ML19330B553
| ML19330B553 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/21/1980 |
| From: | Kempiners W ILLINOIS, STATE OF |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0680, RTR-NUREG-680 16903, NUDOCS 8008050020 | |
| Download: ML19330B553 (3) | |
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- William L Kempibeti.'
7 tor 535 West Jef ferson Stres, wargfield, Illinois 62761 + Teleonone: 217 782-4977
- s Reply to:
' July 21, 1980 7
Director, Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555 Subj:
Comments on " Draft Enviromental Statement Related to Primary Cooling System Chemical Decontamination at Dresden Nuclear Power Station Unit 1" Ref:
1.
Dresden Unit 1 Chemical Cleaning, Executive Summary of Project Progress, Prepared by CE Co Station Nuclear Engineering Department, Oct. 22, 1979
Dear Director:
The Division of Nuclear Safety, of the Illinois Department of Public Health, has reviewed the subject Environmental Statement and offers its comment.
In addition to the Statement, the Division has reviewed several reports, letters, and presentations prepared by CE Co, Dow, and the Illinois safe Energy Alliance.
- 1) Although the preponderance of researched data and other evidence supports the conclusion that: the proposed decontamination using Dow NS-1 is safe, the Environmental Statement fails to present sufficient data to provide a stand alone definition of the environmental impact to be expected from disposal of wastes produced by the proposed operation.
For instance, the report indicates that field or laboratory tesc results which quantify the migration potential of radionuclides associated with the Dow solvent are not available.
One must utilize other documentation to determine that test results are availa' ole but pertain to y
free ionic cobalt with no chelating agent.
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- 2) The environmental impact of disposal is not directly addressed.
Rather, it is stated to be less than that already analyzed in the FES, November 1973.
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L Director, Division of Licensing July 21, 1980 Page 2
- 3) Data on burial sites presented is given in the answers to letters in Appendix A.
Such data and more should be included in the body of the report.
- 4) It appears from reading varivas reports previously supplied by Dow, that the problems associated with recontamination
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have been ignored in the statement and understated in the answer to question 6a of Appendix A.
Reference 1 indicates that recontamination occurs quickly, suggesting the need for frequent future decontaminations.
This need, and its effect should be thoroughly addressed in the statement.
- 5) There was no discussion of venting of the N2 cover gas.
However benign this may be, it should be noted in the statement.
- 6) A better technical description of the chemical inter clon of the burial environment with chelated wastes should be provided in the statement itself.
It is our understanding from discussions with the DOW Company technical representatives that it is more desirable from a chemical reaction viewpoint not to deactivate the chelates by any means.
It was indicated that deactivated chelates would chemically react more readily with the burial environs.
- 7) The economic impact of alternatives does not include the effects of shutdown on the utility's reserve power status.
- 8) The arguments for utilizing the Hanford and Beatty sites need to be strengthened, perhaps with some statistical data on rainfall.
The present statement remains somewhat unconvincing.
- 9) No discussion of single, hignly exposed workers is discussed.
- 10) In the discussion of Radioactive Waste (Section 4. 2. 2),
"significant quantities" needs to be defined.
In comparing the amounts of decontamination wastes to total radwaste, a discussion of the comparison between the types of waste should be included.
- 11) No discussion of the effects of a possible closing of the Hanford and Beatty sites is included.
Because of this possibility, some discussion should be included for making the availability of a dry waste site a condition of approval.
't Director,'Oivision of Licensing July 21, 1980
. Page'3-
- 12) One disappointing aspectL of the statement is that' only one
- option, in reality, is considered viable.
Rather than rating the. options,;all others are eliminated due to the disadvantages, leaving only?NS-1 to choosa from.
One could hope'for at least a back-up option to compare against.
- 13) The response to Questien 1 of the Illinois safe Energy Alliance is unsatisfactory in-that it fails.to utilize all
'the data available to support the conclusion.
Dow has performed a feasibility study and scrutinised available data and litarature on the decontamination of nuclear reactors.
Several chemical solvents were tested on actual-metal samples (all of the D-1 primary system is constructed of Type 300 series stainless Steel) removed from D-l's primary system corrosion test loop and gave unsatisfactory decontamination factors or unacceptabla
. corrosion cates; therefore, Dow developed its own solvent
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NS-1, and this cleaning solvent was successfully applied on metal samples.
After antens;ve testing, it was concluded that serious intergranular stress corrosion cracking (ISCC) should not occur as a :asult of using NS-1 f or 100 contiaucus hours at a maximum 2500F. temperature.
It was observed that NS-1 is no more corrosive than deionized watec.
Sincerely,
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- William L. Kempiners Director cc
- . Bill O'Connor Fred Uhlig Pa? W.-O'Connor O
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