ML19340B405

Forwards Request for Addl Info Re Technical Study for Chemical Cleaning of Facility.Advises That Meeting W/Dow Chemical Co & Site Visit Would Expedite Resolution of Concerns Re Decontamination

ML19340B405
Person / Time
Site:	Dresden
Issue date:	12/05/1977
From:	Grimes B Office of Nuclear Reactor Regulation
To:	Oconnor P Office of Nuclear Reactor Regulation
Shared Package
ML19340B404	List: ML19340B403 ML19340B405
References
NUDOCS 8010220711
Download: ML19340B405 (13)

Text

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ENCLOSURE 1 9':

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llEMORANDUM FOR:

P. W. O'Connor, Operating Reactors Branch #2, DDR

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FROM:

B. K. Grimes, Chief Environmental Evaluation Branch, DDR

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SUBJECT:

DEC0HTN11 NATION OF DRESDEN UNIT 1

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P,crerence:

Dow Chenical Company Reports on " Technical Study for the Chemical Cleaning of Dresden 1" The Environmental Evaluation Branch, Division of Operating Reactors, its consultants Bat +.elle Horthwest Labs and the Radiological Assessment Cranch (DSE) have reviewed the above referenced docuacnts. Acequate responses to the enclosed request for additional information are required before we can

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complete our evaluation.

In order to expeditiously resolve most of these 3

c concerns, a neeting with Dow Chenical, where a scale codel of the radwaste building is, and a necting at the Dresden site would seem appropriate-

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Transmittal of the enclosed questions to the parties concerned prior to a formal meeting cight also expedite resolutio6.

Brian K. Grimes, Chief Environmental Evaluation Branch Division of Operating P.cactors i

Enclosure:

e Questions on Dresden Decontauinati6n

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V. Stello DISTRIBUTION D. Eisenhut Central files J. Collins EEB Rdg W. Kreger BGrimes T. ?!urphy RZavadoski J. Kastner LBarrett D. DiIanni J6th cert

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Questions on Dresden Decontaminatien 1.

Transuranic contaminants in solid wastes cannot exceed 10 nanocuries/ gram for disposal at licensed burial facilities, except for the Richland, Washington

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Since the chemical decontamination of the Dresden-1 primary system will remove transuranics, as well as Cobalt-60, desiribe the measurements and procedures which will be followed to assure that the transuranic content in solid wastes is not exceeded: Provide the leveis of trans jranics present in the decontamination solution (unconcentrated or ccncentrated but specify which) used in the pilot decontamination.

2.

Details of the ventilation system for the Waste Processing Building and con-N tainment sphere have not been presented.

Describe the system in detail, speci-fically identifying such items as HEPA and activated charcoal filters which will be used to reduce radioactive effluents.

If air can bypass the filtration sys-tem, evaluate the pc sible onsequences. Describe the " unfiltered gas pathway e

in the cleaning facility" mentioned in Section 10.1 of DNS-NS-DI-020.

3.

What is the flammability of the solidified waste product and the organic binder prior to use?

If the procuct is flammable ' provide a detailed analysis of the criteria, procedures and provisions which will be invoked to mitigate the potential fire hazard.

4.

A nitrogen system will be connected to the steam drun to maintain a positive pressure on the primary system during decontamination.

During fill, the nitro-gen is vented to the containment ventilation system. What provisions have been made to filter the vent'ed nitrogen?

If no filtration is 'provided for, bvaluate the possibility of filtering and the effects of such filtration on reducing airborne effluents.

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The applicant estimates that the off-site doses due to the release of E=E.j 1-gaseous waste will be negligible.

However, lodi e-129 contamination of the pri-l

-mary system has not been addressed.

Estimates of the total quantity of I-129 5[.5 p= _

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which will be collected during decontamination (from samples,0f the test loop i

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solution) should be addressed as well as the estimated release paths and their E=

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environmental impact.

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6.

In the event of a large volatilization accident with f S-1 solvent at Dresden gj. 3 i

i 1, wSat provisions or precautions have been taken to assure the safe habit-

Eist.

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' Tsq ability of the operators in the control. dom of Units 2 and 3? Specifically, js t

(1) how will the cperators in Units 2/3 be notified of such an event, (2) what t

i protection is affcrded to the operators, such as control room filtration or

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1 respirators, and (3) what procedures will be followed in the event of an incident.

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Experience with the. pilot loop indicated that small leaks of solvent can be

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j expected to occur with possible increases in airborne releases of radioactive E. l,.;

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materials., Based on measured releases of radioactive materials (iodine and par-ticulates includir.g alpha emitters) from the test loop area during decontami-

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nation estimate what the releases might be from the full scale decontamination jj

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opera tion.

It should be noted that the reported Co-60 release from the Cresden JC a

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Unit I reactor for the month of June 1977 (when the test loop was deconta--i-

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nated) had increased o'.er prior months of reactor operation.

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Assuming there will be some leaks in the primary system decon, as experience

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' dictates from tie pilot loop, and also assuming that the nature, extent and

=g place of. a leak cannot be predicted what is the effect of flS-1 solvent in the

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m-vapor form and in the liquid form on cabling and instruments necessary for i

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safety? From the experience gained onothe test loop, conservatively estimate d

the amount of solvent which could potentially leak from the primary system.

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Describe the overflows and vents from the waste storage tanks with respect

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to design such that inadvertent overfilling of the tanks would not result in a

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release of radioactive liquids.

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gr 10.

Procedures for installation of temporary piping and drain lines in the

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primary coolant system should be described for equipment installation, hookup, removal and disposal. The description should include (1) which operations will

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be remote and which will require workers to be in close proximity to perform i

ZE the job, (2) the methods to be employed to ens 0re containment of radioactive

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material, and (3) h w radiation exposures will be kept ALARA during these opera tions.

11. Provide a detailed example of dose calculations for a particular installation procedure.

This should include:'(1)'a detailed procedure outline;(2) the time and personnel involved in the job;(3) actual dose rate measurements taken in tha area where the job will be performed,and(4) specific procedures and ' techniques

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12. Which portions of the actual cleaning operations are expected to contr. mute

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the major portion of radiation exposure? What contingencies have been taken into i

consideration in the dose estimates? Specifically, which procedures will involve

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13. What type of ventilation system has been installed in the radwaste building?

How will effluents be controlled? What parts of the building and waste treatrent

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system must be dismantled and removed or decontaminated af ter the chenical g

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cleaning has been compleigd?.How much radiation exposure is expected from q...;.y these procedures? Since the cleaning' solution etches stainless steel, what b==

provis' ions have been taken to en'sure that the waste,, storage tanks will isolate the waste ' solution effectively?

14. For waste handling operations, how will the radwaste system be operated?

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- Will it be a remte operation or an inhabited operation? Describe the proced-M j

ures to be used for handling and processing the liquid waste. Whatcontpgencies have been considered in the dose estimate,s,for waste handling? Doe'. ilsmantling

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l and cleanup include loading waste containers and transport to the disposal site?

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Describe the procedures for processing and solidification of the radwaste, in-cluding the dose estimates for these procedures.

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15. Provide esticates of the curie amounts of Fe-55, Hi-63, and any other non-

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gama emitters of significant quantities (~>10 curies) that. may be encountered

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in the decontamination process.

Provide assurance that all liquid releases to the environ' ment from the Dresden 1 reactor, including Dresden 2/3 if liquids from Dresden 1 are transferred to Dresden 2/3, will be analyzed for the isotopes determined above while decontamination and subsequent waste. processing operations are in progress or until the expected relea'ses of these isotopes decrease to less than 10 mei/yr.

Analysis should consist of at least a monthly analysis of a cis composite sample of all the liquid releases over the past month.

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16. Describe the considerations and features which you nave included in

.g g the design of new radwaste facility to help maintain occupation 41 expo-sures As low As is Reasonably A_chievable (ALARA).

Drawing A-102 does

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not'show any separation by shielding of the various radwaste components

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(condensors,resinbeds,evaporato..etc.).

If you intend to use this

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facility on a continuing basis, maintenance of these components will be

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necessary.

Workers involved in such maintenance will be unnecessarily I..:. ;

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exposed to radiation if shielding is not installed to separate tanks y

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and demineralizer beds, etc. from pumps and valves.

Include such

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shielding in your design or justify the lack of such shielding in light of your comitment to maintain occupational exposures ALARA.

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17.

You have indicated that Equipment Installation, Hookup and Operation i

phases v!ill be responsible for the major portion of your estimated man-rem for the entire decontamination 'ptoject.

Provide a list of the tasks in-4 volved in these indicating your estimate of the man-rem which will be

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received in each task.

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18. Appendix X" of " Technical Study for the Chemical Cleaning of Dresden I" describes SUNTAC's general radiation protection procedures.

Page 4 states that the radiation pro ~tection training program is a minimum of two hours long, g.

4 Describe the criteria used for the length of radiation protection training 1

j relative to the tasks to be performed.

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Page' '18. states that " pre-plan meetings" viill bs hel'd for v.ork involving 4:.

dose rates above 1 R/hr. Justify your belief that pre-plan meetings for work in areas with dose rates greater than 100 mR/hr are not necessary.

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Verbil Response to Questions on Dresden Decontamination 5ll :

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11 Questiu 1 Response As of this date, no attempt has been made, nor was one planned, to measure the transuranic content of the wastes expected from the chemical decontamination waste.

Commonwealth Edisen (CE) pointed out that EPRI has mad.e measurements at several plants, but not Dresden 1.

It was pointed out by the NRC staff that their results could not conclusively rule out the possibility of exceeding the

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10 nanocuries/ gram limit for solid wastes at licensed burial facilities (the

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limit for all except Richland). CE's consultant, Dow, said it may be possible

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to perform an analysis on their waste solution left over from the test loop de-contamination, but that this vmuld be very difficult due to the nature of the analysis. No commitments were made and this remains an open item.

Unless the licensee can provide adequate assurance that the decontamination solu-tions will contain less than 10 y ci/gm of transuranics, he should be required to analyze the decontamination waste after the plant decontamination to assure proper disposal of t'he wastes.

Question 2 Response This question should be answered by the licensing submittal where details of the chemical cleaning building will be given. The ventilation system for the building consists of two 15,000 CFM filter trains complete with !iEPA filters.

The unfiltered gas pathways consists of the clean utility area and truck bay og which do not communicate with the radiation zones and are maintained at a higher positive pressure. There is a 2 CFM toilet filter near the control room which is unfiltered and in a radiation zone.

No charcoal filters are necessary due to the

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low level of iodine present (< 1 y ci of'I-129) and the extended time of pro-y;;.-*

cessing the waste.

If 1 y ci of I-129 was released over two hours with 30,000 y':h))

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tration would not be exceeded at the stack, much less the site boundary. The basis for the 1 y ci of I-129 will be provided in the submittal (see response I.i

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Question 3 Respo'nse The solidified waste product is not flammable and Dow has documented this O~

l by tests and reports. This issue should be resolved by referencing the reports 4

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j in the licensing submittal. However, the binder is flammable and prior to its incorporation in the waste PSB should review the fire protection aspects of the binder use.

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Question 4 Response l

The nitrogen is vented thru both HEPA and charcoal filters according to CE. This issue should be resolved by the 'i' censing submittal.,

Question 5 Response An estimate of the total I-129 content contamination has been made and f

is appr'oximately 1 y ci. Details of the estimate with justification were prom-ised for the licensing submittal and should resolve this issue.

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Question 6 Response According to Dow, if the NS-1 solvent is vaporized, only water vapor is

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produced, which' posses no threat to the safe operation of ' Units 2/3. This-

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question should be eliminated.

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4 Question 7 Response Measurements were made for airborne releases in the' test loop 'rea during the test loop de'.ontamination (June,1976) and no increase in airborne activity was measured ever tiough there were known leaks in the system.

For June of 1976 airborne Co-60 releases did not increase significantly.

Experience therefore iridicates that this is not a significant problem.

Question 8 Response See response to question 6.

Water vapor at the temperatures (<200*F) and pressures ( atmospheric) used in this cleaning operation should not deleter-iously effect safety related cabling and instruments.

In addition, the safety related cabling and instruments will be replaced during this outage. Therefore, this question should be eliminated.

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Question 9 Response In the Chemical Cleaning Building all process equipment and tanks are ey housed in a Seismic I " bathtub" with the lowest penetration at 10 ft. above base level.

If everything failed.ne " bathtub" would fill to the 6 ft. level. This will be documented in the licensing submittal.

Question 10 Response CE has identified approxinately 100 interfaces with the primary system each of which has been evaluated in detail.

CE promised to supply these esti-mates in the licensing review. A curscry revi'ew of their estimate for one inter-face indicated that all the concerns expressed in questions 10,11,16 and 17, as

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well as the general comments mentioned via the cover memo, will be eliminated in the licensing submittal.

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Question 11 Response See Question 10 Response

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CE agreed to demonstrate with approximately 5 of their 100 interfaces what ste'ps they would try to take to reduce exposures. This issue should be resolved in the licensing submittal.

Question 13 Response

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See also Question 2 Response. The Chemical Cleaning Building will not be dismantled. The corrosion rate of the hS-1 solvent is less than 3 mils / year, so 7

4 this is not expected to be a problem for 1/4 inch stainless steel tanks.

Question 14' Response

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Details of the operations of the Chemica.1 Cleaning Building will be submitted in the licensing submittal and should resolve this issue.

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j Question 15 Response This is an unresolved issue which should be formally forwarded to the licensee.

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Questions 16 and 17 Responses See Question 10 Response.

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Quet'.Jons 18 and 19 Responses The questions were based on SUNTAC's general radiation protection procedures.

For the' actual' Chemical Cleaning CE's radiation protection procedures'will be~

I-followed which require 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> minimum radiation protection training plus separate e

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In addition, all jobs performed in areas with dose rates greater than 100 mr/hr require supervisory' review.

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ATTENDAllCE LIST A 12/15/77 SITE VISIT'TO DRESDEN-CHEMICAL CLEANING

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Mike Turbak Ceco Nuclear Licensing Roger.Zavadoski USNRC/D0P./EEB R. T. Cupp Catalytic - Power Engr.

Robert Clark Battelle PNL Jay Lee USNRC/DSE/ETSB Kelvin Soldat~

Battelle PNL W. S. Lange Ceco - SNED Dave Harner Dow Nuclear Serv.

• H Richard E. Basso Catalytic, Inc.

Jack Harrison Ceco - Dresden Proj. Engr.

Stan Graves Ceco - SNED - Proj. Mngr.

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ATTENDANCE LIST B

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12/16/77 MEETING WIT 9 CATALYTIC, INC.-

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Dill Wehn D.d.S.

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Tom Snyder Catalytic, Proj. Engr.

4+i-Richard E. Basso Catalytic, Proj. Mngr.

J. Stanley Graves Ceco - Proj. Mngr.

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Dave Harmer Dow Nuclear Serv.

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Roger Zavadoski USNRC/ DOR /EEB

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M Robert Clark Battelle PNL

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Kelvin Soldat Battelle PNL

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