ML19345A984

Expresses Concern Re Environ Statement Re Proposed Decontamination of Facility.Deficiencies Should Be Removed Prior to Approval of Primary Coolant Sys Decontamination. Util Reserve Capacity Makes Facility Unnecessary

ML19345A984
Person / Time
Site:	Dresden
Issue date:	11/17/1980
From:	Frey D SASSAFRAS AUDUBON SOCIETY
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
NUDOCS 8011250537
Download: ML19345A984 (4)

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The SASSAFRAS AUDUDON SOCIETY s'

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ovember 17, 1930

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.1r. Darmll G. Eisenhut, Ddmetor Division of Licensirg U.S. :uclear Pegulatory Co:nission Nashington, D.C. 20555 rear Mr. Eisenhut:

Sassafras Audubon considers the cor. elusion of tra U.S. :Iuclear Pogulatory Co ds-sian (:iRC) on the propoced decontamination of Drasden 1 of _rpo simificant affect on 9.e nuality of the hitman ertironment, unaccactable and indarensible. Citizens and citizen groups have established in their cc ments on the :30's Ervircemental Stateront on Dmsden 1 that the decontamination project is an exterirent with sig-nificant unmsolved prob 2aas and unanswead questicns, deficieneies which should be mmoved prior to approval of decontarination of a prir.ary coolirg syste= of Dresden 1 or any nuclear power plant.

I The decision of Co==onwealth Edison (CECO) to postpore the scheduled mturn of Dmaden 1 to certice until 1986 so that it can concen, rate its financial msources on bringing its LaSalle Station on line, in fact, appara to recove the justifica-tion for the Dmaden 1 Decontamination Project. The CH:o postponement corroborates the arg2ments that CECO's larm omsent and ^:ture mserte areratir.c caracities, the lower than anticipated gmuth rates in peak de=and, and the untapped potential of conservation incentives, make Dmsden 1 sicolr not maded. A 3-year postponement will e=phasize the fact.

The :aC, in its discussion of per=anent shut down of Dmsden 1 (5-2, FES) ard in its response to Fn+11 L. Plant (ard others) on cost comparison of siternatives (8-4, FES) fails to consider the most salient facts bearirg on the question of whether Dresden 1 should be decontnm%ated and rehabilitated. or whether it should be decom-mis sioned: CECO's overcapacity which could mach SC5 by the =id-1980's, ard Dmsden l's poor design and structural degradation, low capacity factor (no more than 45%) etc.

At the very least, the decontamination of Dresden 1 should be shelved because of the low priority given it by CECO.

Sassafras Audubon sees no validity in the evaluation of the :2C that delayirg decontamination 5 years "would msult in, at test, a small savings in =an-m:s, or that "It might even asult in higher can-m= experditure than the h ndiate decontamination option, for the estimate of only 150-200 =an-u m:s is likely to be exceeded in the trial-rin of a decontn Nation project p_f_ this mamitude, while the decay of the isotopes during the dehy is certain.

!or should delayirg the decontamination of Dresden 1 for 5 years place significant c.co 1 8 0112 50 ff~[

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I costs on CECO. Slould it not be to CEd's advantage, since CECO does not want to spend morey on Dmsden 1 in the next 'few years,- to cancel its capatility to decontamirate i

on a 1-conth 2ead tira and " mothball" Dmaden 1 for the period in question?

A strong, if not absolute, possibility erists that the costs of adesigning Dresden 1, the. installation of mw syste=s, such as a high-pressure coolant syste=, and other mtmfitting to =ake it confom to post D!I-2 standards, cannot be justified in te=s j

of Dresden l's future potentic1. Particularly, if its powr is not reeded. The j.

decontamination of Dmoden 1 cannot be justified without a definite co==itt:nnt of

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CECO to bring Dresden 1 on lire again, with all that entails.

The 1=plications of an extended " wet layup" following chemical decontc=ination with mgards to reactor safety will becorn a moot point if deconta+2 tion is delayed and it becomes appamnt that Dresden 1 should be deco==issiored. I'avertheless, the public has been concerrod about " wet layup" ard the t"%; of decontamination mlative to whabilitation and opemtion. The NRC has infor=ed us in the FES that Mr. John 3.

'iecks will have considerable input into the "3eactor Safety E7aluation" to be issued separately frc= the FES, ard that his concerns in the 3rookhaven :~ational Laboratory l

Memorandun of April 16, 1979 am substant4,"y mduced.

'.le f d ' to understand why the " Safety Evaluation" of Dmoden l's decontaniration was not part of the ES since i

it is relevant to occupatioral exposum as well as the hu=an environ =ent beyond t'ro plant. Ilill the public have ample ti=e to mviou and co==ent on the Safety E7aluation Report prior to a decision by the NEC on the deconte 4 2 tion of Dmsden l?

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The :EC' acknowledges in the FES that 1) the buildup of radioactive corrosion products inside the piping and other components of the pri=ary cooling system and the upward j'

tend and absolute value of occucational exposum of workers at Dmsden 1 am si-i-lar to thoce at other mactors, and, 2) that a goal of Dmsden 1 decontamination is i

to "Davelop and prove the aliability of techniques which can subsegmntly be used on other mactors." The problem of contamiration and deconta=ination of nuclear i

mact-6 is a gemric problem and 3ould be addmssed in a sinde IIS sithat the

=agnitude of the problem and its consequences can be established.

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The Citizens for a Setter Environ =ent (C35) note the deficiency of the Draft EIS (A-44-45, FES) in that it fails to consider the disposal and transportation of all tFo vastes ;ererated in like deco =tnM :ations as we11 as other generic issues and concluded:

l "Hence, to fulf4ll the nMate of the National Fexiron= ental Policy l

Act (:! EPA) the 30 =ust prepare and circulate an IIS related to the chemical decontamination of light water, co=.arcial power, nuclear plants."

i The U.S. Imriron= ental Protection A ency (EPA) proposes that :

6 "the U.S. Nuclear Pogulatory Cc==ission ( :3C) prepare a generic IIS identifying the available waste tmatrent and disposal options for the eventual decontanination of other nuclear power mactors. This i

geraric EIS should also address the cumulative environ = ental impacts

.of the whole series of likely deconta:inations." (A.138, FES)

Peter !!antague, Dimetor, National Ca=paign for Radicactive ',laste Safety, masons that:

i "Either Dmsden doesn't reed deconta-4.ation because (with the excep-r

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s ticrof the ar.o=alous year,1975) it is ver/ close to the average

• of all DiR exposums, or alternatively, all L'iR's reed decontanimtion.

If the latter case is true, the Umsden decontamination is just the j

first step in a decontamination crocan ard the entire crocram should be the subject cf this DEIS." (page A-lCO, M)

The :!RC resconce to Mr. Montage (6-36) =isces the point of the reed for a program-eatic EIS for all L*.!R's.

The :20 response to CSE (6-19, 7ES), ignons the poidhat

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E!R's am ageing s ri',rly, causing inemaced occupational exposum, ard i= plies i

that Dresden 1 is different: "The decontamination of Dmsden 1 has been proposed to accomodate a specific situation that exists at Dresden 1 as a msult of tre ver/

difficult physical access afforded by the Dresden 1 design for insertice inspection and phnt specific modifications." Actually, Dresden l's "very difficult physical acceso for insertice inspeetion" only emphasizes why Desden 1 is a poomr candidate

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for decontamination than cost reactors, at least with the intent of bringing it on lire again.

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?urthor=om, the new mgulation being developed by the IIRC for low-level waste man-age ent,10 CFR 61, cannot be construed as a substitute for a prograrcatic IIS on deconta+ation of nuclear mactors with the diverse problems associated with the proce ss.

Sassafras audubon asks that a gereric EIS be prepamd on chemical deconto+ation of nuclear mactors and that the Gemric IIS assu e pracedence over decontWnation of Dmsden 1.

elith CECO's postporerent of mturning Omsden 1 to sertice, the :20 has a ple tire in which to prepam a Gercric IIS f n chemical decontamination of o

nuclear reactors.)

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j Sassafras Audubon, in their com ents on the LES, asked the 13C whetler 3eatty, :'evada, or Hanford, '.!ashington, had accepted msponsibility for disposal of Dresden 1 decon-tanination vastes, and why the matter was not firi d ed prior to ' issuance of the DES?

This question was not answad in the FES, the :30 only raiterating that the radio-i active vastes would be ahipped to a cor nreial low-level waste burial site such.a_q Seatty, l' vada, or Hanford, Uachington.

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The IEC responded to the Von Zellen CS ment (A-33) that both the Beatty and Hanford sites had denied burial of low-level radwaste fran Cocconwealth Ediaon in the past

/ ear or so, by noting that CECO was under contract with !uclear Engireering Corpora-tion (IEC) to dispece of solid radioactive waste.

The point is whether the State of :Tevada ard the State of '?ashington will approve disposal of chelated radioactive wastes from a commercial nuclear reactor located in the State of T1"nois? The position of citizens of the Stats of t?ashington seems clear, for they have voted to deny burial of co=rercial radwastes from other States after July 1981. Do the citize:.s of :' vada know that their State is targeted as a e

l rapositor/ for chelated radwastes from Dresden 1 ard probably other mactors? Am the citizens of T714nois willing to have the chelated wastes stored on site in l

1000 =ild steel 55-gallon drums with a' radiation 2evel frec each drum approxi=ately -

10 mes for any length of time?

i The 77'incis Safe Energy Alliance, who has been concerned that both 3eatty and Han-i ford will be closed in rasponse to public prassure, and that the chelated wastes

=ight be stomd in Nnois longer than desirable, was told by the 23C (S-30, 7ES):

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If the Hanford and Beatty disposal sites am closed for any :eason, the wastes.would have to be stored until alternative arrangements could be made (i.e. at a DCE arid disposal site)."

This answer does not inspi:e confidence. 2em is the DCE arid disposal site?

Sassafras audubon opposes the chemical decontamination of any comcercial melear l

mactor with chelates without an arid waste disposal site having been identified in i

advance which has the concurrence of the State ard its citizens in its use for the disposal of chalated radioactive wastes.

I7 On the question of pologic stability and cF" tic change, Sassafras Audubon was referred to the :30 response to 3anassak Co: cent A-19, page 3-10, a response to which we take enception. Soce of the radionuclides in the oxide layer at D:esden 1 and probably other :eactors am long-lived (Table 2.1, FES). The plasticity of the earth's 4

crust and the dyramics of cli= ate change nake the refrain "t'ro:e 's no hiding place 1

down he:n" ceen plausibla, particular3y for chelated wastes. Contrary to the sta+a-cent concerning glacial periods, "it is uncertain if even these events could al+2r the prasent arid envirorment into a M" d or tropical zone.", them were pluvial periods during the last glaciation in the arid and semi-arid uest.

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e disagree with the :30 msponse to Javid A. Crerar's co=ments on the alternative af physically or chemically degrading chelating agents after :eactor decontamina-tion and orio-M discosal,that even if the deactivation of chelates were feasible, deactivation would provide little additional protection to the health and safety of the public.(?-7, FES) l 2he :30 noted in their :esponse to Carar on the scre pamconcerning the degrading of chelates, that the Brookhaven :Tational laboratory had ihdicated that there wem no satisfactory methods for degradation of chelating agents, but, "There a:e how-ever, sore rethods which might, following ihrther developrent,. provide feasible degra-dntion processes."

4 Ue support the :ecocoendation of :-Ir. Cmrar that "2e:S data are unavailable programs should be undertaken to design and evaluate specific degradation procedures appli-cable to large-scale decontamination operations.", and ask that this be innleaented by the :aC and the msults of the program included in the Gereric ZES on chemical decontamination of concercial nuclear reactors.

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. 'Je should Mkn to :nceive a copy of the report on reactor safety considerations of the proposed Dresden 1 deconte%ation action when issued, and ask to be noti-fled of the Cc=nission's decision on the petition of the Citi:: ens for a Better h-vironment, and others, for a public hearing on the Dmsden 1 '(proposed) chemical decontanination action.

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q Tours sincerely,,

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Irs. David G. Fm y Ersrgy Policy Co-4ttee, Sassafras Audubon 2625 S. Seith Road Bloomington, Indiana 47401' 1

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