ML19321A161

Forwards Comments on Des Re Chemical Decontamination of Facility.Des Inadequate to Serve as Model for Similar Decontaminations

ML19321A161
Person / Time
Site:	Dresden
Issue date:	07/18/1980
From:	Goldsmith R CITIZENS FOR A BETTER ENVIRONMENT
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
NUDOCS 8007220548
Download: ML19321A161 (26)

Text

{{#Wiki_filter:- Cu' - 18 July 1980 Darrell G. Eisenhut, Director A Division of Licensing U.S. Nuclear Regulatory Comission l ld Washington, D.C. 20555 Re: Docket # 50-10

Dear Mr. Eisenhut,

Enclosed please find six copies of Citizens-for a Better Environment's Coments on the Draft Environmental Statement related to the chemical decontamination of Dresden 1. It is possible that we will be filing some late, supplemental comments on the Draft Statement because we have a Freedom of Information Request, dated 2 July 1980,. outstanding.to:the NRC for which we have not received any information. I have been informed by Sarah Weddington that some materials are on the way from NRC. In the event that the.r.aterials are relevant to our coments, we. will file the supplemnt as soon as possible. - _.....s 5 h Your truly, .s- $'.= g w.,+ ~ -.1 ' TT. 1 - i -. Robert Goldsmith ~ ~. . Jr ~ '~c

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CllE 80-141 COMMENTS ON TriE DRAFT ENVIRONMENTAL STATEMENT RELATED TO THE CHEMICAL DECONTAMINATION AT DRESDtN UNIT 1 BEFORE THE UNITED STATES IluCLEAR REGULATORY COMMISSION SUBMITTED C.1 BEHALF 0F CITIZENS FOR A BETTER ENVIRONMENT BY ROBERT GOLDSMITH, ESQ. AND ROBERT GINSBuRc, PH.D. JULY 18, 1980

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INTRODUCTION The following are comments of Citizens for a Better Environment (CBE) concerning the Draf t Environmental Statement (Draf t EIS) related to " Primary Cooling System Chemical Decontamination at Dresden Nuclear Power Station Unit No.1," Comnonwealth Edison Company (CECO), May 1980, written by the U.S. Nuclear Regulatory Commission (NRC). CBE is a not-for-profit corporation specializing in environmental research and liti-gation. CBE has approximately 3500 members in Illinois and over 10,000 members nationwide. Many of CBE's members live near nuclear power plants and are seriously concerned about the environmental impact of these plants. CBE applauds the NRC decision to do an EIS concerning the decontamination of Dresden 1. However, as these comments indicate, CBE believes the Draf t EIS is technically deficient and superficial in its analysis. What is more, CBE has requested by petition a full public hearing on this EIS. Because the decontamination of Dresden I will serve as a model for future decontaminations, CBE believes that this EIS should consider the environ-mental impact of future, similar decontaminations. It is CBZ's position that a programmatic EIS must be done for the decontaminations which are sure to follow that of Dresden 1. Thus the Draft EIS under consideration is not only inadequate insofar as the Dresden 1 decontamination goes, but it is also deficient in that it fails to consider the disposal and trans-portation of all the waste generated in like decontaminations as well as

HCEEGXitlacihilf other generic issues raised in these comments. Hence, to fulfill the -mandate of the National Environmental Policy Act (NEPA) the NRC must prepare and circulate an EIS related to the chemical decontaminations of light water, commercial power, nuclear plants. GENERAL ORGAFIZATION AND ANALYSIS The overall organization and analysis of this Draft EIS are deplorable. Many pages are not even numbered. Several tables and charts are direct transfers from other documents. Much of the text is verbatim from pre-vious memoranda or submittals. All of which evinces a failure to under-take a serious, independent, systematic analysis of the proposed decon-tamination. This certainly violates the spirit of NEPA and in many instances the letter.2 Beginning with Table 1, p. 2-2, the EIS directly lif ts this table from i-CECO's submittal of April 14, 1975. These data are crucial because they are relied upon to determine how radioactive the resultant waste will be. Hence CECO's own data, not the NRC's, form the foundation upon which many steps and decisions are built. The EIS does not mention any' con-firmatory testing done by NRC or any other federal agency. This abdica- . tion of an essential piece-of analysis negates the role of-federal ' assessment of the environmental. impact of the project. '1..Section '102 o'f NEPA requires compliance "to the fullest extent possible." i ~2. See sections 102(2)(A) which requires a " systematic, interdisciplinary approach" and.102(2)(C) which requires a " detailed statement." - ~.

, MC8EC M i.i iG Tables 3, 4 and 5 and figure 2 in the Draf t EIS are all identical to Table I, pages 5-9, and Figure II, p.15, found in CECO's "Dresden 1 Chemical Cleaning Licensing Submittal," dated December 16, 1974. This direct transfer from CECO's submittal to the EIS again reflects the utter dearth of independent agency analysis. All the alternatives short of shutting the reactor down (see infra) are thus lef t up to the inter-ested industry. In no sense of the term can the fiRC in this Draft EIS be said to have taken a "hard look" at the environmental conse-quences. If anything, the uncritical adoption of an industry study submitted nearly six years ago demonstrates the flRC's desire to jus-tify a decision already made and thus directly contravenes the Council on Environmental Quality (CEQ) regulations implementing f1 EPA, 40 CFR 1502.2(g) and 1502.14 The analysis of Radioactive Waste, section 4.2.2, p. 4-6 et seq., is derived virtually word for word from Attach:nent 1 to a me c'randum from G.W. Knighton to D. Ziemann, dated June 21, 1979. Even the conclusion on p. 2 of Attachment 1 is identical to the conclusion at the end of section 4.2.2 of the Draf t EIS, except to the extent that the Draft EIS cites different regulations and statutes. On the face of it, this is not necessarily illegal since the flRC did perform some of its own anal-ysis. However, it should be noted that Attvhment 1 is based in part upon an earlier evaluation of December 9,1975 along with information added since 19. t The EIS, on the other hand, adds nothing to the anal-ysis of June 1979 and thus we wonder whether the flRC has overlooked any

_4 ECBE12Ji?) I u y G new developments and information since that time. Again this betrays NRC's cavalier attitude toward this EIS. To a lesser extent the section on Occupational Radiation Exposure, 4.2.1, pp 4-1-4-6, is derived from a memorandum from G. Knighton to D. Ziemann, dated February 13, 1979. This section, in addition to the previous sections derived elsewhere, leaves only four to five pages of text which were done for the sake of this EIS. It is clear that this EIS is a " cut-and-paste" job and by no stretch of the imagination ful-fills the requirements of NEPA. ANALYSIS AND NATURE OF THE RADI0 ACTIVE " CRUD" The initial step in analyzino the problem of radioactive deoosits on reactor coolino pipes is to accurately identify the nature of the deposits. l The NRC has <oparently failed to accomplish this task-. The value for the total amount of radiation, as reported by the NRC to Prof. Banaszak on 9/7/79, has a very large error ( 3000 + 1000 curies ). The total amount of radiation to be removed has an impact on several areas of the project, esoecially radiation exposure and waste disposal. ) l Without an accurate assesnent of the amount of radiation in the pipes there cannot be effective plannino. The Draft EIS also does not indicate how the sampling was done, where the samples came from, how long they had been removed from exposure to radiation ( in order to deternine the presence of shorter lived isotopes ), and the source of the laroe error. The second critical question af ter the determination of the total amount of radiati,n to be removed is an analysis of the specific q

. hC8Erfi m W t radionuclides present in the crud. There are two aspects to this question. First the nossible presence of fission products and transuranics and second the oresence of other radioisotopes generated from the materials in the coolino system. It is surprising to us that Table 1 does not contain any isotopes of materials found in the cooling system such as Fe, Cr, Ni or Cu isotones. It is odd that the components of scainless steel ( which was most likely used for at least part of the cooling system ) would not contribute to the radionuclides in the crud. Furthermore a study by EPRI (see Appendix A) in December 1976 indicated that in 1968 large quantities of Cu-64 were found in the reactor water. Since Table I was constructed by CECO in a reoort prior to the shutdown of Dresden 1 in October 1978 it is surprising that Cu-64 is not included in the table. The presence of fission products in the crud is of even greater concern given their longer half lives. The same EPRI reoort, mentioned above, indicated that Cs-134 and Cs-137 had been in some deposits in the stainless steel clean-up piping at Dre 2n 1 during a decontamination of the clean-uo loop. Both Cesium isotooes are fission products with half-lives of 2.1 and 30.1 years respectively. Furthermore the Draft EIS mentions in section 4.2.2 that radioactive Todine levels will have decayed to insignificant levels. If I-129 or 1-131 are present,then other long lived fission products should also be present. If the NRC concludes they are not, a detailed explanation of that conclusion is necessary. As mentioned previously, paragraph d.2.2 in the EIS was copied nearly verbatim from an earlier CECO report. Only the sentence on the radioactive iodine

aC8E 0nlu Ci! was added. Obviously the NRC thought it important enough to mention the possible problem from Iodine isotopes ( and by implication the presence of other fission products ) in the crud but not important enough to offer any reasons or explanations. The absence of any of these radioisotopes from Table 1 or any explanation of their absence raises serious questions about the adequacy of the analyses performed by CECO and Dow and their subsequent evaluation by the NRC. CORROSION One of the primary concerns of the NRC should be some assurance that the decoritamination does not degrade the integrity of the primary coolant system boundary. Unfortunately the Draf t EIS addresses this problem most perfunctor 41y. One of the bases of public concern over the decontaminati,n has been the possibility of damaging the reactor and thus precipitating a major accident in the future. The NRC has ignored the concerns of the public as well as of government scientists. In particular, a memo from John Weeks (4/16/79) at Brookhaven National Laboratories (BNL) expressed concern that significant amounts of NS-1 solvent might be trapped in creviced areas around bolts or in creviced pccLets formed by gelvanic corrosion near defects of the vessel clad. The water rinse cycles could ensily fail to remove such trapped solvents. The longer the solvent remain, the more corrosion becomes significant. These concerns were initially raised by studies done by Dow and GE on various steel types found in the reastor. Those studies reported that type 410 steel which is usad in a number of bolts and valves in the core support system is susceptible to corrosion under certain conditions. The BNL memo said that such conditions could readily exist in the reactor

4 i especially if there is an extended period between the decontamination and start up. It is likely there will be such an extended period since Dresden 1 will not be on line again until 1986. At page 14, Appendix A of the Draf t EIS, the flRC states that the chelating agent decomposes at 300 deg. F. Without knowledge of the formula for flS-1 it is impossible for commenters to confirm whether those decomposition products will indeed be innocuous. It is likely that the decomposition products will include other complexing agents or remain corrosive in some other fashion. Thus even the start up of the reactor would not alleviate the problem of trapped solvent. REMOVAL AND C0f1TAINMENT OF USED 50LVEf4T Since the decontamination solvent is not described in detail because of proprietary rights, several questions arise concerning the nature of the radionuclide-chelate complex. Since such complexes and the uncomplexed chelates are known to be highly mobile in the environment ( see Crerar et.al. article referred to in Appendix A of the Draft EIS ) and the food chain, there is great concern over any possible release of these materials. At ter the decontamination, CECO plans to concentrate the decontamination solvent and the first rinse in an evaporator and further purify the distillate by passing it through a demineralizer. Other rinses, if necessary, will be purified similarly. If the complexes are non-ionic, significant quantities of radioactivity may distill over into the distillate along with some uncomplexed chelate. Moreover, any non-ionic species will be less efficiently removed from the distillate or later

iiCBEa R1 c ( V rinses than will ionic species. Such a situation could lead to increased time and costs in purifying the waste water and storage of the wastes. The Draf t EIS also does not address the fate ( i.e. eventual disposal ) of these demineralizers and evaporators. They could be highly contaminated with radioactivity. Also, if any chelate ( whether complexed or not ) were trapped in the pipes and only slowly leached out over time, it could eventually be flushed into the Illinois River. The release could cause radionuclides emitted in past years and now trapped in river sediments to be resuspended or redissolved and thus reenter the food chain. This would pose a long term problem even if only small quantities of chelate were involved. Even 0.01 of the original 200,000 gallons from the decontamination and first rinse could provoke serious environmental consequences. The Draf t EIS does not adequately discuss these points, if address them at all. PACKAGING AND DISPOSAL OF THE CONCENTRATED WASTE The Draft EIS states that the concentrated waste will be solidified with a vinyl ester-styrene polymer in 55 gallon steel drums. In the process of describing the procedure ( Draft EIS, section 4.2.3 ) the NRC shrugs off concerns about (1) the lifetime of the steel drums and whe her they will remain intact long enough to be buried, (2) that the polymer matrix and steel drums will not prevent significant leaching, even at the " drier" disposal sites and (3) what will happen if the waste has radiation levels greater than 10 naccuries/ gram and cannot be

hC8E ':T ~ 1 t i 'J disposed of in a low level waste depository. As to the durm's lifetime, experimental results from BNL ( H. K. Manaktala memo, 10/31/79 ) indicate that pockets of liquid would be very corrosive to commercial grade mild steel used in the drums. Such pockets of liquid could form for several reasons, including mixing errors and variations in the composition of the solidified waste. The data showed that formation of pin holes was easily possible in 1 to 3 months. It is likely, given the extent of the project, that the barrels will not be delivered to the disposal site for several weeks af ter they are filled In that time period it is reasonable to assume that some of the drums could develop small leaks. In the face of the BNL conclusions, the Draf t EIS ( section 4.2.3 ) concluded otherwise. The Draf t EIS almost completely ignores the problems of chelates leaching into the environment by saying that the chelate complexes will be trapped in the polymer matrix and surrounded by a " dry environment" H' wever even in a dry environment a concentrated plume of chelate bound radionuclides could slowly leach out of the barrels and eventually the site. The solidification is only for ease of transportation and to slow down leaching - not eliminate it. In this case migration could be easily aided by the NRC's proposed burial policies. In particular, the NRC proposes to segregate the waste from everything but crganic materials like toluene and xylene. In our experience such materials could probably dissolve the polymer

m.C BE a u 1.i M natrix freeing the radionuclide-chelate complexes. In such a situation a highly dangerous form of radioactivity whose physical and chemical characterisitics are unknown would be released. It is frightening to see the flRC recommend a procedure which could have such consequences and runs counter to their own stated goals. The problems raised in the first section of these technical comments concerning the amount of radioactivity and the nature of the radionuclides has further significance for the waste disposal problem. The presence of significant quantities of long-lived radionuclides and/or transuranics that increases the level of radioactivity over the limit for low level disposal would pose a very real disposal problem for the project. In that case the waste would have to be stored at Dresden until a "dcpository operated by the U.S government which is authorized to dispose of transuranic waste" is created ( Draf t EIS, Appendix A ). That may take a long time. Alternatively if the waste is still " low level" but with longer lived isotopes than Co-60, leakage from the waste disposal site and contamination of water and the food j chain could be very significant and hazardous. In either case, the assurances by the fiRC in section 4.2.3 that the waste can be isolated from the human environment for a long enough period of time are not satisfying or even barely adequate given these uncertainties and the unanswered questions in the Draf t EIS regarding the amount and type of radioactivity. TRAtlSPORTATIO:t At4D EMERGEi1CY PROCi 'URES The Draft EIS does not mention or even appear to have thought about

e C8E R X m taiiif about the problem of transporting the waste from Illinois to Washington S ta te. We ha.>e already described the possibility of pin hole leaks developing in the drums. There is also a real possibility of a highway accident and resulting spills.The latter is even more serious since tae NRC estimates from 10 to 100 trucks for transporting these wastes which must be multiplied for future decontaminations the NRC is planning. A spill from one of these trucks could cause severe long term harm. There is no mention in the Draft EIS of special precautions that will be necessary in the case of an accidental spill. The Draft EIS downplays the possibility of anything going wrong with their plans. There are no contingency plans to inspect inaccessible welds, bolts etc. if accessible welds and bolts show signs of damage from the decontamination. There are few, if any, details on the post decontamination inspection procedures and criteria. There are no stated contingency plans to deal with any other potential problems at the reactor during or af ter the decontamination. Given the danger from the chelated forms of radiation in terms of human exposure as well as incorporation into the food chain the NRC should have paid more attention to precautions, plans and criteria in case of an [ accident.

. M C B EL4 f;* rT SilVT Tile REACTOR DOWN PERMANENTLY The alternative of shutting the reactor down permanently is given short shrift. Three short paragraphs are devoted to the topic and no detail or supporting data are given. The conclusion that $300 million could be saved over 15 years is unsupported. A 60% " availability factor" is as-sumed and yet a capacity factor is required to determine the accuracy of the $300 million. No cost per kilowatthour (kwh) for the replacement power nor for Dresden 1 to operate for' the next 15 years are given, elim-inating the possibility of auditing the $300 million. The analysis is thus made up of conclusory statements and violates section 102(2)(C)(iii) of NEPA as well as CEQ regulation,10 CFR 1502.14. Even without the supporting data, a $100,000 per day replacement cost is unduly high. Although $100,000 per day may fairly represent the cost of purchasing the replacement power from other utilities, it is not a real-istic figure. For example, during periods where there is little or no seasonal demand above the base load, such as spring or fall, CECO could very well replace Dresden 1 with its own base load generating plants.3 Adding to the unreality of the $100,000 per day figure is the fact that 3. Excluding Dresden 1, CECO owns over 12,000 megawatts of coal or nu-clear plants. ( Annual Report of CECO for the year 1979 to the Illi-nois Commerce Coninission (ICC)) CECO's estimated base load for 1978 was 8,727 megawatts (see Exhibit VI-3-b in the rebuttal testimony of G.F. Rifakes submitted by CECO in ICC Docket # 79-0214.) Even if the the base load grows at 4' a year, Ceco will own an ample enough margin to use its own base load plants to replace Dresden 1 for much of the year, and in a few years new base load plants will be on line. r: CBEiit K' C CECO does not plan to return Dresden 1 to service until June, 1986. (CECO's Load and Capacity Statement, May 28,1980) At $100,000/ day, this amounts to approximately $219 million. ($100,000/ day X 365 X 6 years) It is therefore apparent that neither the $100,000 per day nor the $300 million for 15 years are meaningful figures. The ultimate comparison of $300 million with the decontamination cost of $39.5 million is misleading and improper. To begin with $300 million is not properly comparable to the estimated $39.5 million cost of decon-tamination because the $39.5 million does not include the additional cost of generating electricity at Dresden 1 for the 15 year period. To properly compare the $300 million to the cost of decontamination, the cost of operating Dresden 1 for the 15 year period must be added to the $39.5 million. According to CECO's Annual Report to the ICC for 1979, the cost of running the Dresden station was 8.47 mills /kwh.4 Assuming a 45% capacity factor, the daily operating cost of Dresden 1 would be approximately $18,300. (200 megawatts X.45 X.00847 X 24) Over the 15 year period (actually only 9 years of operation, considering the 605 availability factor) this would amount to about $60.1 million. Add this to the $39.5 million, and $99.6 million is the proper starting point of comparison. 4. This figure does not actually include Dresden 1 because it did not operate in 1979. However, it is unlikely the oldest, smallest plant of the three would decrease this average cost.

i: CBE : i; ' 11 e i As has been noted, the $300 million is unduly high since CECO cou d l replace much of the electricity from Dresden 1 with its own base load, thus narrowing the gap between $99.6 million and $300 millien even more. Moreover, it is probable the a 60I capacity factor was assumed in arri-ving at the $300 million calculation.5 If this is the case, then the capacity f actor assumption is significantly erroneous and hence biases the $100,000/ day figure upward. For Dresden l's actual capacity factor is around 45% cumulative.0 The actual experience, a 45% capacity fac-tor, would substantially reduce the $300 million replacement cost, thus narrowing the differential even more. 5. This is quite likely since a 200 megawatt plant with a 60% capacity factor i Juld require 2,880,000 kilowatthours of replacement power each day. CECO currently purchases economy power at the suggested price of 3.5c per kwh. (CECO Exhibit 2.003, second revision, sub-mitted with R. Heumann's testimony in ICC Docket #79-0214.) 5100,000/ day with a 607 capacity factor at a 200 megawatt plant means the purchased power costs between 3.4c and 3.5c per kwh. 6. See fiUREG-0618, Nuclear Power Plant Operating Experience 1978, where the 1978 Dresden 1 capacity factor was 44t, and operations were considered routine during the year. (p. B-80) See also, NUREG 0200, Operating Units Status Report, March 1980, where Dresden l's cumulative lifetime capacity factor (DER Net) is 45.47 (p. D-5) 7. The purchased power replacement cost would then be about $73,900 a day, or about $242.8 million for the 15 year period. This is still an inflated figure because it fails to account for CECO's own generating capabilities.

, CBE; F Ul.1 rn Hence the comparison of $300 million to $39.5 million is a mea.ingless exercisc. The incorrect, implicit capacity factor, the assumption of only purchased power as the replacement pcser and the failure to account for Dresden l's operating cost thus totally invalidate the analysis which eliminates the alternative of shutting the reactor down. From our analysis the cost differential between shutting the reactor down and decontamination plus resumed operation is not so significant as to outweigh the risk of environmental degradation from the entire project. Therefore, we believe NRC must perform a more thorough and supportable analysis before this alternative can be honestly discarded. RE_ QUEST FOR A PROGRAMMATIC EIS CECO's proposed decon+ amination of Dresden 1 will be the first, large-scale commercial reactor system decontamination in the United States. 9 This decentamination experiment is expected to provide experience and 8. See letter of Harold Den:cn to Mrs. David Deutsch, dated September 14, 1979, in which Mr. Denton calls the Dresden 1 decontamination "...the first full-scale application of Dow Chemical's solvent NS-1 for the decontamination action of a complete primary coolant system." (at p. 2) 9. See letter from Ruth C. Clusen, Assistant Secretary for Environment, Department of Energy, to Mrs. Leo A. Drey, dated August 2,1979, in which Ms. Clusen states: "Thus, no NRC license was issued specifi-cally for the decontamination experiment."

. t2CE JJ W t13 l0 background for future decontaminations at other nuclear reactors under NRC regulation. The NRC should not consider the Dresden 1 decontamination in a vacuum. Instead, it must assess the environmental impact of subsequent decon-taminations. The 5.aste generated during the Dresden decontamination may not present a significant transportation or disposal problem, assu-ming our other concerns are not realized. Nonetheless, the decontami-nation of 20 or more reactors may change the dimension of the problem. Hence the scope of this EIS is too narrow. Under CEQ regulations im-plementing NEPA, connected actions which are closely related must be discussed in the same impact statement. 40 CFR 1508.25(a)(1). Cumula-tive and similar actions, as well, merit a programmatic approach under the CEQ's regulations. 40 CFR 1508.25(2) and (3). The waste itself will obviously be accumulated af ter several decontaminations. CBE, therefore, fornally requests that a programmatic EIS be written re-lating to future chemical decontaminations of commercial nuclear reactors. 10. The NRC in a response, dated May 21, 1979, to questions from the Illinois Attorney General's office, (at p. 6) stated: "However, it is very likely that the Dresden decontamination program will provide valuable confinnatory experience and background in large scale reactor system decontamination that will be useful in any Three Mile Island decontamination." See also, a letter to Mrs. Kay Drey, dated November 21, 1977, from Paul Pettit, Division of Nuclear Power Development, Department of Energy, in which he states: "The Commonwealth Edison Company is under contract to the Department of Energy to develop,, demonstrate and document methods to chemically clean reactor equipment in nuclear power plants." (at p. 1) (emphasis added.) ) i } L

Appendix A nace 1 of R ~. 2. LIOGR APHIC D ATA 1.8**Poreh. ~

5. Report Daie '

4. Tsale and Subeeile December 1976 Primary System Shutdown Radiation Levels at *!uclear Power Generating Stations S. Performing Organization Rept.

1. ^Mihad s t

• l. Pearl, N. Jacob, S. Sawochka No.

10. Proiect/ Task / Work Uni No.

9. Performing Organesseion Name and Address RP 404-2 fluclear !!ater 5 Flaste Technology

" Caa""'/G's a' Na-P. O. Box 6406 San Jose, CA 95150

13. Type of Report as Period

12. Sponsoeing Organis ation Name and Addre s s Covered Electric Pcwer Researc:1 Institute FINAL REPORT 3412 Hillview Avenue a d.

Palo Alto, CA 94304

15. Supplementasy Notes This recort documents the results of a survey of oneratino nuclear stations

16. Abieract s to determine the extent and seriousness of radioactivity buildun in nuclear olants; to access the value of the available data base for extranolatinn observations to lonner coeratina times; to define corrective ontinns and associated R'D nronrams; and to define additional information qatherinn nroqrarqs where needed, ty G ords and Document Analysas.

4 7o. Descriptors .qitt 'later Reactors -3 tion levels activity Buildun i

urvey atta009CID St 17b. IJentifiers /open-Ended Ter*'

NATIONAL TECHNICAL INFOR/AATION SERVICE u 5 OIPas1Mimi CF COMM(ect irst f4.f ILLO. v AL.2161 i 17c. CosAT1 Field, Group

19. decurit y t la s s (This (21. No. ot r' ages j

18. Asailabitat y Statement R e poes )

Ne i. A9CIF IF O

a. see. iy um i i n..

RELEASE Utill'11TED ene t 'NC I A R<t f' t F D ro mw ee r e t-as e n s,. se. p as LN LA.)RSE D 19 Y A Mt # h D t. *s t $( O [ HIS t(JM *4 M AY ti t J4 t P t'UDIJ( I' D u sC Qom O c a J es.p r o ~ I

f page ? of 8 ( llu}Q < > l C ^ Dresden I Cescri p tion Dresden I (01) is a dual cycle GWR rated at 700 f4Wt and 210 MWe (200 fMe net). The core contains 464 tuel elements, each composed of 36 Zircalov-_2 clad fuel rods in a 6x6 array. Steam generated in the stainioss stool clad o rbon steel _ pressure vessel is delivered as a steam-water mixture to the primary steam drum 6 where separation occurs. Primary steam f low is approximately 1.5x10 lbs/h at 1000 psig. Secondary steam is produced in four stainless steel tubed steam gen-erators,at 500 psig. Reactor water cleanup at approximately 270 gpm is handled .b a system consisting of 4 regenerative and I non-regenerative stainless steel y h4cd heat exchangers and 2 deen bed deminerali zers. Full flow ( sv 3000 gpm) uMensate treatment is handled in the primary system by 2 deep bed demineral-The 2 low pressure

p. Primary feedwater is returned to the steam drum.

f* and 3 hiqh oressore gater_ hoaters in the primary system are tubed with 70-30 ' cooper-nidel and Mone, respecti vely. Primary system piping is stainless steel. The condenser, originally tubed ni th Aemi ral ty, was retubed wi th s tainless steel b) b % 2n. (,3 (mp,,)y,y in 19ti9. awJ c,77a s %. 4.1 .1 h Primary Con tai nment Radi atien i.evel ?'easuremen t Program dl1 D.s. l. - u,J. In mid-1974, a shutdown radiation level review was perf ormed by Commonweal th 12 Edison personnel. The f ol lowing is an excerp t frcm that s tudy. "A. 01 "A" and "C" Secondary Steam Generator studies p...,. x, Dose rate build-up surveys were performed i n both " A" and "C" l Secondary Steam Cenerator Roce.s during major outages f rom 1960-I966. ); Approximately seven sets of dose rate measurements were obtained at each of 36 speci tied locations in these rooms. Surveys from Nov and [ Cec 1973 were reviewed f or measurements at these same locations in order tc extend this s tudy to the present. Representa ti ve resul ts were normali zed to the Nov 1960 data and are presented in Figure 18.1. ( p?rt /I. ) i Al2. BBS Letter No7-74 to F. A. Palmer, W. P. horden, W. t. Kiedasch/ i R. A. Pavlick, July 12, 19 74 k 18.i Ir

page 3 of 8 e included in this program. Avai lablo dose rates at survey points in s team generator roces B, C ?. D are given in Table 18.3, ) Water Chemistry { t General: During normal operation, reactor nater pH and conductivity f alls wi thin 5.5 to 8.5 and 5 0.5 pmhos/cm, respectively. The average s aluble nickel concen trations f rom 1963-1968 ( 1.1-4.5 EFPY) in .;6 the condensato demineralizer ef f luent, ag feedwater were 6 ppb and 20 ppb, j respectiveIy. As a result of corrosion of the MoneI and concer-nickeI f eedwater heaters, this nickel input to the reactor, - 200 lbs/y, is at leas t an order of magni tude greater than that at current generation BWRs wi th stainless steel feedwater heaters. As such, it is expected to strongly influence corrosion product deposit on the fuel and to lead to larcer than average rates of Cog and g o production. Corrosion Product Radiochemis try : Avai lab le total (solub le and insolub le) 'A reactor water isotopic data are given in Table 18.4 Hicn concentra-t i one, nf Cu 64 and Cn-5A tre indicatise of the ger and nigel ig t, y respectisely f eco the feedwater heaters. Radiochemical analysis of a nickel-i ron spi nel depos i t, found in the stain- ! css. clean-up piping gino d d_econtaminatien_ of the clean-up loop, indicated Al6 tha t the major acti vi ty was Co-60 wi th abou t 101, due to Cs-134 and Cs-137_. j . y., c* b

2. yurs h>y.

L, s ' '" ti s Al3. A. B. Sisson, " Water Chemistry at Dresden Nuclear Power Station", l Paper published at the Hous ton flational Association of Corrosion Engin-eers Meeting, Apri l 1969 ) Al4 J. M. Skarpelos and R. S. Gilbert, " Technical Derivation of BWR 1971 Cesign Basis Radioactise '4aterial Source Terms", NEDO-10871, General E l ec tri c-Company, March 1973. 1 AIS. B. Kahn, et al., " Radiological Surveillance Studies at a Boiling Water tiuctear Power Peactor", U. S. Departmen t of Heal th, Education, and Welfare, Public Health Service, 1969. A lb. J. S. Scott, P r i va te Ccemun i ca t i on, June 19 75. 18. I

~.. n n 3 u Page 4 of 8 a TABLE 18.1 URESCEN I SECONDARY STEAM GENERATOR RADI Ail 0N SURVEY IN OCTOBER-DECEMBER 1973 I ( ~ 7.1 EFPY) E i Steam Generator (mo/h at 2")_ [ Oescription/ Location of Measurement A B C D L 1. Handhole cover (right) 22 900 1600 300 ' t 2. Handhole co/er llett) 110 60 0 900 100 l 3. Bottom drain (right) 3900 3500 2500-3000 3000 1 4 Bottom drain (left) 3000 3500 2500-3000 1500 f 5. Primary side vent (rignt) 1200 30 0 1300 3000 i l' 6. Primary si de vent (lett) 1600 550 1100 3000 p 7 To lef t of primary side vent, I" pipo NR' NR* NR* 600 l cupped off (secondary side drain) i 3 8. Pump tcp of vent 20 250 500 600 ) 9. Valve-to right of pump top at vent NR' 150 300 30 0 10. Decon flange 60 0 NR* 650 400 1 11. Suction side, decon f lango NR' NR' NR* 600 12. Primary lead drain line NR* 1200 NR' NR* t 13. Secondary side drain NR' 800 NR' NR* I l 'NR - Not Reported P 18.5 1 I

r page 5 of 8 Table IB.2 EARLY RADI AT10t4 LEVEL MEASUPNEt4TS Ot1 RECIRCULAT!0ft L!r4E I UPSTREAM OF PtJ4P tra LOOPS A At40 C AT ORESDEl4 1 Rad i a ti on level, mR/h EFPY Loop A Lcop C 0.4 70 120-130 0.6 50 70 3 0.8 70 60 i 1.1 90 1.2 50 90 l f 1.8 100 200 2.3 400 2.4 600 350 3.4 400 l \\ f l I6.0

c e pa9e 6 of 8 TABLE 18,3 DRESCEN I PADIATION LEVELS IN STE W GENERATOR ROOMS CN JUNE 22, 1974* ( ~ 7.4 EFPY) Point Approxi.. ate Dose Rate e Number Elevation (MR/H D.} C# l-3 0 SSGR 529' 360 2-1 0 SSGR 529' 15 0 3-3 0 SSGR 529' l 320 4-3 S SSGR 529'

220 B SSGR 529'

/60 5-1 l l 330 6-3 8 SSGR 529' 7-3 c SSGR 529' l 330 8-1 C SSGR 529' l J. sr o 9-3 f C SSGR 529' l 130 ' Blue Diarend Survey i 18,7'

.Aof .p page 7 of 8 ..e 9v s TABLE 18.4 DRESDEtl i REACTOR WATER IS0 TOPICS /j [ -1 (pCi /rnI ) ' 3;, qI$. Date (EFPY) '!A Al2 2/l/68 (4.I)A13 8/22/68 (4.3) A13 Nuclide 1963 [f Cr-SI 500 tim *

• 500 E

Mn-54 NR"- NM " 2

• 1g Fe 60 flR' NR*

2 1 -,3 pe 4-- Co-58 5000 - 14000 - 1700 ~ p. Co-60 500 2200 260

g..:

gg-9, ', .y 4--- Cu-64 60000. IC000 - 2200 i.h fli-65 300 NR' NR* -.. ii .Q <,).T Zn-65 2 NM" 4

...,e Cs-.I34 NP' I3 23

' f'yi Cs-137 NR" 30 44 j. ..n

q'

?,, 'I

• l

'em 1 t1 t 1 t .l?2*O I {s s. ..f,,,o I, s.. 4. I f, 4 - , 'c l

• tiR - tiot Reported
• *NM '- tio t Measured

.T l.t II - 1: l 1 18.8 e 6, i i<

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