ML19330B492

Submits Questions & Comments on Des Re Primary Cooling Sys Chemical Decontamination Which Would Enable Util to Immediately Shut Down & Decommission Plant

ML19330B492
Person / Time
Site:	Dresden
Issue date:	07/19/1980
From:	Frey D SASSAFRAS AUDUBON SOCIETY
To:	Office of Nuclear Reactor Regulation
References
RTR-NUREG-0686, RTR-NUREG-686 16868, NUDOCS 8008040087
Download: ML19330B492 (3)

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- The SASSAFRAS AUDUBON SOCIETY

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July 19, 1980 e

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To the Director of the Division of Licensing s

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mlated to PRLIA?Ji C00LI:?G 5'IS"'EM CEZ'!ICAL DECO::TAMI::ATIO:I x

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..T ORESDE ! !!UCLEAR P'"<!ZR STAT:0:I U::IT ::0.1, CC:t!CLT.ALTH (9

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a The chemical deconta 4.ation of Dresden 1 is vieued as a hignly profitable venture by C =nonwea'th Idison, representi.g 1300 mil' ion dollars of power over the remain-ing 15 fearo that the Drasden licence vou'd be

1. " *S ct. To the ::RC it seems an a---a " a

• oppo:-tu.ity jio on re that excessively " hot" reactors can be retur ed to service. As noted on page - - fol'oving Table 3, a project goal is to " Develop and prove techniques usable on other reactors."

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.a The '.!RO, in their response to question 3, pa;;e 4, Arpendix A, asserts that "The Dresden decontn-4".ation is not an experiment, it represents the application of a provon method of deconta 4".ation that has been specifically developed and tested

'Taile the use of before being used on the Dresden Unit 1 pri.ar/ cooling system."

IS-1 may be a proven =ethod of deconta:ination on a laboratory scale, the results of a full-scale flushing out of % s of pri=ary cooling syste may not be one and the sa e thing, and the recults unknown until the flushing-out and post-cleanirg surteillance progran have been completed. In this sense it is an exceriment. Par-ticularly with Dmsden 1 where some inservice inspection requirements were waived for a considerable period of tire.

Can it be said with certainty that one flushing (of approximately 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) will do the job?

Or how long occupational exposure levels may be reduced to " acceptable" levels?

Or that the integrity of the primary cooling system will not be affected?

The liRC, in their response to Question 6, page 15, Appendix A, says that "there is no anticipated acceleration in the buildup of crud" after the cleaning, but notes in the sa:e response that "in the future it is quite possible that, following the strong decontamination solution the utility may elect to use a weaker but more fre-quent decontamination process on line that is curmntly being develoced under.~.)RI sponsorship by Battelle !!orthwest." This statement is indicative of the uncertain-ties surrounding the Dmeden 1 decontn ".ation experiment.

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n., v.ss. <.Gw. r.a, C.-,Lm. S nt s Chelates nave the capacity to fora strong comple:03s "ith rado"~ ' ' ~s and to reduce, carhedly, the adsorption capacity of soil and rock for radionuclides; to accelerate acucous' transport of radionuclides in the ground; and an extre ely persistent in the mtural entiron=ent. The aigration potential of ~ chelated radionuclides may be

' decnased when placed in a solid waste matrix and disposed of in a ser.i-a:ii dis-posal site but the fact remains that it is a dangenus if not unaccentab's practice

' to bury radioactive wastes' bound to chelates that are not biodeg-adabla.

TH3 STABILITY OF 3 Err?, I:ELDA r;D/03 HA:UC2D, JA3MI::GTO:I?

Has either Beatty, :!evada, or Hanford, '.lashington accepted responsibility for the disposal of the Dresden 1 decontn+:ation wastes?

'.hy was this not finaZ:ed before issuance of the PES?

It is essential to know the length of tire that radicaccite vastes ass:ciated tith the Omsden decon:W nation ust be isclated f== the actinnnent in re=c af the stability of the vaste dispcsal site. 21 e 223 states

.11: about 95.' of the radio-activity excected will be in the forn of coba~t isotoges ti:h Scba^:-60 rith a half life of 5.3 years the isotope of greatest concern.

The question about the possibility of transuranics was ansvend on page 3, appendix A, to the effect that Com Zd was co=nitted to neasuremen; of then if they are present.

'e have heard, however, that Hickel-63 with a half Zfe f 32 ;, ears.ay be present in the oxide layer and this is not =entioned in the 323.

_a it excocted, and if so j

' to what extent?

There is a question'of ;e lagic instabi'ity a; bc:h :'..e Zeat:-l r. nd :*anford sites.

,L Hanford is about 120 ras fron 7.t. St. Helans cri considenble covecent of the earth's crust"37idenced in earthquakes and volcanic e=ptions.

"'he Hanford site

, has also been subject to considerable disturbance fms the practice of " water cound-

.ing which added to the problem of the escape" of large quantities of liquid radio-n active wastes into the ground, particularly since Flutonium had been comple:md with a wetting agent in some instances which promotes its covement through the soil.

Mr. Clave Arderson, testifying befom the House Subco: ittee on Erctiron=ent, Inergy, and Xatural Resources on nuclear vaste disposal (1777) said that over 2000 wells had been drilled with some budgeted to deter =ine uhere the radioactivity that had

escaced to ground had' migrated in the gnound water. The drainage channels flow to-ward the Columbia River.

Dresden'l wastes am to be solidified but they can be affected by noisture and it is not difficult to i=agine scenarios where chelated wastes night be vulnerable to dissemination while still toxic.

2eatty, :Tevada is near a seismically active area, and on'y 50 W s from the Cevada

~ tomic bomb testing. grounds. The 3eatty, :'evada site has had numerous problems with a

Governor List supposedly fed up with the dangers of radioactive vastes, the burden of taking care of other people's problems, and the lack of adequate in-spection by.the Federal Govern =ent.

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.. u Dresden 1 was not designed to limit'T"3Ecupational exposure of workers

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-te _what is.tened ALaA, a.pfor required inservice inspections as radiation levels i

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rose and the plant aged. It is a peor candidate for a decontamination e:gerbent with the many uncertainties surrourding its c2aan-up.

The OES does' not addass sufficiemly alternatives to the decontamination which would emblo Cos Ed to shutdown and deco =nission Dresden 1 i=nediately.

'Je ask that this be done in the ?inal SIS rith a discussion of Con Ed facilities, both nuclear and others (coal,' cil,. natural gas etc) and how they can be used effectively fg com-pensate fo'.the decommissioning of Dmaden 1.

"atural gas seems to offer exceptional

- low-risk clternative to mc3aar power at this time and far into the future whih soft erargy alternatives are being developed.

Our Society would appreciate a copy of the Final ZIS w'ran issued.~

Tours sincealy,,

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->p.w Mrs. David G. ?my Erargy Folicy Committee, Sassafras Audubon Society 2625 S. Smith Road Bloo=ington, Indiana 47401 o

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