ML19330A573
| ML19330A573 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/21/1980 |
| From: | Janecek R COMMONWEALTH EDISON CO. |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0686, RTR-NUREG-686 NUDOCS 8007280595 | |
| Download: ML19330A573 (8) | |
Text
___.._ _ _ _ _
Commonwealth Edison on? First National PI:73. Chicago. Ilhnots
' Address Reply to: Post Office Box 767 Chicago, filinois 60690 July 21, 1980 Director, Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Oresden Station Unit 1 Comments on Draft Environmental Statement for Primary System Chemical Decontamination Referenue (a):
D.
M.
Crutchfield letter to D.
L.
Peoples dated May 30, 1980
Dear Sir:
This letter is to provide the Commonwealth Edison Co.
Comments on the Draft Environmental Statement, NUREG-0686, for the Drescen 1 Primary System Chemical Decontamination whicn was transmitted by Reference (a).
The Final Environmental Statement should specifically adoress the factors identified in Sections 102 (2)(C) and 102(2)(E) of NEPA, 42 U.S.C.
$54332(2)(C) and 4322(2)(E).
The Draft Environmental Statement explicitly discusses only two of those factors:
environmental impact, Section 102(2)(C)(1); and alternatives, Section 102(2)(C)(iii), although the discussion of occupational exposure is probably responsive to Section 102(2)(C)(li), which calls for a discussion of any adverse environmental ef fects which cannot be avoided snould the proposal be implemented.
There is no explicit discussion in tne Draft Environmental Statement of "the relationship between local short-term uses of man's environment and the maintenance and ennancement of long-term productivity," as requireo by Section 102(2)(C)(iv).
While this prescription is somewhat difficult to apply to the facts at hand, it seems reasonable to say that the proposed decontamination does not significantly af fect the trade-off between short term and long term uses of the environment implicit in the decisions to build and operate the Dresden Unit One reactor, made more than twenty years ago.
Similarly, the shipment of radioactive wastes proouced by this project to licensea burial facilities does not affect the trade-off between short term and long term uses of the environment which was made when those sites were licensed.
This conclusion is supported by the discussion of radioactive waste disposal found in Section Coo 2 5
Y/
800728063365
1 Comntnwc:lth Edison Director, Division of Licensing July 21, 1980 Page 2 4.2.3.
and Appendix A o f the Draf t Environmental Statement.
Further, from Table 1 it can be seen that the dominant radioactive isotope to be buried will be 60Co, with a half-life of 5.3 years.
Essentially all of the radioactivity therefore will have decayed away in fifty years.
Section 102(2)(c)(v) directs federal agencies to consider
" irreversible and irretrievable commitments of resources."
For the
<cssan decontamination, these would be the money involved, the concrete and steel used to build the decontaminatin facility, tne NS-1 solvent, the Dow vinyl ester-styrene polymyer solidification system, the 55-gallon steel drums, and the burial space to be occupied.
Although Commonwealth Edison does not believe NEPA requires consideration of financial resources, see Consumers Power Company (Midland Plant, Units 1 and 2) ALAB c53, 7 NRC 155 (1978),
tne cost of tne decontamination project is ooviously very small comparea with the savings to De gaineo by carrying out the project, as described elsewhere in these comments.
Similarly there is no shortage of stainless steel or concrete in this country.
Both the NS-1 solvent and the Dow solidification polymer are petroleum-based products.
However, the amount of oil needed to make these products is small in aosolute terms ano in conmparison to the energy savings associatea nith continued reactor operation.
Finally, NEPA Section 102(2)(E) requires federal agencies to " study, cevelop and describe appropriate alternatives to recommended courses of action in any proposal which involves unresolveo conflicts concerning alternative uses of available resources."
The Draft Environmental Statement's discussion of alternatives is acequate, with the modifications suggested elsewhere in these comments.
Nevertheless it seems worth pointing out that this project coes not involve unresolved conflicts concerning alternative uses of available resourcese.
Dresden Unit One was built to operate and this project will contribute to that goal.
The burial facilities to which radioactive waste will be sent were licensed for that purpose.
And, of course, the NS-1 solvent and the Dow solidification system were developed for projects such as the Dresden decontamination.
Although Commonwealtn Edison does not question the authority of the NRC in the performance of a Environmental Statement for the chemical decontamination, we question the necessity of performing one for an action which has minor impact on the public and the environment, considering the cost involved.
The decision to perform an environmental statement at such a late date and the resulting delay in the chemical cleaning will add to Commonwealth Edison's cost to complete the project.
These costs will in turn be borne by Commonwealth Edison's customers.
As indicated in l
Comm:nwallth Edison Director, Division of Licensing
' July 21, 1980 Page 3 Comment 17 on page 3 of Attachment A, rescheduling activities and maintaining key personnel on the project for the period required to prepare the environmental-statement will cost $25,000 in June and July plus $110,000 per month thereafter.
An additional $90,000 will De required to redo earlier' testing to assure equipment operability and to train additional personnel.
Assuming an October 1, 1980 injection ~date at the earliest, the total cost of the project delay from June 1, 1980 is estimated to be $360,000.
Further delay will result in additional costs accruing at a rate of $110,000 per month.
In addition to the previous general comments, specific comments to various sections of the draf t statement are provided in Attachment A.
Very truly yours, Robert F. Janecek Nuclear Licensing Administrator Boiling water Reactors 5379A k
J
1 ATTACHMENT A 1)
Page 11, paragraph 3:
Though shutting the reactor down permanently would have prevented the continued increase of radiation levels in Dresden 1, it will not preclude the need to chemically clean if prompt decommissioning is desired.
Therefore, it is not necessarily an alternative to the proposed chemical cleaning p roj ec t.
2)
Page 2-2; Table 1:
The estimated activity of 3000 curies shown was based on an crud analysis taken in 1974.
Two significant events need to be considered which affect this estimate.
First, the unit remained in service to October 31, 1978, which has the effect of increasing the estimate slightly.
Second and more significant, is that the unit has been shutdown from October 31, 1978.
During this current two year outage, a significant reduction in curie inventory can be expected due to the short half lifes of the majority radionuclides present in the oxide layer.
As a result, it is expected that between 2000-3000 curies will be removed during the chemical cleaning.
The estimated curies per barrel of 2.5 Ci is a minimum figure.
The actual value may vary between 2.5 Ci and 7 Ci/ barrel based upon the total curies removed and the ability to evaporate excess water and maximize the volume of concentrated radwaste per barrel.
The amount of activity per drum can be regulated by changing the concentration and/or amount of radwaste placed in a barrel.
By minimizing the total radwaste volume, the total number of barrels required to be shipped can be reduced.
This will reduce the number of shipments and minimize the total transportation costs.
3)
Pages 2-6, 2-7, 2-8, 2-9, 2-10, 2-11, 4-8, 4-9, 4-10, 4-11, 5-1, 5-2, 5-3, 6-1 and 7-1 have not been numb ered.
4)
Page 3-1, paragraph 3:
Not all of the chemical cleaning f acility structure is Seismic Cat.
I.
Only the concrete floor and the walls designated as the " bathtub" and the walls and-ceiling surrounding the two radwaste hold tanks have been designed as Seismic Category I structures 5)
Page 3-1, paragraph 4:
It should be stated that the solidification process, including the solidification line equipment, the radwaste injection locations and the solidification line control room are all located within the chemical cleaning f acility which also contains the radwaste hold tanks.
6)
Page 4-5, paragraph 2, line 12; typo,".
. academy.
' 7 )-
Page 4-7, Secti on 4.2.2 B, p aragraph 2:
The first sentence should be deleted and replaced with the following:
" Continuous sampling and monitoring will be done.
Thus, any unplanned releases due to leaks and spills can be quickly detected and remedial steps taken."
8)
Page 4-7, Section 4.2.2.C, paragraph 1:
See Comment #2, listed above.
The 1200 fifty-five gallon drums mentioned is a maximum number of barrels expected.
This quantity is based on the unlikely event of requiring two cleaning cycles using a total of 225,000 gallons of solvent and an approximate evaporation r ati o of 7 :1.
This results in a maximum of 36,000 gallons of concentrated waste.
Approximately thirty (30) gallons of waste will be solidified per drum for a total of 1200 drums.
The actual number of drums of solidified radwaste is expected to be considerably less (400-600 drums) based on lower " crud" inventory and increased evaporation and waste to binder ratios.
9)
Page 4-8, Section 4.2.2 C, paragraph I continued, line three:
Replace ".
.has.
." with
.have.
- 10) Page 4-8 Section 4.2.2 C, paragraph I continued:
Add the following between lines three and four: "(The chemical cleaning of the test 1000 was a test of the solvent and cleaning process in a pilot system which was subjected to the same solvent conditions as anticipated for the full scale chemical cleaning)".
- 11) Page 4-8, Section 4.2.2 C, paragraph 2:
Typo:
. destructively.
- 12) Page 4-8, Section 4.2.2 C, paragraph 3:
Retain the first se' tence and delete the remainder that follows.
Replace the de'etions with the following: "For each drum of solidified waste, a rod containing a thermocouple will be brought in contact with the top surface of the solid material to measure its temperature to verify the occurrence of polymerization.
This same rod.tur making contact and measuring resistance to penetration of the solid mass, will verify the solidification.
Television cameras will allow for the observation of this activity at the top of the waste drum.
"The liquid waste to be solidified will be added to the solidification agent during mixing.
Any incomplete mixing will also likely be observable from above by using television as the solification agent and waste are not s
soluable and are of different colors and densities."
13 ) Page 4-9, Secti on 4.2.3, p aragraph 1, line 10:
Delete ".
.significant.
and add insignificant
__ 14 ) P age 4-10, p arag raph 1, line 9:
Change
. Amendment 1.
" to ".
. Amendments 01, 02, and 03.
- 15) Page 4-10, paragraph 3, line 12:
Delete ".
comprehensive strength testing.
" add ".
resistence to penetration testing.
- 16) Page 4-10, paragraph 2, lines 8 and 9:
Delete
. manuf acturer (DOW Chemical Company).
by the manufacturer." and add ".
the DOW Chemical Company, when wastes were solidified in accordance with the procedure specified by DOW."
- 17) P-ge 5-3, Section 5.2, paragraphs 1, 2, & 3:
See Comment #1, listed above.
The current estimated cost for replacement power in 1981 is
$100,000 per day.
The total estimated cost to purchase replacement power for Dresden I over the remaining 15 years of the unit's Operating License is approximately $470 million dollars.
The total estimated cost to CECO. for the chemical cleaning, including solvent research and development; solvent compatibility testing; construction of the chemical cleaning million dollars, not the 39.5 million dollars,y clean facility and the operational cost to chemicall is 37.5 listed.
The chemical cleaning had been scheduled for 6/1/80 The NRC's decision to require an Environmental Impact Statement (EIS) at such a late date and the resulting delay in the cleaning will add additional expenditures to the project.
These costs will in turn be borne by Commonwealth Edison's customers.
The need to retain core architect / engineering personnel; to re-establish priorities and reschedule project activities to provide most efficient use of time and personnel; and to provide support for the review and comment of the Environmental Imp act Statement and additional NRC questions will result in an added cost of $25,000 in June and July plus
$110,000 per month thereafter.
In addition, the delay will result in the need to obtain new personnel to replace experienced personnel, forced to be released'from the project due to other committments.
These new personnel will supplement core personnel and will need to be trained in the chemical cleaning system and process.
Also, all pre-operational testing completed earlier will need to be redone to assure the system is fully operational prior to cleaning.
These activities will cost an additional
$90,000.
i
. Assuming a 10/1/80 injection date at the earliest, the total cost of this delay is estimated to be $360,000.
- 18) Appendix A, Page 4, Ques. 3a, paragraph 3:
See Comment # 2, above.
- 19) Appendix A, Page 4, Ques. 36, paragraph 1, line 2:
Delete ".
. under the trade name of NAJVAR".
There is no such trade name.
- 20) Appendix A, Page 5, Ques. 3c, paragraph 1:
Delete the first sentence and replace with the following:
"The leach rate of DOW polymer under burial conditions has not been demonstrated, however, in arid disposal.
(Combine the new wording with the old second sentence)
- 21) Appendix A, Page 7, Ques. 4a:
Delete the last sentence of the response and replace with the following:
"10CFR71 and 73 pertains to the transportation of all radioactive material."
The discussion concerning high level waste presehted in the response to question 3 of the Illinois Safe Energy Alliances Sep temb er 20, 1979 Petition should be referenced here.
- 22) Appendix A, page 8, Ques. 4b, paragraph 2, lines 14 and 15:
Change ".
or the manuf acturer.
by the manufacturer ".
.to or the 00W Chemical Company when the wastes were solidified in accordance with the procedure specified by DOW."
- 23) Appendix A, ISEA, page 2, Response 2, Paragraph 3:
Typo ".
. program.
- 24) Appendix A, ISEA, page 3, Question 3:
In the last sentence of the question, Mr. Lange was mis-quoted.
He never stated that 'Transuranics of a value of greater than 10 nanocuries/ gram will remain at the Dresden site forever.
25)-Appendix A, ISEA, page 5, Response 4, paragraph 2:
Typo ".
. commercial.
1
- 26) Appendix A, ISEA, page 8, Ques. 5, line 3 Typo ".
is.
- 27) Appendix A, ISEA, Page 8, Response 5, Paragraph 5:
Delete ".
. under the trade name NAJVAR."
- 28) Appendix A, ISEA, page 8, Ques. 6, line 1:
Change ".
. the.
to ".
and.
. 29)' Appendix A, ISEA, page 9, Response 6, Paragraph 1, line 5:
Change ".
individual
." to ".
individual's age.
- 30) Appendix A, ISEA, page 9, response 6, Paragraph 2:
Typo ".
industrial
- 31) In Section 4.2.1.B emphasis is placed on the man-rem estimated.
The figures are misleading as stated.
The original estimate did not include items we later felt necessary to include in the dose accounting program of the chemical cleaning.
How well we did in planning, projecting radiation jobs is not accurately stated.
The following table will explain:
Original Estiaate for Construction 250-500 man-rem Total Expended to Date (6-30-80) 290 Dose incurred but not estimated in original scope:
a.
Component Inspection 54 b.
Sphere Cleanup 22 c.
CRD Removal 4
d.
B-Loop Bypass 2
e.
Gamma Scan
_2 Total =
84 man-rem expended but not planned for.
290 Total man-rem expended 84 Unplanned man-rem
~706 Man-rem incurred that can be attributed to the original estimated jobs.
This shows that by strictly complying with the ALARA principles, the expended man-r?ms of 290 which included 84 man-rems expended on jobs not originally planned for is well within the 250-500 man-rems O timated for chemical cleaning.
_ - _ _ _ _