ML19338G439
| ML19338G439 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 09/04/1980 |
| From: | Janecek R COMMONWEALTH EDISON CO. |
| To: | Oconnor P Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8010290355 | |
| Download: ML19338G439 (12) | |
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Commonwealth Edison on7 First N'tional P'azi, Chic *go. I!!*nois Address Reply to: Post Office Box 767 Chicago lilinois 60690 September 4,
1980 Mr. Paul W.
O'Connor, Project Mgr.
Operating Reactors Branch 5 Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555 bo-IV
Subject:
Drescen Station Unit 1 Additional Information Pertaining to Chemical Cleaning Environmental Imoact Statement
Dear Mr. O'Connor:
The following information is being transmitted to you to assist in the preparation of the final Environmen;al Impact Statement for the Drescen 1 Primary System Chemical Cleaning.
- 1., " Radioisotope Analyses of Dresden Unit 1 Specimens",
- 2., " Transuranic Concentration in Dresden Unit 1 Cleaning Waste",
- 3., "Considertions in Regard to Currently Performing the Drescen Unit 1 Chemical Cleaning",
A.,
"Need for a Programmatic Environmental Impact Statement".
Please address any questions concerning this matter to this office.
Very truly yours, Robert F. Janecek Nuclear Licensing Administrator Boiling Water Reactors 6 \\\\
Enclosures
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S010290 3 6 I 6455A
Radioisotooe Analyses of Dresden i
Unit 1 Specimens On two separate occasions, radiometric analyses were performed on Dresden Unit I specimens.
In 1972, samples were obtained from steam generator hand hole covers and bypass piping.
Additional corrosion product scrapings from the steam generator tubes were taken in 1979.
The results of these investigations have been previously discussed with NRC personnel and are summarized in the following table.
Comparison of the detection limits across a wide range of energies indicates a lower limit of sensitivity for all gamma-emitting isotopes which is (at least) 20,000 times lower than the value reported for Cobalt 60 (Co-60).
Therefore, for an estimated value of 3000 curies of Co-60, any gamma emitting radionuclide which may not be identified in the analyses must consist of less than 150 millicuries.
Properly solidified and buried, this amount does not pose a significant concern.
'i As shown in the table, the predominant isotope remains Co-60.
The solidification process and burial have been designed to meet all federal and state regulations pertaining to it as well as all other identified radionucli des.
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TABLE 1 RADI0 CHEMICAL Af;ALYSIS OF CRESDEN-1 CRUDS mci /g*
~
Detection (Samples from t
twolocations)
Limit Energy,*
Isotooe 1/2 1972 1979 mC1/o Mev 144CePr 284d
.24;.02
.09 6.5 x 10-5
.13 y 141Ce 33d
.09,.01 6.7 x 10-5
,14 y 57Co 270d
.02,.02 6.,5 x 10-5
,14 y 58 o, 71d 3-3,1.1
.14 1.8 x 10-4
.8 y
C 60 o 5.3y 3.9 3.8 1.7 x 10-4 1.17,1.33 y C
154Eu 16y
.0015 1 x 10-5
,1 y 59pe.
45d
.064 1.2 x 10-4 1.1 y 55 e 2.6y
.53 1 x 10-3 K capture F
soft radiation 54 n 303d
.10,.05
.05 1 x 10-4
.8 y
M i
63Ni 92y
.20 1 x 10-4
.07 8 i
]
103Ru 40d
.16,.01
.002 1 x 10-4
.6 y
.i.
106RuRh ly
.0004
.17 1 x 10-6
.5 y
124Sb 60d
.0065 3.4 x 10-4 1.7 y i
125Sb 2.7y
.007 3.4 x 10-4
.4,.6 y 95ZrNb 65d
.16,.04
.03 1.7 x 10-6
,7 y
l.
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- Measured predominant gama activity unless otherwise indicated.
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1 Transuranic Concentration fn Dresden Unit 1 Cleaning Waste Calculations have been perf ormed in order to determine the amount of transuranic material which is expected in the Dresden Unit 1 chemical cleaning radwaste.
These results have been previously discursed with the NRC Staff and are summarized in the following table.
Values reported by Nuclear Environmental Services for the 1979 steam generator tube scrapings are presented in Table 1.
Using area ratios, these values have been projected into steam generator totals.
Additional calculations based upon primary system area ratios and a 50% efficiency in the scraping procedures, result in a total of 1.68 x 109 nanocuries in the system.
A more realistic appraisal is ~ based on calculated Co-60 curie levels (obtained f rom gamma field measurements) in various parts of the j
system.
Furthermore, a laboratory mock-up shows the 50% s: raping efficiency to be conservative.
Theref ore, a more realistic scraping l
efficiency would be 85%.
When these more realistic assumptions are used, the total system transuranic Activity becomes 0.74 x 109 nanocuries.
i It is evident that the transuranic nuclide concentration is in i
the range which can be controlled.
A measurement of the transuranics in t
the unconcentrated waste will be made to confirm the required evaporation ratio after the spent solvent is returned to the shielded storage tanks.
Through the use of these analyses and operating procedures, we will insure that all transportation and burial requirements pertaining to transuranic limits will be met.
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TABLE 1 ALPHA EMITTING _NUCLIDES The transuranic concentrations are reported in millicuries per 4
gram. The T-XXX indicates the tag number we have designated that particular sample for our records.
SAI TAG #
00W TAG #
T-395 T-396 Per Amount Used 106-1-2 106-2-1 Steam (mg) 4.60 mg 7.',7 mg Generator Nuclides mci /g mci /g mci Pu239-240 1.09105(-3) 1.651 08(-3) 35 Pu238 -
1.95110(-3) 2.701 13(-3) 60 i
Cm341 5.22139(-4) 6.281 63(-4) 15 l
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Cm242-243 2.281 17(-3)
~2.571 26(-3) 63 Cm244 7.87f.59(-4) 7.811 78(-4) 20 TOTAL TRANSURANIC 193 S
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1 ATTACHMENT 3 Considerations in Regard to Currently Performing The Dresden Unit 1 Chemical Cleaning.
In May of 1980, Commonwealth Edison Co. decided to defer the restarting of Dresden Unit 1 to June of 1986.
This delay was the result of the current undefined future commitments required by the events at Three Mile Island, participation in the Systematic Evaluation Program and existing corporate short term cash fl ow defici encies.
As a result, all projects, except for the Chemical Cleaning, are being brought to a logical point of termination and have been given re-start dates to co-ordinate with the revised start-up.
A)
A number of commenters have suggested that the chemical cleaning project should also be deferred for several years until necessary to meet the new 1986 start up date for Unit 1.
Commor. weal th Edison considered this alternative at the ' time of deferring Dresden Unit I restart and rej ected it for the following reasons, which are compelling:
1)
Additional expense would be incurred to lay up the installed equipment f or proper long-term storage.
An estimated $50,000 would be necessary to perform the actual chemical cleaning system lay-up.
Another $50,000 would be. equired to perf orm the necessary maintenance and inspections during the lay-up period.
(Total estimate $100,000) 2)
Delay of the project at this time would effectively cancel contracts with DOW Nuclear Services, Catalytic, and General Electric, the prime consultants on the project.
Additional costs would be incurred by CECO to establish, review and approve i
new contracts, in order to reinstitute a cleaning program with these consul tants.
It would take approximately fourteen (14) months to initiate new contracts, organize key management, secure qualified engineering personnel, and familiarize and train these personnel.
1 A delay and the resulting cancellation of the contracts with DNS, Catalytic and GE would also cause the loss of key personnel i
from the project.
These people, some of whom have been with the project since its inception in 1973-74, have considerable expertise in the design, engineering, construction and operation of the chemical cleaning system, as well as related research studies.
The loss of these personnel will result in the loss of extensive k nowledge and skills necessary f or a successful i
completion of the project.
i New personnel will be required and it will take them considerable time to review the chemical cleaning system to obtain a full understanding of its functions and operations.
The estimated cost for the above is $1,700,000.
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3)
A delay would require a complete re-preoperational testing of all i
equipment'and systems taking a total of approximately eight (8) weeks at a cost of $300,000.
4)
A new supply of chemicals would be required at an additional cost of $750,000.
Thus, the total additional costs of delaying the chemical cleaning f or several years would be approximately $2,850,000.
These dollars are an estimate based upon data that is presently avail ab l e.
This figure does not include the costs presently being incurred by Commonwealth Edison in maintaining the chemical cleaning project in readines's pending the NRC's decision to approve or disapprove the project.
Commonwealth j
Edison has previously estimated these costs, attributable to regulatory inaction, to be about $100,000 per month.
5)
Any delay in the chemical cleaning will require personnel, as j
they perform routine activities, to receive additional radiation t
dosage.
The following lists activities that will be perf ormed:
?
Activity Dosage 1
a)
Re-hydro test of the reactor 1 man-rem pressure vessel system.
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b)
Retraining of new personnel.
15 man-rem c)
Detensioning of RPV head and 6 man-rem later retensioning.
d)
Leak detection system m'aintenance 1 man-ren Total additional dosage not pre-I viously estimated 23 man-rem f
This total of 23 man-rem does not include dosage which would be incurred as a result of any in service inspections required
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during the lay-up period.
Activities related to the Dresden 1
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lay-up could increase this number significantly.
A delay in the chemical cleaning could possibly prohibit potential lay-up alternatives from being performed, due to excessive dosage.
6)
Any delay in the chemical cleaning reduces or eliminates the company's flexibility to adjust the unit's return to service if load demand or financial considerations change.
The chemical cleaning must be completed before many of the required plant modifications are made.
Early completion of the cleaning allows efficient use of manpo.ser aad financial resources.
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8)
Section 5.2 of the Draf t Environmental Statement presents the permanent shut-down of Dresden Unit 1 as an alternative to the proposed chemical cleaning.
It then rejects this alternative because the costs of the chemical cleaning (estimated to be $37.5 million) are f ar less than the estimated savings in replacement power should Dresden Unit 1 be returned to service.
A number of commenters have debated the NRC's estimate of replacement power costs.
As Edison has previously stated, permanent shut-down of Dresden Unit 1 is not a true alternative to carrying out the chemical cleaning.
Decontamination is a necessary step in decommissioning the f acility 7,
,even if Dresden Unit 1 is perman,ently shut down.
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A second major flaw in the NRC's analysis is that it i s incorrect to y
use the entire decontamination budget in deciding whether to go ahead with the chemical cleaning of Dresden Unit 1.
'l At this time most of this budget has been expended and represents j
" sunk cost" which according to law, must be ignored in striking the NEPA cost / benefit analysis.
New England Coalition On Nuclear i
Pollution.
- v. NRC, 582 F.2d 87 (1st Cir. 1978).
Instead, the cost of completing the chemical cleaning at this time is the relevant cost, for NEPA purposes.
Edison estimates this cost to be $1.3 million, based upon the following:-
- i d
Surveillance 300,000 3
CECO Radiation Protection 20,000
- j CECO Operating Support 30,000 i
Contrac tor Maintenance 250,000 Facilit y Operation by Dow 550,000 l
Radwaste Solidification 150.000 1
TOTAL
$1,300,000 N.
.t Again, this estimate does not include the large costs associated with j
regulatory delay in this case.
On the other hand, some commenters have argued that the NRC's estimate of replacement power costs for Dresden 1 is too high.
2, f or example, correctly notes that because start-up of the unit has already been delayed until 1986, the relevant replacement power estimate should be calculated f or 10 years f or the remaining 4
operating life (1986-1996) rather than 15 (if the alternative being consi dered is permanent shut-down).
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-4 Edison has re-calculated the costs of replacement power for Dresden Unit 1, using latest available estimates of system capacity and fuel costs, as follows:
Commonwealth Edison's best current estimate is that replacement power will cost approximately 30 mills /kwh in excess of the cost of generation at Dresden 1 for the period in question.
Employing a 30 mills /kwh replacement power cost, and based on a total capacity f actor of 49% (derived historically) the following can be calculated:
49% X 207MWe X 1000KWe X 30 mills X 1 dollar X 24 hrs 1MWe 1 kwh 1000 mills 1 day
= $73,000/ day (Average)
The 30 mill /kwh comes from the PROM 00 III code.
The PROM 00 III computer code is used f or production cost studies.
PROM 00 III was developed by Energy Management Associates, Inc. and is now used by more than 20 electric utilities.
PROMOD III has also been used in studies performed by the Department of Energy and the Edison Electric Institute.
PROM 00 III essentially simulates the operation of future el ectric-generation systems.
The major data requirements which are necessary inputs to the program are a load forecast and efficiency forced generating unit characteristics such as size, type and cos,t.
outage rates, maintenance requirements, fuel The model uses these data to perform calculations to determine expected fuel consumptions, operating costs and generating unit I
cap acity f ac tors.
The replacement power cost derived f rom PROM 00 III reflects the most economical mix of producing replacement power f rom Edison's other generating f acilities and purchasing replacement power from other utilities.
It also implicitly accounts f or the savings in eliminating the operating expenses associated with Dresden Unit 1, contrary to CBE's suggestion.
At the time the DES was written, it was expected to put Dresden 1 back on line, in 1981.
Thus, shutting D1 down permanently, would require 15 years of replacement power.
At the historic 49% cap acity f ac tor, 15 years of replacement power would cost 15 x 73,000 x 365 = $400,000,000.
Compared to this $400 million, the $300,000,000 in the DES is conservative.
Even though D1 is not expected back in service until 1986, shutting the plant down would entail 10 years of replacement power.
A realistic figura for replacement cost is as follows:
10 x 73,000 x 365 = $266 million i
(based on 30 mills /kwh replacement power cost and a 49% capacity f actor)
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. This figure does not i alude present value or escalation.
If these factors are takei. into account, at the 10.8066% interest and 7.5% inflation rate used by Ceco, we estimate a $190 million Present Valued Replacement Power Cost between 1986-1996 for 01 being shutdown.
I On the other hand, this estimate fails to take into account the present value of capital improvements necessary to return Oresden Unit 1 to service.
Commonwealth Edison is not able at this time to estimate the costs of those capital improvements, due to the present uncertain regulatory climate.
This is one of i
the reasons why the -restart of Dresden Unit I has been delayed.
Because of this uncertainty, the NRC should be cautious about i
relying solely on estimates of repl acement power savings in this analysis.
Nevertheless the investment of $1.3 million to carry out the chemical cleaning at this time is clearly a prudent business judgement in order to preserve the option of returing Oresden Unit 1 to service in the near future, even if the
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potential replacement power savings cannot yet be quantified precisely.
Finally, Commonwealth Edison believes that in light of the NRC 1
Staff's determination that the chemical cleaning will have insignificant environmental impacts, consideration of the
" alternative" of shutdown is.not requi red by NEPA.
The NRC case law is clear that:
I to a course whickation to search out kossible alternatives There is no obli itself will not eit er harm the I
i environment or bring into serious question the manner in I
which this country's resources are being expended.
Virginia Electric and Power Company (North Anna Nuclear Power
'I Station, Units 1 and 2) ALAB-584, 11 NRC 451, 457 (1980);
Portland General Electric Comoany (Trojan Nuclear Plant) ALAB 531, 9 NRC 263, 266 (1979).
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NEED FOR A PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT In its comments on the Draf t Environmental Statement, Citizens For a Better Environment (CBE) demands that the NRC prepare a programmatic environmental impact statement covering not only the proposed chemical cleaning of Dresden Unit One but also possible future decontaminations at
'I other nuclear reactors.
According to CBE, a Programmatic EIS is required by NEPA~and by the CEQ's regulations.
40 CFR S2508.25(2) and (3).
a CBE's interpretation of NEPA is clearly wrong, directly inconsistent with the United States Supreme Court's decision in Kleppe v.
1 Sierra Club, 327 U.S. 390 (1976).
In Kleppe the Sierra Club attempted to prevent the Department of Interior from granting coal leases for certain f
specific mining operations in the Powder River Coal Basin.
Even though
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impact statements had been prepared in respect of those i
specific projects, the Sierra Club, citing widespread interest in the q
coal reserves of a broader region in'dentified as the " Northern Great Plains," argued that federal agencies could not allow the Powder River
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developments to proceed without preparing a " comprehensive" regional imp act statement f or the Northern Great Plains.
While the Suareme Court acknowledged that there was " waxing interest" in developing the Great i
Plains coal, it found that there was no concrete plan or proposal to develop the region.
In the absence of such a proposal, the Supreme court ruled that NEPA did not require a regional EIS, and further observed that preparation of such without a "f actual predicate" would be impracticable.
The Court also held that even if preparation of a, programmatic environmental imp act statement had been necessary and feasible, it would have been in error for lower courts to enjoin the Powder River Basin projects in the absence of any showing that the environmental analyses of the individual projects were inadequate.
427 U.S. 390, 407-8.
In this case, it is simply too soon to tell whether mid-life decontaminations will be carried out at nuclear reactors other than Dresden Unit One.
If so, it is certainly impossible to say at this point which reactors and whether the decontamination method or methods chosen will resemble the chemical cleaning proposed f or Dresden Unit One.
Thus it is premat,ure and impracticable at this time to prepare a programmatic environmental imp act, although if in the future mid-lif e decantaminations seem to be a routine need for most reactors such a statement might be appropriate.
And even if the Commission were to decide, as a matter of discretion, to try to prepare a programmatic EIS, there has oeen no showing that there are cumulative or synergistic eff ects of such possible l
future decontaminations which make separate consideration of the Dresden Unit One chemical cleaning inadequate, nor does Edison believe any such effects exist.
Therefore, there is no legal or commonsence reason to delay the Dresden Unit One project.
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