits ana-lysed fer isotopic information for the above EPRI study, for example, was retrieved from Indian Point One, and seems to be no larger than 4.5 square centimeters. By the way, the gamma dose rate of this small colleetion of mostly cobalt-60 measured one rom an hour! (EPRI # 404-2,
- p. 9.7)
Perhaps this paucity of data explains scue of the EPRI authors' possi-mism: "In summary, aoourate prediction of radiation levels on out-of-core surfaces or assessment of the effects on shutdown radiation levels of plant operating practices or minor design variations in current gener-ation BWRs and PWRs are not considered possibis within the state-of-the-art."
(Op. cit., p. 58)
(2) Iodine:
In an enclosure to an NRC memorandam frcm G. Knighton, Chief, Environ-i mental Branch, to D. Ziemann, Chief, Operating Reactors Branch #2, dated February 13, 1979, the manze r in which fission products may have become "I di es an integral part of the Dresden crud is described as follows:
o n and other volatile fission products which may have plated out on the 4
primary system surfaces will have decayed to insignificant levels before j
the cleaning begins so that these isotopes are generally not present."
i (p. 7) j On page 4-7 of the Draft EIS a similar statement appears: "All radioao-l tive iodine isotopes have been decayed to insignificant levels." Ifhat about iodine-129 which has a half-life of 17 million years?
(3) Zirconium:
1thile I have seen sirconium isotopes in lists of both corrosion products and fission products, siroonium olearly plays a role in helping to clog -
up a reactor, regardless of how it's labeled. And while I have not read specifically of Zirealoy cladding failures at Dresden One, there is no J
reason to think this reactor alone would have been spared.
Since siroonium-95 is listed as one of the isotopes expected to be present i
in the crud at Dresden, is it possible that sitconium-93 may be present, toof Zirconium-95 has a half-life of 63 days; ziroonium-93 has a half-life of 900,000 years. Do you ex-oot the radioactive zirconium to be present as the result of particles s5oughed off of failed Ziroaloy cladding, or as a fission product, or both?
(4) Transuranies:
llhile not technically fission products, transuranies are byproducts of the fissioning of uranium. (I am not meant to understand that sentence.)
The Bureau of Radiological Health's environmental surveillance report en Dresden One includes an especially important observation: Although the alpha-partiolo spectrometer used to study the Dresden primary coolant in 1968 was apparently only sophisticated enough to be able to identify one
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group of transuranics in the primary coolant, the presence of one probably means others would han escaped into the coolant, too. Would this not also mean that transuranies could be in the crud as wollt 1he BEH soientists attributed the group of alpha particles to curium-242.
(BR4/ DER 70-1, p. 7) Curium-242 has a half-life of 163 days, but many other transuranios will be arcund for a lot lon6er. Such as plutonium.
l
- 2. Corrosion products:
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l
- a. Should there not have been a long list of corrosion products amid the pre-dominant radionuolides expected to be present in the oxide layer at Dresden, j
on page 2-2, Table I, or the Draft EIST Ilist of the corrosion products activated (irradiated) by stray neutron be-bardment within most nuclear reactors reads almost like the periodic table of elements. There's not much missing. In the Draft EIS, however, the only corrosion products listed are cobalt-57, 58 and 60; zirconium-95; and mangs-1 nose-54. Perhaps because Dresden One has been shut down for a year mai a l
half, some of the most comon, shorter-lived corrosion products may have been expected to have decayed to insignificant levels -- though cobalt-58 is listed ani it has a half-life of only 22 days.
If there is to be a thorough assessment of the risks of dissolving crud from the interior of a reactor, and bringing it out into the human (as supposedly distinot from the worker) environment, should it not include a far wider i
range -of corrosion products?
(1) The follcwing corrosion products have been specifically identified in various reports about Dresden One -- that is, over and above the few menticned in the Dr ft EIS: iron-59 (half-life of 45 da ) iron-55 hours), nickel-65 (244 days), sinc-69 {per-64 (13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />)ys,
a 13.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />), sinc-65 (ganese-56 (2.6 (2.7 pars), chromium-51 (28 days), coo
, Man 2.55 hours6.365741e-4 days <br />0.0153 hours <br />9.093915e-5 weeks <br />2.09275e-5 months <br />; a corrosion product of Admiralty, for example, with which the Dresden One condenser was tubed until 1969), sodium-24 (15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />), phosphorus-32 (14 days), silver-110m (253 days), cobalt-57 (2?1 days),/ DER 70-1, Maroh 1970; (a ospilation from EPRI y 404-2, Dooember 1976; BR4 and General Electrio y NEDO-10871, March 1973.,
Not included in these 17, oxgen-19, and fluorine-18.) products, such as nitrogen-13,16, and studies are coolant activation (2) In addition, the following elements were listed by the Atomic Energy Canmis-i sion in WASH-1258 among " corrosion products released to the primary coolant" in boiling water reactors: silicon, carbon, vanadium, titanium, sulfur, lithium, tin, tungsten, and molybdenum.
(" Final Environmental Statement Concerning Proposed Rule Making Action: Numerical Guides for... the Criterion 'As Low As Practicable '... in... Effluents," July 1973, l
Volume 2, p. A-4)
- b. And aren't many o6 erosion products long-lived? For examples (1) Carbon-14:
Is it not possible that long-lived isotopes of some of the elements men-tioned above would be found in the Dresden crud if it were isotopically analyzed, specifically testing for those components? Once again, my conenents about the composition of the crud are aimed at two basic questions addressed in the Draft EIS: the amount of radioactivity in the crud, and the potential persistence of its hasard in the human environment.
Apparently cobalt-60 is so prevalent becausd it is the most common activa-tion product of the natural cobalt that occurs to some extent in almost all iron and niokol alloys, as well as in stainless and carbon steels. Is
+6-it possible that carbon-14 may be an activation product of carbon steel, a material no doubt present at Dresden, such as in the con-denser. If so, might some of the carbon-14 have ended up in the oxide layer?
(2) Nickel-63:
According to the EPRI report mentioned above on the buildup of radioso-tivity, approximately 200 pounds per year of nickel is released into the Dresden One reactor as the result of the corrosion of Dresden's copper-nickel and Monel feedwater heaters, an amount "at least an order of magnitude greater than that at current generation ENRs with stainless steel feedwater heaters. (EPRI f 404-2, p.18-4)
The report explains that this causes the production of more cobalt-58 and 60.
Does it not also mean that nickel-63 may be produced, toof Nickel-63 has a half-life of 92 years. I first read of nickel-63 in lecture notes of health physicist Karl Z. Morgan. He listed cobalt-60, nickel-63 and iron-59 as the most common corrosion products, Apparently at least some NRC staff members expect nickel-63 to be present in the Dresden crud also.
In the NEC memorandum mentioned above, dated February 13, 1979, George Knighton reports as follows:
27, 1978, the licensee (comonwealth Edi-
"By) letter dated Decemberhas committed to analyzing the spent decontaminati son determine the transuranio nuclide content of the solidified waste.
The licensee also committed to sa=pling the demineralizer discharge product for Fe-55 and Ni-63 at the beginning and end of the waste processing cycle to ensure that no Fe-55 or Ni-63 is transferred to Dresden 1 radwaste or Dresden Units 2 or 3."
While the processes involved in analyzing, ferreting out and keeping the transuranics, iron and nickel isolated are not at all cleat, the fact that they may indeed be present surely is.
- 3. According to pa6e 15 of the Appendix,to the Draft EIS, the Eleottio Power Research Institute is presently sponsoring research by Satte11e Northwest to develop)."a weaker but more frequent decontamination process on line."
(emphasis added I
would certainly hope that neither the NBC nor DOE would allow its licensees to use non-biodegradable chelates while a plant is on line -- or even during a routine refueling or maintenance shutdown -- unless the uranium core is removed in advance (though cores, too, become crud encrusted), and unless the deoontami-nation effluent is kept isolated from the rest of the plant's liquid radwastes so that the ohelates can be broken down before shipment and burial.cf the corro-siog/ fission ptoducts.
E.
Is it really a good idea to bond chelates to the Dresden orud - even if the pipe interiors get cleaner?
Scientists already know that chelating agents, such as those included in Dow's NS-1, can cause the accelerated migration of radionuclides through the environment. The NRC staff says it does not have " field or laboratory tests which quantify the migra-tion potential of radionuclides associated with Dow solvent...." (Dieft RIS, Appendix, fir st-pa ge-two). On the contrary, field data do exist which demonstrate that radio-nuclides bonded to EDTA, an ingredient of NS-1, have migrated through the environment at a rate far faster than that czpected if the chelates were not present. The very qualities which make chelates effective as solvents -- their ability to form clawlike multiple bonds with a metal ion, enabling them to dissolve normally insoluble metal oxides and to keep thom in solution -- are the same qualities that make them a Persistent threat in the environment.
To quote from the abstract of a study by Means, Kuoak and Crerar recently published r
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NUREG-0606 4 I
in England:
" Multidentate oholating agents such as NTA, EDTA and DNA are receiving widespread use in a variety of industrial applications and are entering i
netural water systems. The presence of those chelates in the envirennent can be undesirable because they solubilise torio heavy metals. We have analysed the relative biodegradabilities of NTA, EDTA and_DTA in several different chemical environments. The objective was to determine whether any particular chelate is significantly more biodegradable than the others and therefore more desirable from an environmental point of view....
Degradation rates of all three chelates are not rapid enough, even under ideal laboratory conditions, to preclude concern about their release to the environment." (J. L. Means, et al., " Relative Degradation Rates of NTA, EDTA and DNA and Environmental Implications," snvironmental Pollu-tion (Series B), Vol.1 (1980), pp. 45-60)
In the body of the paper a compendium of the primary hasards involved in the use of chelates includes the followings i
"While chelates are used because of their powerful metal-binairs proper-ties, it is this same characteristic which may have undesirable environ-sental consequences. For example, EDTA, which is used in nuclear decontsa-ination operations, is causing the migration ofCo from intermediate-level waste disposal pits and trenches in the Oak Ridge National Laboratory (ORNL) burial grounds. Because it forms extrousl,, strong complexes with rare earths and actinides, EDTA and similar chelatos may also be contributing to the mo-bilisation of these radionue' ides from various terrestrial radioactive waste disposal. sites in the USA.... Indeed, the presence of significant concentra-tions of EDTA in 12-to 15-year old radioactive waste at 03NL attests to its persistence. Therefore, wherever EDTA and similar compounds havo been intro-duced into the natural environment, the aqueous transport of transition met-als, rare earths and transuranics, which characteristichily form the most stable complexes with chelates, will be expected to occur....
"Also, chelates may degrade into ocmpt,unds which still possess strong metal-binding properties, although probably weaker than the original complexing agent....
"In addition to increasing the solubility of heavy metals, chelates can fur-ther increase the uptake of these metals by plants and consequently increase their ecological recycling rates and the possibility of their entering human food chains. If chelates are present in domestic wastes, they may dissolve copper, lead and iron from plumbing systems and sewage effluents and/or adversely affect sewage plant efficiency."
That last sentence might make one wonder about the wisdom of putting Dresden One back en line after the cleaning, though I have heard that Commonwealth Edison may not in-tend to take that action at any rate, decontamination or not. Apparently the cost i
of retrofitting much of the obsolete equipment to bring it into complitnoe with NRC requirements may be ennomically usjustifiable.
Although the full range of components of Dow's NS-1 is not available to the public, in a letter dated April 18, 1980, to U.S. Senator Howard Cannon from Nevada, the DCE in Washington, D.C. made the following statement, based on information provided frca the DOE 4.: Idaho Operations Office:
"The decontamination solvent and first water rinses will be collected and processed by evaporation. The resulting liquid waste is estimated to be 60,000 gallons, containing approximately 15 percent otheylenediaminetetra-
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NUREG-0686 l8-tacetic acid (EDTA). This liquid waste will be solidified using a proprietary Dow process using polyester resins."
Whether that means 15% of the 60,000 gallon sludge (the Draft EIS estimates 20,000 gallons on page 4-6) or 15% of the Dow solvent, I do not know. Neverthelessa the remainder of the letter to Senator Cannon reveals many other important faatt.and opinions:
"Inigeneral, concerns about the disposal of decontaminating agents like EDTA by shallow land burial are appropriate and shared by the Department of Energy.
The Department is currently sponsoring the following related research programs:
- 1. The quantitative effect of agents such as EDTA upcn the mobility of radio-nuolides in the soil is being determined.
- 2. Techniques are being developed to stabilize old burial trenches.
- 3. Techniques are being developed to destroy organic compounds such as EDTA.
One such method would result in a final product encased in glass.
" Disposing of the waste from the deoontamination of Dresden I at the Beat +~
site, however, should not pose a significant hazard. The Dow resin is water re-pellent, ani the lack of water at the Beatty sito will severely limit any migra-tion of radioactive wastr. In addition, the predcminate nuclide is cobalt-60, which has a 5.2 year half-life.
- The Dresden I decontamination process will probably not be used to deocntarenate i
othe r reactors. The process is applicable only to boilin6 water reactors, 21 the proposed process is not econcunical. The sponsoring utility, Commenwealth Edison, is in fact censidering a different process for Dresden II."
(from Sheldon Meyers, Deputy Assistant Secretary for Nuclear Waste Management, DOE.
Original signed by R. G. Rematowski)
Even just one or two of the above statements alone should provide reason enough for the Dresdenrose t roject-to be postponed. Data unearthed (1) by the Department of i
Energy after the crud has been bonded to the chelates and brou6ht into the environ-ment may be too late.
l F.
Does anyone know for how long Dow's solidifying plastic resins will be able to keep chelated radioactive wastes solidified"?
l I don's know hcw to connent on the reports of laboratory testa perfonned by Dow of its own solidification agent other than oynically. Nevertheless, even without being able to unsoramble which Dow ani Brookhaven tests nere which in the Draft EIS, it seems clear ths,t some cobalt-60 can ani did begin leaching out of the radioactive waste /Dow NS-3/Dow polymer matrix when immersed in pure distilled water in only one week! Although none of the solidification tests was trying to simulate burial grouni oonditions, do they not all indier.te that the Dow matrix is indeed porous and that chelated oobalt-60 remains highly mobile?
If one adds to those laboratory studies the field dats, from Oak Ridge, Tennessee (Means et al., Soietoe, Vol. 200, pp.1477-1481), Maxey Flats, Kentucky (research in Progress at the U. S. Geological Survey in Denver, Battelle - Columbus Laboratories, and Brookhaven National Laboratory), and West Valley, New York (research in progress at BNL), can anyone still be wondering whether it is wise to experiment in nature with huge quantities of Dow's plastic resins to see if they can really i:eep huge quantities of chelates frcan keeping huge quantities of radionuclides in solution -- as the chelates apparently are wont to dof What is the expected lifetime of the Dow vinyl-ester-styrene solidifying agent itself
under burial conditions, and when subjected to radiation and chelates? As studies in California, South Dakota and Illinois have shown, data collected in Oklahoma also indicate that " low levels of many potentially undesirable organic ocmpounds were being contributed to groundwater within and imediately under the Norman (Oklahcana) landfill by solid waste deposited in this landfill."
(W. J. Dunlap et al., from a symposium on " Gas and 14achate from Landfills," EPA-600/9-76-004, March 1976, p.105.
Emphasis added.) As the Dow solidification agent breaks down, oculd it, too, release components that in themselves may bond onto the Dresden radionuolides and other wastes already at Hanford ani Beatty, adding to the migratien problemt G. Can anyone be sure the Washington and Nevada sites will remain dry?
A U.S. General Accounting Office report lists characteristics identified by earth soientists about America s low-level waste dumps for which inadequate data have been collected, and "about which not enough is known to reasonably prediot the migration direction and rate (of radioactivity movement) or to determine whether reascnable pre-dictions osn be made." Major information lacking about the Hanford site includes:
" rate of infiltration (the amount of water that is not evaporated or transpired ani is free to move downward), rate and dircotion of grcund water =ovement, ani interocn-nection between shallow and deep aquifers." The data needed for the Beatty site includes " rate of infiltration, and direction and rate of grcund water movement."
(" Improvements Needed in the Land Disposal of Radioactive Wastes -- A Problem of Centuries," RED-76-54. January 12,1976; pp.13 ani 45-46.)
The same report describes the following: "'Ihrough 1974 over 140 billion gallons of liquid waste containing about 5 million curies have been discharged into the ground at Savannah River, Idaho, and Hanford with the intention that the radionotivity wculd be trapped as it moved through the soil beyond the points of release and that the ex-tent of migratien would be limited by removing the driving force of further liquid releases. As soon as technically and economically practical, ERDA (DOE) plans to discontinue such practices." (Op. cit., pp. 5, 6)
?lhere are those Hanford liquid wastes now?
Because of the possibility that len6-lived transuranics and fission products may be present in the crud at Dresden, as well as long-lived corrosion products; and because chelates in the proposed Nuclear Solvent-1 are known to cause the migration of radionu-olides through the environment; and because neither the proposed polymer matrix nor the mild steel drums is capable of serving as a permanent barrier to keep the Dresden wastes segregated from other known and unknown, liquid and solid wastes already present at the Hanford and Beatty sites or apt to arrive in the future; ani because Mother Nature --
who is in charge of 500-year rainfalls, the Columbia River and the Amargosa, groundwater and aquifers, the Cascade Mountains, earthquakes and climates -- refuses to be held accountable, I urge the Nuolear Regulatory Comission to withhold its permission for Commonwealth Edison to use chelates to flush its crud out into the human environment.
Sincerely, Mrs. Leo Drey (Esy)
,