ML20041E385
| ML20041E385 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 03/02/1982 |
| From: | Chavez D DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE) |
| To: | COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 8203100452 | |
| Download: ML20041E385 (8) | |
Text
, .
. uuno coaRumme .
Sinnissippi Allianco for the Environmont m.M
326 North Avon Street l March 2, 1982 Rockford, Illinois 61103
'82 II:1.9 -8 p11 :21 UNITED S'TATES OF AMERICA r:
l7 D
NUCLEAR REGULATORY COMMISSION \
{ j.
N-BEFORE THE AIDMIC SAFETY AND LICENSING h B0E[ s%D (
I '
N/1? 9 1982 v.
In the Matter of )
)
\T3CS
\
g C COMMONWEALTH EDISON COMPANY ) (DocketNos.50454 I
)
(Byron Station, Units 1 and 2) )
X(D7QS0-455 DAARE/ SAFE SUPPLEMENTAL RESPONSE TO COMMON-WEALTH EDISON'S REQUEST FOR ADDITIONAL INFORMATION/ CONTENTION EIGHT In response to Edison's request for additional clarification of f acts underlying DAARE/ SAFE's Contentions, DAARE/ SAFE provides the fol-lowing information relating to Contention Eight. This response incorp-orates DAARE/ SAFE's previous responses to Commonwealth Edison and NRC Staff and spacifies, to the best of DAARE/ SAFE's ability, the specific facts, documents, and/or portions of documents which DAARE/ SAFE will
'ely upon as evidence for Contention.Eight. DAARE/ SAFE's clarification of it's "other contentions will be supplied as soon as~)ossible r ' ^ ~~
12 ,
DAARE/ SAFE has no intention of relying upon expert testimony to 4
support this Contention at this time. .
\ Upon written notification at least one week in advance, DAARE/ SAFE will arrange to have available for inspection and copying requested doc-uments in this response DAARE/ SAFE should be contacted care of: Mr.
Stanley Campbell, (815) 962-7373 for questions concerning this response..
O .
(1) j /
8203100452 820302 PDR ADOCK 05000454 -
G PDR
CONTENTION 8 l
Intervenors contend that Applicant does not meet the recuirements ,
of 10 C.F.R. Part 51.21 and 51.20(a), (1 and 2), (b), (c) be'cause no consideration is given the ~e,nvironmental impact of primary coolant system chemical decontamination and steam generator chemical ' cleaning which the Departman of Energy has determined will occur twice during the lifetime of a nuclear power plant. Recent data raise the possi-bility of serious adverse consequences of the decontamination process.
Chelating agenta, intended for the removal of highly radioactive corrosion products adherent to the coolant system surfaces, sharply increase the rate of migration 'of these same radioactive products throp3h the environment and into the food chain. No analysis or discussion is given possible biological consequences to the accidental .
spillage during decontamination, waste storage, transportation, or dis-posal (on or off-site) .
Central to the discussion of the Byron Station is NUREG-0686, The Final Environmental Statement Related to the Primary Cooling System Chemical Decontamination at Dresden Nuclear Power Station, Unit No. 1 NUREG-0686 reveals the applicant's commitment to chemical' decontamination with chelating agents, specifically the solvent NS-1 i
and an evaporatinD and polymerization-solidification process developed for the applicant by DOW Chemical Company with a Department of Energy grant. The comment section of NUREG-0686 exposes many of the unanswered environmental problems of the applicant's proposals.
l l
l
, _ . , _ _ _ _ . . _ , , - - - - - - - - - - - - - - ' - - ' - - - - - - ' - " - ' ~ ~ " - ~ ~ " - - - ' ' ' ' ' - ' ' ' - - - ' " - ' ~ " - -
. . 2d),
Cror wZ ascer aet 's 311cn w ce 4
'In c,cud r
comme m top c ntcnt i
nd fiv the Uni tcd S Dugui nt"to NU R C fcc il i e En e te rgy Re tates d (Scie n e E -0686 tate th rre the re strial sea c rh are c , Vol. 2 illustr in r and six the adioa De and pas t ctiv velopme commer 00) stat e: at rec eived .e wa cial nt inter adn le e md or ste bu v ls of r e iate-lev are rial Administr atio site adion el r currently sites w n s ha v c ul adioa nich e been ide ctiv rec have othe migr e r'than obs atio wa s
eiving low to erved n from ste . Va ry, So ORN L , in at four o West uth Ca clud rigina l rying o of the s d Chalk Valley, rN lina ; th ing the Savan e bu ispo sla ew Rive r n nha rial migr r fa Yo k; naedHa ford River sites ation cili ty in Ma x , Wash Labor of ingto a-Pu in pr bo le Ca a ey Flats n fa a
m.
e the dis n da ha , Ke cili xistence Actua l mi s e ntucky. ties; pi of so lved gr xperien o
mb fra e cd The ts hav atio n e been ction of simi la Max repoile Pu oc of le Pu, the r
nta c are ey Flats fc rted at minated a hate s , a pr eithe'r pr a il i le c nd esence at esent tie s, r e spe the Ha a hate s the Chalk Riv r or ct nfor d, We in wa e , We suspe ively. st ste The Val abov st cted Co ley, a o e impl Valley to be pr mplexing a nd ,
r le in ies ad n esent ge the co Ma x nts Riv ey Flats' in waste unexpe er, We,st mplexinggea ad n cted nts migr
. Savan Valley, ation play nh a
Riv ad n
of r a
n impo Max er. adws rtant ey Flats ste Han fo , in at ,
rd, Wa s hi addi Chalk ngto tion n- et one ORNL of the two
\
I I
,' *Pcg1 3 pecposed sites fer tha d: cant minated Drasdan redwnsto -
experienced plutonium migration. Does the proposed disposal at Beatty or Hanford mean the introduction of complexing agents to these sites? In view of the 14rge radioactive burden (4.3 x 106 C1) in place at commercial burial sites as of 1977, what vnrst case effect (e.g.100 year flood; earthquate) would result from the presence of NS-1 (solidified from an original 85,000 gallons) at either Beatty or Hanford (waste to aquifer distances 300' and 290' respectively) ? "
- 2. The composition of the crud to be cleaned from the primary cooling system and disposed of in the environment is. uncertain. NUREG-0686 neglects' the possibility of fuel rod cladding failure and the consequent presence of many long-lived fission products and much more radioactivity in the crud. Potential falittes of the Zircaloy cladding used in the Byron Station are examined l
in contention 6. The DOW waste processing process is limited to irradiated pipe and component corrosion, mainly CO-60 As the NRC states in NUREG-0686 Appendix, second page 5, "The longest lived significant isotope that will be solidified l after decontamination is co-60 with half-life of 5.2 years. Tests have been performed to demonstrate that the statility of the solid polymer will not substantially alter for over 50 years, corressonding to 10 half-lives .
of CD-60." But since the crud may contain fission products, actinides and corrosion products with longer half-lives than CO-60, the solidification. may i fail before the sctivity decreases. ,
- 3. No methods of physically, chemically cr biologically degrading chelated radioactive wastes have been developed. Although the wastes are so dangerous o
that their containment must be abaolute, the applicant's solidificatbn and isolation methods are only temporary. Before disposal, the complexed water soluble nature of decontamination vastes should be abolished and theib
- Pcg3 4 ,
uptake by organisma prevented. i The applicant's waste containment strategy has three basic elements:
(1) solidification in a polymer matrix, (2) disposal in an arid region, (3) !
l isolation from other wastes and populations. Points 4 through 7 consider t
some fundamental weaknesses of this plan.
- 4. DOW did not field test the leaching rate of the polymerized chelated radioactive wasta. DOW apparently didn't know the pH of the dump site soil and NUREG-0686 mentions only DOW 1eaching tests using domineralized water (NRC response, BUREG-0686, Page 8-13). " Leach. tests performed by DOW indicate that the cobalt-60 release is less than 1 percent in 70 days "
(NRC response NUREG-0686, Page 8-16)
- 5. .For leaching prevention, the applicant relies heavily on the arid condi-tions at the Hanford, Washington and Beatty, Nevada dump ~ sites.
A U.S. General Accounting Office report lists character-istics identified by earch scientists about America's low-level waste dumps frouwhich inadequate data have been collected, and "about which not enough is known to reason- -
ably predict the migration direction and rate (or radio-activity movement) or to determine whether reasonable predictions can be made." Major information lacking about the Hanford site includes: " rate of infiltration (the amount of water that is not evaporated or transpired and is free to move downward), rate and direction of ground water movement, and interconnection between shallow and deep aquifers." The data needed for the Beatty site include:
'Yate of infiltration, and direction and rate of ground water movement." (" Improvements Needed in the Land Disposal' of Radioactive Wastes -- A Problem of Centuries," RED-76-54
-e .-- - - ~ , . - , - . - . - - - . - ,- ,_ . , . - - . - - , - - , - - - - - - , . - . . - - - --
' Pace 5 January 12, 1976 pp. 13 and 45 46.) I NUEG-0686 section 4.2 3 on diseosal gives only, sketchy, incomplete climatic'and hydrologic site information.
Omitted is the probability of a fissh flood occurring at the dump sites during the period the chelsting agents remain active.
- 6. Will chelated decontamination vaste interact with other weste at Hanford or Beatty?
High
.Most nuclear dump ~ here and in Canada, have had wasta leaks and seepage.
level liquid wastes. have leaked at Hanford. They contain xylene and tuolene, Further, NUEG-0686, solvents for the DClf vinyl-ester-sturene solidifying agent.
section 4.2.3 states: "that solidified vaste be segregated from 4ther vaste by a minimum of 10 ft. of soil" . High level wastes have leaked further than this before. The possible contact of high level liquid wastes and a chelating agent -
set the stage for a large secle environmental disaster in the ev'ent of a flash flood at one of the dumn sites, i
EFA recommends 'a generic environmental impact statement on vaste treatment,and
- 7 '
disposal. (NUEG-0686, page 8 45) What is the total anticipated chelsted~ waste production for Byron and all other, nuclear power stations? How can this total be managed to provide the most effective treatment and safest disposalt
- 8. Will decontamination solvents weaken or corrode critics 1 plant ecmponents leading to a nuclect accident?
Cris~ of the bases of ublic concem over the decontamination has been the tossibility of damaging the reactor and thus The NEC has precipitating a major accident in the futuns.
ignored the concerns of the public as well as of government scientists. In particular, a memo from John 'feeks (h/16/W) .
at Brookhaven Nations 1 Laboratories (BNL) expressed concern that sirnifiennt pmounts of NS-1 solvent might be trapped in creviced areas nround bolts or in creviced rockets formed by galvanic corrosion near defects of the vessel clad.
Fage 6 The vater rinse cycles could easily fail to remove such trapped solvents. The longer the solvent remains, the 'more corrosion t i
i becomes significant.
"These concerns were iniiially raised by studies done by DOR and GE on vorious steel types found in the reactor. Those studies retorted that type '410 steel which is used in a number of bolts and valves in the core support system is susceptible to corrosion undair certain conditions. The BNL memo said that such conditions '
could readily exist in. the reactor especially if there 'is an extended period between the decontamination and start up.
(C3E comment, ITJF2G-0686 page AJ9)
- 9. Accortling to the DresdenMecontamination Draft EIS, appendix page 15. the Electric Power Research Institute is sponsoring research by Battelle Northwest to develop "a weaker but more frequent decontaminstion process on line". Thi's suggests a^ continuous vaste problem adding more and more chelating agents to the environment, processing imanse quantities of contaminated cooling water, and a greater corrosion problem.
O e e
a S
4 0
i 9
- - , - - - - _ , , - - - , - , , e.--,---n- , - , - , . , , , - - , , - - - - - ~ - - - , - - - , - - ,
s, .
- I This response was compiled by the following members of DAARE/ SAFE:
Richard Bunch , ,
Diane Chavez
- Mark Eckblad The undersigned, a member of DAARE/ SAFE, certifies that on this date she served a copy of this " Response" on each member of the Service List by United States regular mail, Special Delivery, or by other means as appropriate.
Date: March 2, 1982 /
lAML }UtA Diane Chavez 7,
- - SERVICE LIST Alan Bielawski Marshall E. Miller, E'sq'.,
Isham, Lincoln & Beale
~
Chairman Admin. Judge One First National Plaza Atomic Safety and Licens-42nd Floor ing Board Chicago, II. 60603 U.S. Nuclear Regulatory Comm.
Washington, D.C. 20555 Mi t zi Young Steven C. Goldberg Dr. Richard F. Cole Office of Executive Counsel Administrative Judge U.S. Regulatory Comm. Atomic Safety and Licens-Washingtan, D.C. 20555 ing Board U.S. Nuclear Regulatory Comm.
Myron Cherry Washington, D.C. 20555 Cherry & Flynn Suite 3700 Dr. A. Dixon Callihan Three First National Plaza' Administrative Judge Chicago, II. 60602 Union Carbide Corporation P.O. Box Y Dr. Bruce von Zellen Oak Ridge, Tenn. 37830 Department of Biological Sciences Northern Illinois University Docketing and Service Sect.
DeKalb, II. 61107 Office of the Secretary .
U.S. Nuclear Regulatory Comm. l Mrs. Phillip B. Johnson Wa'shington, D.C. 20555 1907 Stratford Lane Rockford, 11. 61107 Region III (
U.S. Nuclear Regulatory Comm.
Office of Inspection and Inforcement 799 Roosevelt Rd.
Glen Ellyn, II. 60137
- , -