ML19323A469

Responds to Ltr Re Chemical Decontamination of Facility. Disposal of Waste Will Not Cause Any New Hazards Not Previously Evaluted.Disposal Is Acceptable.Forwards Safety Evaluation

ML19323A469
Person / Time
Site:	Dresden
Issue date:	03/15/1980
From:	Vollmer R Office of Nuclear Reactor Regulation
To:	Malone L AFFILIATION NOT ASSIGNED
Shared Package
ML19323A470	List: ML19323A469 ML19323A472
References
NUDOCS 8004210252
Download: ML19323A469 (5)

Text

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i UNITED STATES y

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March 15,1980

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Docket No. 50-10 5

Mr. Larry Molone 203 E. Stoughton #13 Chagaign, Illinois 61820

Dear Mr. Molone:

This is in response to your recent letter to Chairman John Ahearne, which expressed your concern related to the chemical decontamination of Dresden Nuclear Power Station, Unit No.1.

l We have been reviewing this project since Comonwealth Edison's initial decontamination proposal on December 12, 1974. On December 9,1975, de issued a conditional authorization which allowed Comonwealth Edison to initiate the chemical decontamination subject to the completion of three items which would be resolved as follows:

1.

The testing program will be completed and the results submitted for the review and approval of the NRC staff prior to performing the proposed chemical cleaning.

2. ' A pre-service inspection program for the primary cooant boundary will be fornulated and submitted for NRC review and ap;iroval prior r

to returning the reactor to service.

3.

A post-cleaning surveillance program which includes additional surveillance specimens and a specimen withdrawal and exannnation schedule will be submitted for NRC review and approval prier to returning the reactor to service.

A copy of our Safety Evaluation in support of these actions is enclosed for your information.

Since our 1975 authorization Comonwealth Edison has completed its materials test program and constmetion of the necessary support facilities to carry out the project in a safe and environmentally acceptable manner. Our review of the testing program and the facility construction is continuing and will be cogleted prior to the chemical cleaning that is currently scheduled for early 1980.

I The decontamination process involves the circulation of a Dow Chemical Company cleaning solvent through the reactor primary cooling system.

The solvent, identified as NS-1, has been developed to remove the thin, tightly adherent, layer of highly radioactive oxide that has formed on the inside surfaces of the Dresden 1 primary cooling system.

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Mr. Larry Molone March 15,1980 The solvent will preferentially dissolve the oxide without significantly l

attacking the underlying base metal of the primary cooling system piping.

After removal of the uranium fuel, the solvent will be circulated through the primary coolant system for approximately 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> at about 250*F.

After circulation the solvent and the dissolved oxides will be drained from the reactor to a waste treatment facility located adjacent to the reactor. Any remaining solvent will be cleaned from the reactor by rinsing with deminerali:ed water. The rinse water and solvent will be stored in the waste treatment facility storage tanks until processed to concentrate and solidify the solvent and dissolved radioactive corrosion products.

The decontamination will be carried out entirely within a closed system i

and all waste processing will be accomplished within a specially designed, earthquake proof, leak tight, building. All transporation of radioactive wastes will be done in accordance with all applicable NRC and Department of Transporation regulations. Because of these precautions, there will be no increased hazard to the health and safety of the citizens of Illinois or any degradation of the environment in Illinois.

After processing the concentrated waste solution will be solidified in 55 i

gallon drums using a process developed by the Dow Chemical Conpany for the solidification of low level radioactive wastes. This solidification process has been tested on the NS-1 solvent and produced a solid waste form that I

contained no free liquids. The waste solidification procedures include a quality control process test on each barrel of waste to provide additional assurance that the liquid waste has been properly solidified.

After solidification the waste drums will be transported by a comercial radioactive waste carrier to a licensed solid waste burial ground such as Beatty, Nevada or Hanford, Washington. These arid, desert sites have been specifically selected for the disposal of the Dresden waste to further assure that there is no interaction of the waste with ground water. Because the waste is in a solid form, the ground water level is approximately 300 feet below the surface, and the burial sites are located in remote, uninhabited locations, there is adequate assurance that the waste will remain isolated from potential pathways for exposure of the population.

The cost of the Dreeden 1 decontamination has been estimated at 36 million dollars. Much of this cost represents one time development costs which would not be incurred in subsequent reactor decontamination at Dresden 1 or other nuclear facilities. At this time there are no plans to decon-taminate the primary cooling system of other U. S. nuclear facilities.

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Mr. Larry Molone March 15,1980 however, preliminary estimates of the cost for decontamination currently operating U. S. reactors range from 1 million to 5 million dollars per l

reactor and would vary depending on the extent of modification required at a. specific facility to perform the decontamination.

The decontamination of reactor primary cooling systens will reduce the I

radiation exposure levels in the areas of these systems, thereby permit-ting greater access to the system for inspection, modifications, and i

repairs. These activities provide greater assurance of the continued i

safe operation of the reactor and are therefore in the best interest of I

the health and safety of the public. Furthermore, the decontamination i

will reduce the occupational exposure of the individuals employed at l

Dresden.

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With respect to requests for the preparation of an Environmental Impact Statement for the Dresden Unit I decontamination, the Nuclear Regulatory Comission is fully comitted to satisfying all requirements of the l

National Environmental Policy Act (NEPA). Our regulations which implement the NEPA requirements are contained in Title 10, Part 51.5, of the United States Code of Federal Regulations. These regulations are in conformance l

with guidelines issued by the President's Council on Environmental Quality i

which were in effect prior to July 30, 1979. They identify the following l

types of actions for which NRC must prepare an environmental impact i

statement:

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"(1) Issuance of a permit to construct a nuclear power reactor, testing facility, or fuel reprocessing plant pursuant to Part 50 of this chapter-l (2) Issuance of a full power or design capacity itcense to operate i

a nuclear power reactor, testing facility, or fuel reprocessing plant pursuant to Part 50 of this chapter; (3) Issuance of a permit to construct or a design capacity license to operate an isotopic e1richment plant pursuant to 50.22 of this l

chapter; i

(4) Issuance of a license to possess and use special nuclear material

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for processing and fuel fabrication, scrap recovery, or conversion of uranium hexafluoride pursuant to Part 70 of this chapter; (5) Issuance of a license to passes:: and use source material for i

uranium milling or production of uranium hexafluoride pursuant to Part 40 of this chapter; (6) Issuance of a license authorizing comerical radioactive waste disposal by land burial pursuant to Parts 30, 40, and/or 70 of this chapter;

Mr. Larry Molone. March 15,1980 (7) Conversion of a provisional operating license for a nuclear power reactor, testing facility or fuel reprocessing plant to a full power or design capacity license pursuant to Part 50 of this chapter where no final environmental impact statement has been previously prepared; (8) Issuance of a license to manufacture pursuant to Appendix M of Part 50 of this Chapter; (9) Amendments of Parts 30 and 40 of this chapter concerning the exemption from licensing and regulatory requirements of any equip-ment, device, comodity or other product containing byproduct material or source material; and (10) Any other action which the Comission determines is a major Comission action significantly affecting the quality of the human envi ronment. "

The Comission is presently in the process o'f modifying our Environmental Protection regulations to take into account, voluntarily, the regulations pror:ulgated by CEQ which became effective July 30, 1979. We have concluded that this action is not one of these actions requiring an environmental impact statement under current Comission regulations.

While our regulations do not require the preparation of an environmental impact statement, we are evaluating the environmental impact of the proposed action to determine whether an environmental impact statement should be prepared because of specific circumstances related to this particular action.

If it is determined that an environmental imact statement need not be prepared, a negative declaration and environmental igact appraisal will be prepared in accordance with Sections 51.7 and Sl.50(d) of our pro-cedures for environmental protection. We will coglete our review and issue the appropriate statement or appraisal prior to the Dresden decontamination.

The chemical decontamination of nuclear reactors is not an experimental process. Over the past twenty years, extensive experience has been obtained in the decontamination of reactor cogonents such as punps, valves, heat exchangers, and pipes. This experience has demonstrated that radioactive contamination can be removed from reactor components and significantly reduce the oci.upational radiation exposure to personnel who require access to these cogonents for purposes of repair, inspection or modification.

Such cog onents have been cleaned, inspected, and returned to service without any evidence of damage caused by decon-tamination.

In addition to the decontamination of reactor cogonents, at least eighteen reactor primary cooling systems or parts of those systems have been decontaminated in the United States since the early 1960's. Table i

1 identifies these and other major decontaminations that have taken place to date throughout the world l

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I Mr. Larry Molone March 15,1980 TABLE 1 Plutonium Recycle Test Reactor 1962 Shippingport PWR 1964 Plutonium Recycle Test Reactor 1965 Hanford, N Reactor 15 major decontam.

1964 to present SENA Power Plant Chooz, France 1967 Rheinsberg PWR Rheinsberg, Germany 1968 Douglas Point Canada 1970 NPD Canada 1973 Gentilly Canada 1973 Douglas Point Canada 1975 Dresden Unit 1 Test Loop using 1976 Dow NS-1 Solvent Peach Bottom Regenerative Heat 1977 Exchanger using DOW NS-1 In sunnary, the Dresden decontamination has been carefully planned to improve the safety of the reactor and reduce the exposure of plant personnel to radiation. The waste produced by the process is similar in type and quantity to the waste routinely produced at Dresden and its processing, transportation, and disposal will not cause any new hazards not previously evaluated and deemed acceptable.

Sincerely, I h&"

l Richard H. Vollmer, Acting Assistant Director for Systematic Evaluation Program Division of Operating Reactors

Enclosure:

Safety Evaluation L

UNITEE) STATES NUCt. EAR REGut.ATORY COMMIS310N W AsMIN GToN. o. c. 20s55 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AlTIEORI2ATION TO CHEMICALLY DECOSTAMINATE THE PRIMARY COOLING SYSTEM AT DRESDEN UNIT 1 CottiONWEALTH EDISON COMPANY DRESDEN NUCLEAR P0h~=R STATION UNIT 1 DDCET NO. 50-10 IhTRODUCTION By letters dated Dece=ber '16,1974, April 1,1975 and April 14, 1975, the Co==enwealth Edison Co=pany '(CECO) requested authori:ation to carry out a che=ical deconta=ina:icn of the interior surfaces of the Dresden Uni: 1 pri=a:y coolant syste=.

The purpose of the decontamination is to re=ove a deposition of activated corrosion produe:s which is tightly bonded to the pri=ary coolant syste=

piping and cc=ponents., The presence of the corresion products in the system results in high levels of radiation in adjacent areas and li=its access to these areas for the purpose of in-service inspection, routine maintenance and plan: =odifications.

CECO has tentatively scheduled the che=ical cleaning project to begin in Jaruary 1977 with an anticipated return to service scheduled for July 1977.

EVALUATION ne staff's review of CECO's proposed

• che=ical decontanination of-the interior surfaces of the Dresden Unit i pri=ary ' coolant system ha.s been compl eted.' The results of this' review are as follows:

1.

Environmental I= pact The, che..ical deconta=ination of the Dresden 1 pri=ary coolant syst~e=

will be perfor=ed entirely within a closed deconta=ination syste=.

The syste= has been designed so that no che=ical or radiological wastes will be released to the environ =en fro the deconta ination t

proc ess. All wastes generated in' the process will be either solidIYied.

licensed burial ground er reprocessed for reuse for offsite burial a: 2 onsite. The solid westes produced are similar in type and quantity to these hendled routinely 2: the site. Therefere, no adverse environ = ental i= pacts are anticipcted due to the deconta=ination.

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Materials Co=patibility l

The staff has reviewed the results of the material testing progra=

that has been carried ou in supper: of the proposed Dresden 1 1

The test progra= was organized to look decontamination program.

at corrosive effects during the deconta=ination process and possible~

residual effects during subsequent reactor operation.

Based upon our review of the resu'lts of the testing program ce=pleted to date, we have concluded that the tes: progras adequately evaluated those aseects of the =aterials ce=oatibility that we consider to be As a result cf our dis'cussions with CECO's consultant, i=portant.

Dr. Craig Cheng of Argonne Sa ional 1.aboratory, we find tha: the re=aining progra= will be conducted in a manner that will answer our results will be adequately, presently unresolved concerns and the tes interpreted and reported.

We conclude that upon the successful co=pletien of the testing progra=

described in the sub=i::als and with an adeo,uste surveillance and I can be inspection progrs=, the Dresden Nuclear Power Station Uni:

subjected to the described che=ical cleaning process without undue corrosion or other deleterious =aterials co=patibility effects that would adversely effect the integrity of the pri ary coolant syste=

and connec:ed syste:s.

A s=211 nu=ber of ite=5 of concen have not been resolved to the staff's full satisfaction a: this time. However, we conclude tha:

authori:stion to carry out the, che ical decontamination should be granted in anticipt: ion of the successful resolution of these open r

ite=5 in the near future.

~,he following open items are identified this time as recuiring */esolution to the staff's satisfaction:

2:

The materials test prog:ius will be ce=pleted and the test (a) results will be analyced and reviewed prior to the beginning of the elesning process.

Surveillance specimens in ad'dition to those now planned will be (b)-

deter =ined by mutual agreement with the applicant and a schedule for speci=en withdrawal will be stated.

A pre-service inspection prog s= for the pri=ary coolant boundarv (c) and safety related syste:s will be for=ulated and perfor:ed prio'r to re: urn to power.

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3.

Effluent Trea: ment Systems We have deter =ined that the effluent treatment system, if constructed as described in the CECO submittals, is capable of handling the ty~:es and quantities of effluents eixpected to be generated by the decon-Our review was limited to -he use of the syste:

tarination program.

for chemical deconta=ination only, and use of the system for any ce.e

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pu:7ose subsequent 'to that program =ust be reviewed prior to such u.s e.

r 4.

Radiological Safety We have fur: lier concluded tha: the radiological safety progra=.

described in the sub=ittals is adeo,uate to assure -dia: the health and safety of the public and the onsite personnel. will not be endangered by the Dresden 1 decontanination proj ec.

CONCLUSION We have conclided, based on the consider'.tiens discussed above, that:

(1) because :) e che:ical cleaning does not involve a significant increas e in the probability or consecuences of accidents previously censidered and does not involve a significan-decrease in a safety =argin, the cleani=g project.does not involve a significan: ha:ards considera: ion, (2) there is reasenable assurance tha: the health and safety of the public will n: :

be endangered by cperatien in the proposed =anner, and (3) such actitities will be conducted in cc:pliance with the Cc==ission's regulations and e.e issuance of this a end=en will not be inimical to the cc mon defense "a=d' security or to the heal-Js and' safety of the public.

Date:

December 9,1975 I

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To:

Robert Ahern, fluc l e a r Regulatory Commission, Washington, D.C.

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g, As a registered voter of Illinois, I wish to register my protest against

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the proposec decontamination of the Dresden tJuclear Plant, scheduled to take place in March.

I urge you to use your influence to assure that:

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1) An t:nvironmental Impact Statement be done prior to undertaking this g

risky procedure, and 2) Public hearings be held immediately addressing the safety f this as e ' experimental proces'.

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