ML19344D578
| ML19344D578 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 03/26/1980 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Drey K AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML19344D579 | List: |
| References | |
| NUDOCS 8004250056 | |
| Download: ML19344D578 (2) | |
Text
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UNITED sTA[Es NUCLEAR REGULATORY COMMISSION 2
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1 Docket No. 50-10 h!AR 2 6 &U i
Ms. Kay Drey 515 West Point Avenue University City, Missouri 63130
Dear Ms. Drey:
This is in response to your letter to Chairman Ahearne in which you requested information about the status of the Comission's response to your March 19, 1979 request for the preparation of an Environmental Inpact Statement for the Dresden Unit No. I chemical decontamination.
As you know, the Nuclear Regulatory Comission (NRC) is treating your reauest as a petition for Comission action under the provisions of Section 2.206 of Title 10 to the Code of Federal Regulations. We have enclosed a copy of the NRC - Rules of Practice for Domestic Licensing Proceedings for your information.
In response to your petition the NRC staff is presently reassessing the environmental impact of the Dresden decontamination. This reassessment will consider the numerous issues that you and other members of the public have l
raised.
l We have contracted with the Brookhaven National Laboratory to carry out independent confirmatory research related to some aspects of our review.
When the results of this research program are available, we will complete our environmental evaluation and determine the appropriate response to your petition in accordance with the National Environmental Policy Act (NEPA).
The NRC is fully comitted to satisfying all requirements of the NEPA. Our regulations which implement the NEPA requirements are contained in Title 10, Part 51.5, of the United States Code of Federal Regulations. These regulations are in conformance with guidelines issued by the President's Council on Environmental Quality which were in effect prior to July 30, 1979. They identify the types of actions for which NRC must prepare an environmental impact statement. The Comission is presently in the process of modifying our Environmental Protection regulations to take into account, voluntarily, the regulations promulgated by CEQ which became effective July 30, 1979. We have concluded that this action is not one of these actions requiring an environmental impact statement under current Comission regulations.
While our regulations do not require the preparation of an environmental impact statement, we are evaluating the environmental impact of the proposed action to determine whether an environmental impact statement should be prepared because of specific circumstances related to this particular action.
If it is determined that an environmental impact statement need not be pre-pared, a negative declaration and environmental impact appraisal will be prepared in accordance with Sections 51.7 and 51.50(d) of our procedures for environmental protection. We will complete our review and issue the appropriate statement or appraisal prior to the Dresden decontamination.
s o o nso OSG
Ms. Kay Drey e i
The decontamination is presently scheduled for April 1980. In compliance with our requirements, Commonwealth Edison has submitted the results of a testing program supporting the decontamination. They may not proceed with the operation until the NRC staff has approved their testing program.
l Please be assured that NRC will not authorize the decontamination until we have concluded our review of your request and have responded to your petition.
Sincerely, c.:.<,., m y y
?!.. 2:.it:3 Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosures:
1.
Rules of Practice for Domestic Licensing Proceedings 2
Licensing and Regulatory Policy and Procedures for Environmental Protection i
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January J.19CO n
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. TQ:
Pr:sident Jimmy Cart:r, and ts Messrs. John A%arne (Ch3irman,Nuclccr Regulatory Comunission). Douglas Costle' (Administrator, Environmental Protection Agency), Jacob Dtanelle (Chairman, Illinois Pollution Control Board), Charles Duncan, Jr., (Secretary, Department of Energy), Charles Percy (U.S. Senator from Illinois), Adlal Stevenson (U.S. Senator from Illinois) William Scott (Attorney General of Illinois), James Thompson (Govenor of IIIInois), and Charles Varren (Ch4Irman, President's CouncII on Environmental quality)
FCH: Kay Drey, 515 West Point Avenue, University City, Missouri 63130 Next month an experiment -- replete with known and unknown hazards -- Is scheduled to take place at out nation's oldest nuclear power plant, no more than thirty highway miles southwest of Chicago's suburb's. Commonwealth Edison plans to flush chemicals through its Dresden-One reactor to try to dissolve and remove an accumulation of radioactive corrosion products (crud) from within some five miles of convoluted piping. Citizens have s.rltten to the Nuclear Regulatory Commission and the Department of Energy asking that a full Environmental Impact Statement (EIS) be prepared; at least one Illinois organization has asked for a public hearing. Instead we haie been hearing for months now that if an Els is ever to be written, it will be after the fact, not before.
On !tarch 19, 1979, I'sent a copy of the enclosed letter to ysu (or yourpredecessor) listing some of the questions that seem to me to be undeniably wsrthy of examination by Independent scientists -- that is, by scientists other than those from one of the federal agencies, private chemical or nuclear corporations.' research laboratories, universities, or electric utilities which have already ccanitted manpower and/or financial resources to this first in a series of proposed experiments. In addition. I filed a more for:r.al request for an Els on March 30, 1979,with the NRC and DOE. The DOE answered, saying that since they were not expending any fiscal year 1979 funds on the project (their $8.2 million subsidy was apparently contributed to Commonwealth Edison or Dow
_CNrilcal orlor to 1979), they did not feel obligated to write an EIS. The NRC answered that receht of my request had been appropriately acknowledged in the Federal Reoister.
,1 believe M other citizens who wrote received similar responses.
[That Is, to date there has been no public hearing, rc EIS, and no opportunity for
- independent scientists to study the proprietary decontamination brew or to reflect on
! the immeciate and long-term impacts of its use. The project is proceeding under the supervision ano negis of the people most committec ;o and dependent coon its success.
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To allow at least 10,000 to 20,000 oounds of enele:!ng agents (comple.xing solvents) to be flushed through the Dresden '. hit One reactor -- a 20-year-old hulk of corroded, Irradiated, brittle, leaking, man-made, man-operated retal gadgetry -- and to bring c,ut into the biosphere an estimated 450 to 1,100 pounet r.f radtoactive wastes on the basis of assura9:es f ro:n men who have no alternative soiutiens to the permanent shutdown of this prototypical reactor seems to me to be clearly contrary to the letter and intent of the ::ational Environrental.Act of 1969 It i: ake just Asir. frl;5:aning.
f.t.9 Pls=su recall that cheletes have been found to rc t*e very agents responsible for the unex:utedly rapic rigration of radioactive wastas cut of the Oak Ridge burial
- ren:5as ents the unprotected environment. Chelat s also make it easine for radio-mive ::a:erials to be absorbed by roots of gran and vegetables - potentially, then, t: he f urther concentrated in the flesh and milk c' animals when they eat the grass or plants. The NRC says that gravity and Cak Ridge's hioh water table are resconsible fcr tne licuid wastes' eoDility there. An ERDA (CDE) study, however, by geochemists u d.
c.- fm Prir.:eton Uninrsity, Cak Ridge National Lah-:;ery, fr.d Battelle-Columbus Lcbor-ct: y say chelates are responsible. This latter study also says that chelates are oraxoec:edly persistent in tne environment. That rer.-s that the radioactive wastes fed e to ther at Dresden will re:nain uncontaina:le and therefore immeasurably enore Lc:ard ua for decades, perhaps for centuries, pcW-- f oreve r.
Even if they're t,uried
-s ;re:e n: in tevcGa or Wasnington -- in wv r.
3 day are climctically dry ant'
- x t i icai b agreeable -- wn t assurances do we have :nat tha future will mirre the print?
s u wns: r i p t do we.:a ve r: assume that It wil'7
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.:-bsr :' wr Sta. f hicaw fir.: m wh :nst an Ernrernntal Mpact
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S t ie r.c e, 3C June l a7f.,
Volur.e 220. :p. 1477 - 1 4 1.
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.c Yoi Presidect Jiccy Cartori cad to Massrs. Dsuglas Costlo(Adninistrator s
.Eavirstconcol Prstection Agency), Jacob Ducs11s(Chairman. Illinois
. Pollution Control Board)., Joseph Hendrie(Chairman, Nuclear Regulatory Commission), Charles Percy(U.S. Senator from Illinois), James Schlesinger (Secretary, Department of Energy), William Scott (Attorney General of Illinois), Adlai Stevenson(U.S. Senator from Illinois), James Thompson (Governor of Illinois), and Charles Warren (Chairman, President's I
Council on Environmental Quality) l om: Kay Drey, $15 West Point Avenue. University City, Missouri 63130 I
a PLEA FOR AN ENVIRONMENTAL IMPACT STATEMENT ON A MAJOR FEDERAL ACTION PRO-POSED FOR THIS SPRING, 1979 IN ILLINOIS
- i The U.S. Department of Energy is presently contributing $8.2 million toward the first of a series of decontamination experiments designed to dissolve and flush out radioactive corrosion products from nuclear reactors. In April or June (?). 85,000 gallons of a proprietary Dow Chemical solvent are to be flushed through an estimated five miles of l
l piping for 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> within our nation's oldest active commercial reactor (Commonwealth Edison's 200-megawatt Dresden plant. Unit one, near Morris and Joliet, Illinois, on the Kankatee River).
I This solvent may be chemically similar to, even identical with, the very compounds which have been found to be causint the unexnectediv l
raoid migration of radionuclides out of the Oak ".idge burial t re n c b as and possibly into the human food chain.
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The claim contained in a letter I received last month from the Department of l
Energy that there is " reasonable evidence that it(the solvent) vill not i
f contribute to the escape of the radioactive material, nor vill it cause
=igration of radioactive substances through the environment" is not coc-i vincing. Once the Dow Chemical solvent has bound the radioactive materials, i
we say le se all hope of keeping those substances isolated from the biosphere.
I have obtained information and suggestions from professors of geochemistry, l
physics, biophysics, biology, biochemistry and radiation oncology. Every one i
of them is as concerned about this experiment as I am. They have helped formulate (and explain) the questions that follow, and all believe that an environmental impact assessmsnt is imperative. To quote one of the men fron a letter dated March 9, 1979:
l "I
think it is unacceptable that the DOE assure you that their chelating pr.paration is environmentally scfe and, at the same time, refuse te divulge the nature of the material. We still know relatively little about the =ovement of radio nuclides in the environment, but there ic ir. creasing evidence that natural ligands cay contribute to the process.
I should think that one would need to take care that tha artificial ligands provided by Dev veuld not enhance the mobility of nuclides in the biosphere and result in their concencrition in the fooc chain."
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%.s tefore this sction is undertakan the public is entitled to the sesurance cbst
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physical and biological scientists who are not financially and/or emotionall)
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conmitted te this proj et will have studied questions similar te these which 49r
. allow, and vill have conclusive evidence tnat the proposec Dresden experimer.;
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cac be perfor=ed without jeopardizing the human environment. If not, the Q
- reject should not proceed.
j rirst, is it pessible that an environmental impact assessment and a ecg.tive declarati n have already evan vrit.or. regarding the proposal to
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6scontc=inate Dresden Unit One? I have esked this question several t ir. e r.
of the Dfr. but have not received an answer. If an assessment was made.
.ht:5 fndivicuals of the Department of Energy made the deci icn tht! this i
j;cject v'11 not affuct the quality of the human envirennent, anc tbcrc-
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