ML19330B544
| ML19330B544 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/18/1980 |
| From: | Scott W ILLINOIS, STATE OF |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0686, RTR-NUREG-686 NUDOCS 8008050010 | |
| Download: ML19330B544 (5) | |
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WILLIAM J. scott ATTORNEY GENERAL
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STATE OF ILLINots TELEPHONE 160 NOR*
- LA S ALLE STREET 79 3 + 3 500 CHICAGO 60601 July 18, 1980 U.S. Nuclear Regulatory Commission Director, Division of Licensing Washington, D.C.
20555 Re:
Docket No. 50-10 CO:CIENTS OF THE STATE OF ILLINOIS ON DRAFT ENVIRONMENTAL STATEMENT, NUREG-0686 The PEOPLE OF THE STATE OF ILLINOIS, by WILLIAM J.
SCOTT, _ Attorney General of the State of Illinois, submit the following comments on the Draft Environmental Statement relating to the Primary Cooling System Chemical Decontamination at Dresden Nuclear Power Station, Unit No.
1.
I.
The Selection of a Solvent The formation of the NS-1 solvent is stated to be proprietary and thus is not disclosed.
This prevents the reader from making even a cursory evaluation of the possible side effects, residue, vapors, corrosive nature of the solvent, etc.
In addition, the planned operating condition for the NS-1 salvent (100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> at l
250*F) is not justified as being optimum and is not directly com-pared with other solvents.
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.The selection process used by Commonwealth Edison used generalized criteria (e. a., " slow corrosion" and " greatest possible reduction in radiation levels") rather than specific values, so it is difficult to determine if any solvent really met their absoluts requirements.
The choice of NS-1 may be justified but the Draft Environmental Statement does not indicate why.
One reason is that NS-1 is not listed in Tables 4 and 5, so its effectiveness compared to the others cannot be readily discerned by the reader.
Thus, the Draft Environmental Statement does not justify the use of NS-1 since its selection process, formulation and capabilities are not adequately revealed in the document.
II.
Predictions and Criteria The Environmental Statement fails to document the specific criteria for the decontamination process and results.
For example, what is considered an acceptable corrosion rate; I
What is the solvent selection criteria for radiation reduction; What final radiation levels are required for safe operation and inspection?
If the processes are as predictable and proven as the Applicant believes, then it should be possible to make some reasonable predictions for inclusion in the decision base of the Environmental Statement.
What is the effect on the conclusion reached in the Environmental Statement if, for example, the pro-cess is only half as effective ~and creates twice the exposure and
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.twice the waste?
Without specifically defined estimates and cri-
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'teria,Ethe Environmental Statement'is a blanket endorsement of
- an open-ended. process.
III.
Pre-operational Testing The' Environmental Statement states that they expect the process to have minimal effect on the welds in the primary
- loop.
There are some accessible welds which can be inspected to verify that no damage has been done and thus justify not inspect-ing'the few inaccessible welds and components.
What the Environ-mental Statement does not consider is the contingency consideration of what.will be done if the inspected welds show signs of damage after the decontamination.
What action will then be taken regard-ing the inaccessible welds and components?
There is very little information provided on the plans for the inspection and testing after the decontamination and system modifications are completed.
The plans and suitable acceptance cri-teria for this review should be documented and should be part of the basis for the Environmental Statement.
IV.
Wastes There are unique aspects of the wastes to be produced, such as the~ chelating agents, other chemicals of the concentrated solvent (undisclosed in the Environmental Statement), and the char'-
l acteristics of the Dow Chemical solidifying agent which are not fully j
considered in'the Environmental Statement.
,The' Staff response to Q6,estion 5 of Ms. Drey (Environ-w
a mental Statement, Appendix A, page 8) implies that the waste should be buried at least 10 feet from other wastes.
It is not clear if this is just good practice or if the solidified waste and/or the solidifying agent are susceptible to damage by some types of waste materials.
In the discussion of barrel corrosion rates, the Staff quotes worst-case corrosion rates where the barrels would
' corrode through in less chan a year and other environments where they may last 10 years but there is little or no evidence provided that the barrels will remain intact for the 50-100 years needed for decay of Co-60 (half-life'5.3 years).
In addition, the Staff says the leach rate for Co-60 is higher in the Dow solidifying agent than in concrete.
Thus, the proposed waste storage process seems exceedingly dependent upon the arid climate of the storage site for its acceptability.
V.
Items Not Addressed One of the most obvious missing elements is the plan and review of a pre-operational testing and inspection program.
There must be suitable acceptance criteria; but this is not addressed in the Environmental Statement.
VI.
Conclusions The Environmental Statement is written as if the pro-
-posed decontamination process is an everyday occurrence with no un-proven steps.
It is true that some tests have been run but this is the first commercial U.S. reactor to utilize a decontamination tech-
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nique to extend the useful plant life for 10 or 15 more years.
The Environmental Statement is too brief and contains little hard data.
The responses to questions raised by individuals reflect an after-the-fact analysis which tends to justify a decision already reached rather than openly consider the issue raised.
Thus, there is not enough information or serious analysis in.the Draft Environmental Statement to justify the Staff's conclusion that
.the benefits of this action outweigh the im-pacts associated therewith and the proposed decontamination will not significantly affect the quality of the human environment."
(Environmental Statement, Part 6.0)
Respectfully submitted, PEOPLE OF THE STATE OF ILLINOIS WILLIAM J.
SCOTT Attorney General State of Illinois BY:
h hNVANVRANKEN Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60601 (312)793-2491 ai.
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