ML19326D997
| ML19326D997 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/23/1980 |
| From: | Gogol E CITIZENS AGAINST NUCLEAR POWER |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0686, RTR-NUREG-686 NUDOCS 8007250369 | |
| Download: ML19326D997 (11) | |
Text
..
er' Citizens Against Nuclear Power P.O. Box 6625, Chicago, IL 60680 n
Office: 407 S.
Dearborn,
Rm. 930
/
Telephones: (312) 472-2492, 764-5011, or 786-9041 s,WN 3
9'W j i July 23, 1980 Director, Division of Licensing U.S. NRC Washington DC 20555 RE: Docket 'to 50-10
Dear Director:
Contained herein is CANP's "Conrents" on flVREG-0636, the draft EIS done for the proposed chenical decrudding of the Dresden One reactor.
1 It has been brought to ny attention this norning as we nrecared to nail this docunent to you, that the date by which all connents on NUREG-0686 were to have been received to ensure that thev would be taken into consideration durino the oreparation of the final EIS, was July 21, 1980.
CANP was ignorant of this requirenent, as the copy of NU9,EG-0606 which we were sent by Jan Strasna of the Recion III NRC office, was blank where the date was to have been printed (the page on which the " Abstract" apoears).
Since you should receive this document only 3 days after the July 21 deadline, and since the copy of MUREG-0636 we received was silent on the exact deadline, CAtlP stronqly reauests that you do overything in your power to ensure that the enclosed docunent is indeed taken into consideration in the process of precaring the final EIS.
For a nuclear-free future, 3
Edward Gogol, Coordinator
)
9 Too "h\\
80072503df
CelliiENTS on the DRAFT ENVIRONMENTAL STATE' TENT REGARDING THE PROPOSED REMOVAL OF RADIOACTIVE " CRUD" FROM THE INTERIOR OF THE DRESDEtl ONE REACTOR l
00CKET NO. 50-10 July 21, 1980 l
CITIZENS AGAINST NUCLEAR PO'/ER 407 S.
Dearborn,
Rn. 930 Chicago IL 60605 312/786-9041 By:
Edward Gogol,/ Coordinator F
i 4
4
.n
4
The docunent NUREG-0686, entitled "Draf t Environnental State-ment related to Prinary Coolino Systen Chenical Decontanination at Dresden Nuclear Power Station Unit No.
1",
is extrenely inadeouate, wrong in several inportant respects, and unsubstantiated in the najority of its conclusions.
As such, it fails to adequatelv fulfill the U.S. Nuclear Reculatory Connission's statutory resoonsibilities under both the National Environmental Policy Act and the NRC's own legislative mandate to protect the public health and safety.
I.
Concerninn how nuch radioactivity is donosited on the interior surfaces of the reactnr, anc of wili c a nuclides tne radioactivity is conoosed Any evaluation of the public health and environmental con-sequences of the proposed Dresden One "decrudding" nust benin with an estinate of hcw much insoluble radioactivity there is on the surfaces interior to the prinary coolant boundary, of what nuclides this naterial is concosed, and in what nroportions.
NUREG-0636 provides such "information" as Table 1 on oage 2-2.
However, no information whatsoever is niven concerninc the neans of arrivinc at this "estinate".
Until :ne full ce: ails of now :nis "estinate" was nade are nace public, there will be no way of deterninino its correctness.
Table 1 by itself is sorely lacking since it provides no information on the conoosition of what it terns " nixed fission products".
Since it is generally assuned that the nore radiotoxic and environnentally nobile fission creducts (such as isotopes of strontiun and cesiun) are present in " nixed fission products", failure to provide any infornation on the prooortions of such nuclides in
" mixed fission products" is a najor flaw.
The main body of NUREG-0686 is totally lacking in information concernino the cresence of transuranic radionuclides in the " crud".
This constitutes a najor flaw.
This cuestion is only addressed in i
the response to question 4a of Ms. Kav Drey's oetition dated March 19, 1979, in which it is stated that "no fissile naterial is exoected in the decontanination waste"; and in the response to Guestion 3 of the Illinois Safe Enercy Alliance's (ISEA's) Sept. 20, 1979, cetition, in which it is stated that "the cresence of transuranic elenents in levels in excess of 10 nanocuries oer oran is definitelv not expected based upon reasurenents of the transuranic content of the corrcsion product filn observed on artif acts and sanoles renoved from the Dresden Unit No. 1 primary systen and other boiling water reactors."
The actual results of such tests are nowhere af ven in NUREG-0686; indeed, the docunents in which such tests are reported are not even attributed' No exolanation is given for the 10 nCi/c fioure, although NUREG-0686 seems to inply that as long as the concentrction of transuranics renains below that figure, transuranics nay be dismissed as insignificant.
No justification is given for this inclication.
Furthermore, no breakdown by radionuclide is oiven for the uo to 10 nCi/o figure which NUREG-0636 seens to inply nay be expected in the radioactive waste.
And if up to 10 nCi/g of transuranics may be present in the decontanination waste, there is simply no justificac:nn for not listino the total amount of transuranics exDected to be presen' in Table 1 of the nain body of NUREG-0686.
i
-2 The presence of transuranics is not an idle question, since it is well known that durino the first few years of operation of Dresden One, "the world's first orivately financed, full-scale, connerci al, nuclear power reactor," there were siqnificant problens with leaking fuel elenents.
Therefore, it is quite oossible that insoluble plutoniun oxide is a conponent of the radioactive " crud".
II.
Concernino '.fhether the Radioactive !laste oroduced by the "Decruddino" Will Be successfuiiv solidified anc Packaned NUREG-0686 alleges on p. 3-1 that "the concentrated waste solution will be solidified in 55-qallon druns usino a crocess developed by the Dow Chenical Company for the solidification cf low-level radioactive wastes.
This solidification crocess has been tested on the NS-1 solvent and produced a solid waste forn that contained no free liquids.
The waste solidification procedures include a quality control orocess test on each barrel of waste to provide additional assurance that the licuid waste has been crocerly solidified."
Likewise, on the unnunbered pane followinc cane 4-7 (which I shall denote as
- 3. 4-8) NUREG-0686 states that " solidification tests with spent radioactive decontanination solvent obtained fron the actaal decontamination of a Dresden Unit I test loop has (sic) been perforned.
The decontamination solvent was then solidified using the Dow systen.
Samples of the solidified waste indicated no free-standinn licuid."
This question is further addressed in the too paraqraph of the second following page (designated herein as o. 4-10), which discusses "further assurances that the product will not contain free standing liquid."
The arounents given in the above-quote passages do not substan-tiate NUREG-0686's conclusion that the decontanination waste will be successfully solidified.
Furthernore, what " facts" are civen to support this conclusion are not documented.
Specifically:
The passage on p.
3-1 nerely states that the " solidification process has been tested on the NS-1 solvent and produced a solid waste forn that contained no free liquids."
No details whatsoever are niven on these tests, or on the "ouality control process" referred to in the followino sentence.
No docunent which describes these " tests" and "cuality control process" is referred to, let clone attributed.
The oassace on
- p. 4-8 nerely states that samples of the waste nroduced by flushinq the Dresden 1 test 1000 with Dow solvent NS-1 " indicated no free standino liquid."
No details are given on this exoeriment, nor is any docunent which describes this experiment referred to or attributed. Escecially incertant,
and concletely missing are details on the nunber of such "sanoles" taken and the crocess involved; without such information, no assessment of the adecuacy of such ramples to detect unsolidified material can be nade.
Furthernore, the use of the terns " free liquid" and " free standing liquid", without any further defini-tion, is troublinn: would a sponge saturated with water be considered by the NRC to contain no " free licuid"?
t 5
3 (This persistent practice of nakinn undocunented, unsubstantiated clains is extrenely poor science.
And the NRC staff's seenino 6
inability to abide by the rules of grannar, not to nention the lack of a consistent paqe nunberinq systen, would likely result in MllREG-0686's failure to receive a passing grade from even a high-school English teacher')
The paragraoh at the top of p. 4-10 likewise gives no information on the Brookhaven laboratory tests, and no docunent in which these tests are reported is attributed.
The Dow Topical Report DNS-RSS-001-P is not available to the public, and hence NRC's " reference" to it is of no value in assessinq whether or not the "systen design and cuality control checks" will actually orovide "further assurances that the final product will not contain free standinn licuid".
The continued use of the tern " free standino licuid" is troublinc: either the stuff is solid cr it isn't.
The nere referral to "in process sample verification durino the production runs" offers no assurances that such "sanale verification" will be adect:te to detect unsolidified naterial.
And " full scale cualification tests usino sinulated wastes" are not the real thina; the be-havior of the decontanination waste which actually contains a large quantity of toxic radionuclides nay be entirely dif ferent from that of "sinulated wastes."
This question is discussed aoain in Accendix A.
In NRC's response to Question 3 of 'ts. Drey's petition, it is alleced,
" Radioactive corrosion products, bonded with the Dow Chenical solvent, have been tested to renain free of water after beina solidi-fied by the Dow Chenical colyner nrocess since 1974."
The resnonse to Question 3b continues that "the first solidified sanple of proto-type test has renained free of liquid since 1974 when the test was made... Tests have been performed to denonstrate that the stability of the solid polyrer will not substantially alter for over 50 years",
such tests including " accelerated acino, biolocical decradation, radiation dearadation and tencerature cyclino."
The sane clains are l
nade in the response to Question 5 in the ISEA petition.
1 Nowhere are any details civen concerninq any such " tests", nor is any document which describes such " tests" attributed.
It should be obvious that one sanole of solidified vaste remainino solid since 1974 (approximately 6 years) is hardly adequate to denonstrate that the larae quantity of waste which w'.ll result fron the proposed Oresden "decrudding" will renain solid for even that lonn.
And it is extremely unscientific to assert that any " tests" can denonstrate that "the stability of the solid polyner will not substantially alter for over 50 year. ': the only way any test can demonstrate such a thing is if such test were to last 50 years.
In any event, until the exact chemical forcula of Dow solven? MS-1 and the exact chenistry of the solidification process and final oroduct are disclosed, any statenent~ that "the stability of the solid colyner wili act substan-tially alter" will be neaningless, since without such infornation there is no way to determine what chenical reactions the " solidified" waste will be subject to.
J
.,4 III.
Concerninn whether a niace will be #cund to die 90se of the barrels of decontanina:1on vaste, and sne:9er :ne caelan:-nound radionuclides in tne decontanination vaste wili not ieacn out and become environnentaliv nobile NUREG-0686 alleges on
- p. 3-1 that "all decontanination waste will be shipoed to a connercial low level waste disposal site loca.ted at Hanford, Washinoton or Beatty, Nevada." This clain is repeated on the un-nunbered oace on which Section 4.2.3 becins.
The answer to Ques tion 2 o f Ms. Drey's peti tion s ta'tes, "Connonweal th Edison...
has agreed to disoose of the Dresden 1 solidified waste at either Beatty, Nevada or Hanford, '!ashington connercial low level waste burial sites."
The answer to Question 3 of the ISEA petition alleges that "the presence of transuranic elenents in excess of 10 nanocuries per gran is definitely not expected", but that if such cresence is detected, "the waste will not remain at Dresden " forever".
The waste would be discosed of at a waste depository operated by the U.S. Govern-nent which is authorized to dispose of transuranic waste."
As recently as less than one year ago, there have been eoisodes which have been widely described as " crises in low-level nuclear waste managenent,' durinq which no connercial " low-level" nuclear waste burial crounds were accepting shionents of such waste, esoecially fron Connonwealth Edison.
No assurances whatsoever are civen in NUREG-0636 that this condition will not recur.
NUREG-0686 offers no guarantees that the decontanination vaste produced by the 3resden One "decrudding" will be acceoted for burial by either the Beatty or Hanford connercial nuclear waste discosal sites.
In the absence of such assurances and ouarantees, it is entirely possible that the barrels of decontanination vaste will renain at Dresden for an indefinite future tire oeriod, or that it will be buried at a site with unfavorable geological and hydrolonical characteristics.
The exact same conclusion can be nade concerninc the bald, unsubstantiated assertion that if the waste turns out to contain transuranics in excess of 10 nCi/c it would be "disoosed of" at a U.S.
government operated transuranic waste " depository".
'lha t deoosi tory?
Is there anything anywhere to quarantee that such will be the case?
If there is, it cannot be found in auREG-0686.
Regardless of the uitinate fate of the barrels of decontanination waste, there is nothing in NUREG-0636 to indicate that in the cresence of water (cuite a likelihood if the waste is not discosed of at Beatty or Hanford) the chelant-bound radionuclides will not leach out and becone environnentally nobile.
Indeed, in the answer to Questien 2 of Ms. Drey's peti tion, we read tha t, "Ue do not have field or laboratory tests which quantify the migration potential of radionuclides associated with Dow solvent, assuning that sone escaces fron solidified waste and into the soils of the disposal site."
And in the resconse to Question 3c we read that, "We do not know the leach rate of Dow polymer under burial conditions...There is not as yet any test which i
can sinulate leaching under burial conditions."
i This question of whether the chelant-bound radionuclides in the "decrudding" waste will becone environnentally nobi-le is so crucial l
to any assessnent of the environnental inpact of the prooosed "decrudding", that there can be no justification for anything less than a full disclosure of the chenical fornulae of all conoonents of the Dow NS-1 solvent and the full chenical details of the solidification process.
Ilithout such disclosure, any attenpt to determine the potential for the chelant-bound radionuclides to becone environnentally nobile, is critically handicapoed.
The NRC alle7es that any such disclosure, full or otherwise, cannot be done because the Dow solvent and solidification process are
" proprietary."
If that is indeed the reason, then the Dow Chemical Co. should natent their solvent and solidification crocess.
This would allow full orotection nf 9ow's crocrietary rights while af fordina vastly greater crotection of the public health and safety.
IV.
Concerninc whether the croc,ss will result in anv radionuclides dissolvec by :ne :ecentamina: ion solvett beinq reieasec to envirenrent around Drescen NUREG-06S6 states that the decontanination solvent and tirst wash will be eva; orated and that the resultino 130,000 nailons of distillate fren evaporator "will be sanpled and sent to the existino plant holdup systen or will be polished throuch the denineralizer before baing stored for clant reuse."
The main body of NUREG-0606 contains no further information on this.
However, in the answer to Question 3d of '?s. Drey's petition it is alleced that, "At ' ie evaporation tencerature, the chelating agent nortion of the solvent is not volatile except for annonia and organic compound conconents.
Carryover of enelated radionuclides antrained in the vapor nist is an insigificantly snail fraction.
This carryover will be further reduced as the spent solvent is further processed by a nixed-bed denineralizer which has been tested to be effective in renoving chelated radionuclides."
The answer to Question Sa. further alleces that, "the anount of che-lating agent in the second or third rinse should be nininal.
The first rinse will be crocessed throuch the evaporator.
No significant amount of chelatire agent should be present in the distillate.
Additional treatnent by denineralizer of the distillate and/or sub-sequent rinses nay be perforned if necessary.
The licensee's tests indicate that the denineralizer is effective in renovino radioactive
-1 metals bonded by the chelating agent."
And in the answer to Questien 5b we read that, "no licuid waste, including water fron all the rinses, from the decontamination operation will be discharqed into the river."
j NUREG-0686 conta'ns no justification whatever for its assertion that the carryever of chelant-bound radionuclides durina the evaporation step is " insignificant", nor does it contain any definition of just i
how nuch carryover would not be considered " insignificant".
No specific tests are mentioned to justify any such conclusion, nor is any document which describes such tests attributed.
Likewise, no docunent is attributeo which describes the tests perforned by Connonwealth Edison which are alleged to show that the denineralizer is effective at renoving chelant-bound radioactivity from the distillate.
In the absence of any such documentation, there is no reason not to excect that substantial radioactivity from the decontanination will end up in water which is to be used in the ooeration of Dresden One.
If so, a fraction of such radioactivity will be released to the Illinois River throuch the.<ane nechanisns as result in Dresden One'releasino any radioactivity to the river.
In any event, there is no justifica-tion in NUREG-0636 for the clain that the Sresden Cne "decruddinc" will not result in an increased load of radiation to the Illinois River.
V.
Concernino tlSether the decontanination nrocess will weaken or corroce critical giant co-,onents, leadinc to increasea risk cf dannerous nuciee.r accidents On the unnumbered paqe on which Section 5.3 is orinted, NUREG-0686 states that the NRC staff has concluded that, "the use of NS-1 solvent will not result in excessive corrosion of the naterials of construction."
No further discussion of this can be found in the main body of 'lUREG-0606.
However in the response to Question 1 of the ISEA peti tion, it is alleged that:
~
"All primary cooling systen materials that will be in contact with NS-1 have been tested extensively to assure that the intecrity of the prinary cooling systen will not be degraded by the cleanino.
The corrosion research procran covered several thousand individual corrosion tests of all the basic Dresden Unit No. 1 prinary coolinc systen naterials that will be exoosed to the solvent under conditions of tine and tencerature exceedinc those procosed for the actual decon-tanination.
" Based on the staff's review of the tests carried out by CECO, we have concluded that the olant naterials will not be sicni fi-cantly danaaed by the decontaninatien solution...!n addition, pilot-scale orojects utilizing 'IS-1...have orovided assurance that full-scale coerations utilizinq NS-1 will produce similar results to the laboratory scale experiments.
"The inspection progran that will be carried out by CECO af ter the cleaninn will be used to determine whe':her the decontanination has caused the structural integrity of the prinary cooling systen to be degraded."
Nowhere in NUREG-0686 are the docuneats attributed which describe these various laboratory and pilot-scale tests and their specific results.
Thus there is no way to determine if these tests actually yielded the results clained.
Similarly, no documents are attributed which describe in depth Commonwealth Edison's proposed post-cleanino inspection procran, and i
NUREG-0686 is silent on this, t!ithout knowino the details of this program, it is inpossible to deternine the efficacy of the procosed inspection croqran to detect primary coolinc systen structural degradation.
One especially incortant thina which NUREG-0636 does not nake clear is the extent to which radiocraphy will be used as cart of the cost.cleanino insoection procran.
Uithout radionraphy, it is doubtful that prinary coolino systen structural decradation can be detected, since such degradation will occur from the inside out.
This is not an uninportant question.
Undetected dearadation of the structural intecrity of the primary coolino systen can easily lead to severe accidents when and if the reactor is put back into operation, up to and includina total neltdowns of the reactor core.
It is therefore extrenely unsettlina to find NUREG-0686 so deficient in this resoect.
The incertance of th'is question is yet another reason why full disclosure of the chenical fornulae of the cerconents of Dow solvent MS-1 is essential.
Uithout such disclosure there will be no way to tell whether the clained results of the various corrosinn tests are plausible.
VI.
Concer'ninn whether the cronosed "decruddinn" crocess is exoerinental The resconse to Question 3a of Ms. Drey's petition states that "The Dresden decontanination is not an exoerinent, 1t r2 presents the apolication of a proven nethod of decontanination that has been specifically developed and tested before beinq used on the Dresden Unit 1 primary cooling systen."
It is difficult to see how the prooosed Dresden "decrudding" cannot be considered an experinent.
True, a variety of laboratory and pilot-scale tests nay have been carried out; however, this is no guarantee that the results obtained under full-scale conditions will not be quite different.
Dresden One is the first laroe t
connercial power reactor to be "decrudded"; thus the "detrudding" can only be considered t an exoeriment to see what will hannen when such a reactor is "decrudded" usinc Dow solvent NS-1.
The phcbic reluctance of the parties involved (the NRC, CECO, and Dow) to disclose the chenical fornulae of the censonents of the solvent
~~
can only fuel the public fear that it is we, the public, who are beinc experinented on.
And the NRC admits that, "Ue do not know the leach rate of Dow polyner under burial conditions...There is not as yet any test which can sinulate leachina under burial conditions."
VII.
Concernino whether the occucational radiation exoosure incurred by the "decruddino" nas been and will be as low as clairec NUREG-0686 alleces an c. 4-3 that "with over 90% of the pre-decontanination installation completed, the occucational exnosure expended was kept to about 200 man-ram," and on c. 4-4 that "the
{
estinated total occucational dose for the entire decontanination procedure is about 300 nan-ren."
Nowhere in NUREG-0686 is the specific neaas by which these estimates have been arrived at described, nor are any documents attributed whic+.er'ain any such detailed estinates.
VIII.
Concerni*. wnether all alternatives have been considered, and the bes: al ternative cnosen Section V of NUP.EG-0636 clearly has not considered all possible alternativ_s.
One alternative nc t considered is t'o carry out the proposed decontanination, but only af ter a delay of sone years fron now,
8-for exanole 5 to 10 years.
This would have the advantaae that the total quantity of radioactivity to be removed would be dranatically decreased, especially if the conponents o' the radioactivity in the " crud" are as described in Table 1.
NUREG-0686 has not denonstrated that both the above alternative and the alternative of shuttinq the reactor down pernanently are inferior to the chosen " chemical decontamination usinq NS-1" alter-native.
The only argunent advanced for chenical decantanination as opposed to keecine the reactor shut either tenpararily or pernanently is an'econonic one: viz., the need to ourchase replacerent cower.
This argunent is not valid because Connonwealth Edison has a large excess of generatino capacity above and beyond needed reserve.
Thus keepine Dresden One shut will have no effect on Con Ed's need to purchase power.
A pernanent or tenoorary "notnballing" of Dresden One would result in drastically lower occupational radiation exposure than would any course of action which involves re-openinc the reactor.
Thus it cannot be argued that the chenical
- decrudding" of Dresden 1
One will result in keeping occupational radiatien exnosures ALARA, l
since a pernanent or tennorary shutdown of Dresden One is a quite
)
reasonable alternative.
When the economic effects of accidents that nay result ' rom structural decradation of Dresden One's prinary coolino systen, or of human disease and death that nay result fron a large cuantity of chelant-bound radioactivity beconinq environner. tally nobile in the Dresden vicinity, are considered, it becones clear that if the I
NRC allows the prooosad "decruddinq" to go forward, the costs of doing the "decrudding" are likely to be nuch higher than the true costs of shutting down the Dresden Cne reactor pernanently.
f.onclusion This docunent has denonstrated that there is no justification whatever contained in NUREG-0686 for that docunent's conclusion that there will be no significant environnental inpact associated with the proposed "decruddino" of Dresden One and that the chenical "decrudding" using solvent US-1 is the best possible alternative.
The ootentially extrene hazard associated with the crocosed "decruddinc" and the exoerimental nature of the operation necessitate the fullest possible oublic disclosure of all details of the procosed "decrudding".
Especially incortant for disclosure are the chemical fornulae of the NS-1 solvent and the chemical details of the solidi-fication process.
Without this infornation it is inpossible to properly assess the true environnental inpact of the prooosed "decrudding".
There can be no justification for anything less than such full disclosure.
The potentially extrene hazard associated with the prooosed "decrudding" and the exnerinental nature of the oneration likewise necessitate the renoval of the ultinate decision-making power 4
. ~. -...
.g.
concerning the proposed "decruddinc" from the NRC. staff.
The public health and safety can only benefit from the aopointnent of an Atomic Safety and Licensina Board to-nake this decision, and fron full public hearings and.the adversary process that will thereby i,
result.
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