ML20044B723
| ML20044B723 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/14/1980 |
| From: | Malsch M NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | |
| Shared Package | |
| ML19290F683 | List: |
| References | |
| FOIA-92-436 SECY-A-80-101, NUDOCS 9303030238 | |
| Download: ML20044B723 (60) | |
Text
-.
e.
6 UNITIO ITAT13 NL60LEAM RE3ULAToRY C07AufssioN SECY-A-E0-101_
July 14,1950 ADJUDICATORY ITEM COMMISS!ONER ACTION g:
The Commissioners From:
Martin G. Malsch Deputy General Counsel DIRECTOR'S OPJ.NT IN PART AND DENIAL IN PART
Subject:
OF 2 pt:6 RELIEF (IN THE MATTER OF COMMOA'EALTH
~~
EDISON COMPANY)
Tacility:
Dresden Nuclear Pcwer Station, Unit No.1.
Purpose:
To inform the Commission of the grant of a request that the h?.C prepare a env.'ronmental inact statement for the proposed decontamina-tien of part of this f acility and of the denial of a request for public hearings on the proposed i
decontaninaticn.
Reviev Time i
Expires:
August 1,1980 (as previously extended).-
J Discussion:
This is to infor: you that the Director, Nuclear Reactor Regulation har granted two. petitions requesting the N?.C to pre;'are an environmental impact state:ent for the proposed chemical decontamination of the primary cooling system for this facility and-denied a request for publiy b arings on the proposed decontamina-
/
tion.
i
- i..>
I i
i a!x:t::n in iMs rc:cd ws s:e:d
.n 3:::d:::: c.ith N frai1:! nk:matica ict, enmp*:cr,s I ___J__
j TOW f2 - N l
4
Contact:
Sheldon L. Trubatch, 000 634-3224 i
- ^
?
)
9303d3d238 921125 ~
)
/, l GILINSK92-436 PDR
i i
2
~
On December 19, 197t, Comacnwealth Edison Com-pany proposed to decontaminate the primary cooling system of this facility.
The NRC staff issued a Safety Evaluation and conditional authorization to initiate the proposed action on December 9, 1975.
Subsequently, three petitions wer e filed regarding the environmen-tal impacts of the proposed decontamination.
Two of these petitions, one from Ms. Kay Drey
[ Attachment 1] (dated March 19, 1979) and one from Mr. Robert Goldsmith [ Attachment 2) (dated March 13, 1980) requested the NRC to prepare an r
environmental impact statement ftr the propcsed.
d e c ont amina t ion. 1/
The third petition frcm-Ms. Marilyn Shineflug 2/ (dated September 20, 1979) requested a public hear'ng based on the Jack of assurance that the NRC ueuld issue an environnental impact statement.
[ Attachment 33 On June 26, 1980, the Director granted the requests for NRC preparation of an environmental impac; state =ent and enclosed copies of that statement with his replies to the petitioners.
[ Attach =ent 43 Moreover, the Director responded i
to several technical questions raised by Ms. Drey and Ms. Shineflug regarding various aspects of the proposed decontamination and subsequent disposal of the resulttnt radioactive wastes. 1/
The Director denied the request for public hear-ings because an impact statement had been prepared.
Although the Director found that the proposed action would not significantly affect the quality of the human environment, he decided to prepare an environmental impact statement because of significant interest and concern expressed by members of the publi with regard to the proposed f9/, f[
decontamination. E/l i
1/
Mr. Goldsmith's petition was filed on behalf of Citizens for
~
Better Environment and the Frairie Alliance, i
2/
Ms. Shineflug's petition was filed on behalf of the Illinois Safe Energy Alliance.
1/
The questions and answers are also contained in the environ-mental impact statement.
1/
In view of the fact thataninpactstatementwasprepared/
j s i r.
\\
-s 1
3 1
~~s tec : ~
wy GJ c>
l J
7 Y
~
r I
/
Finally,'
In deciding among alternatives to the propoTed program, staff state.d that no alternative is obvioucy superioc.
The "obvi-ously superior" standard was c sloped for choosing among alternative reactor sites, and its use is supported by NEP A ealities arguably
/
unicue to that choice. 5/ /
p-
$^Y l Recom=endetion:
~
i.
l,I.,
- l
~
Martin O. Malsch Deputy General Counsel Attachments as stated ff 5 NRC 503, 528-30 (1977).
l
, w.af 4
Conmissioners' ccaments should be pro ded directly to the Office of the Secretary by c.o.b. Tuesday, July 29, 1980 Commission Staff Office conrents, if any, should be submitted to the Conmissioners NLT July 22, 1980, with an information copy to the Office of the Secretary.
If the paper is of such a nature thLc it requires additional time for analyt':a' review and comi,ent, the Conmissioners and i
tre Secretariat should be, apprised of when concents may be expected.
l i
Dis tributior, Conrissiorers Conmission Staf' C'fices EDO Secretariat
]
e e
l k
l
i w.
?
t I
1 i
?
t 4
?
I ri l
L i
1 h
il e
(
l e
d ATTACHMENT 1 f
J t
u b
w O
F 1
+
l d
d i
I 1
s 1
h I
J d
W 11 4
i 1
O f
D.-)4
.?**.
515 Wes: reint Avenuo f
~
s Univers a ty City, Kis ouri 63130 March 30,1979
,M To:
U.S. Department of Energy e
Secretary James Schissinger Assistant Secretary for Environment Ruth Clusen Generel Counsel Lynn R. Coleman U.S. Nelear Regulatory Cw.ission Cheira.an Joseph M. Hendrie Ccarissioners Victor Gilinsky, Fichard T. Kennedy, Peter A. Bradford, ard John T. Abestne Osnerel Counsel Lecnerd Bickwit
.l Trta: Key Dny l
r This letter is being submitted as a fermal request that an environmental j
1.+ pact states ent be propered on the propesad U.S. Copertment of Energy chemical decontaminet'
'.1 a m p e rir.a r.t a t the Cemsn-eelth Edison Dresden 1
Oclear Po.or Plant, Unit One - or et least, an environmental assessrent.
l I believe that en analysis of questione perhaps similar to those listed in the enciesed letter of March 19, 1979, are essentiel in order to deterwine whether this proposed federal action -ill have a significant impact on the beslth and safety of the homen enviranaent. I undsrstand j
such envirc#cental reviews are requirsd under the National Environmental j
Policy Act of 1970, se in::Ismonted by 40 CTR F'ests 1500 through 1508 l
(fsderal Register, Novenbar 29,1978, Vol. 43, 4. 230, p. 55978).
Ibank you, i
I l
1 e
e
_4G;Jd'
.I I
19 March 1911 p
(
f To.
preesde.t Jis.r Ca,ter. and,. Me,s,e. cewil.s Coe tle (
.inis t r eio,.
Invirossental Preteetion agency). Jacob tuselle(Chairsan. 1111eele fellutten Coctrol teard). Joseph Randria(Chairnas. Fwelear Regulatory Cemetseise). Charles Percy(U.S. Janeter frea 111tnote). James schlesinger
[
(Settetary. repertment of Irergy). W1111ae Icett(Attorney Ceneral of 1111eele). Adlai Steveesen(U.S. seester free 111tnote). James Theepsen (Goverser of 1111eete), and Charles Wa r r en (Chairma n. Fresident's Cowecil en tavtreneental Quality)
Tross 147 Drey. $15 Vest point Avenue. Univoretty City. Misseert 63I10 I
/A FLIA FCI
't IPV110PMENTAL IEFACT STATINIMT 05 A MAJCR FIDgtAL ACTICH pro.
PC8tD Tot 1 *1 SptlpG. 1979 1M ILL1W013:
I
- he C.5 tapairment of Enetty to presently centributing 58.2 elllies of decout seina t tes empe risents des tgesd te toward a e fitet of e eartes o b dissolve m
' ash out radioactive corrosics products free cuclear
.. esters. *i Aarti o r June (?). 85.000 gallees of a proprietary Cow 1[
Chesica.
aivgat are to be fluehod through an estiested five sales of p
r i p1Fing fe ICL hewra withis our estion't eldset active cessercial 4jf/
r e a c t o r t w..= : r w e a *. t h Edison's 100-meta att *resden e'
- t. Colt Cee.
y caer Morris see Joltet. 1111aste. ce the tatkabee B..
d i
/This selvent say be chemically stellar to, even identical with, thj
{wo_v teoreweda which have been found to be esve!(g. the uPerpectodf j,
reSta sitrafice of r _a d i o n w c 11 d e s out of tas Cat fidge twrnal trencase j
r tote the husan food thats.
kase poeesb17 its cista conta1ced is a letter I retelved last meeth from the Coperteest of j [
j teergy that there le "resseeable evidence that it (the selvent) will eat sentribute to the escape of the radioactive satorial, set will it caves
!f
.ebetances through the enviteesses" ta not ces*
vincing. Once the Cow Chemical selvest has sound the redtesttive meteriale.
g I migrettee of radioective we any 1cee all hope of keepteg thoes substaeces isolated free the bleepbers.
- l[
d ud 1 have obtstead toformation and suggaettens free professere of geochemistry.
-lfi phyetce, stopb?sica, btolwgy, biocheelstry and ractaties encology. Every one j
of then is se costerned ateut this empertaept as 1 as. Thev have talped
?
formulatefaed esplais) the tweetices that follev, and all believe that
'l as envirstsental topact assesesent le'teperative. To tuote one of the een j
free a letter dated March 9 19ffs
- ! think it is unecceptable that tEs DCE as sure'you that their chelat ing j'
preparettes la environeestally este and. at the asse time, refuse te r
diev1ge the eature ef the seterial. We ets11 know relatively little f,
L I
abcut the sevesent of redte euclides le the eevironeest, but there is lacrasetsg evidence chac satural 11 geode say contribute to the erstees.
1 I shestd thist that one way1d ased te take care that tbs artificial
~
the settlity of euclidae it s
ligende provided by Cow would met schaece the bloeitere aed raeult is their concentratise is the feed sbate."
l lafers thle acties le vedertaken the public le scritled to the assurance that fissocially sed /or testionally physical sad bielegicel actestiets whc are set consisted to this project will have studied questises sistler to three wktch fellow. and will have scaclosive evidence abas the proposed Dresden esportgest tas be performed wittout jeopardisang the bases seviroesent. If set, the d
j project steeld est proceed.
1.
First. le it possible abet es on.;r.r.estal tspart ast:sstest and a megattes declarsties have already been writtee regardtag the proposal to deceet amina te tre edas Unit Cos? ! bave saked this tweetten several tisse el the 301. but bava set received as seewer, If en assesseest =se eade.
whist individweis of the Department of Isergy sede the decastem stat shis projact will set affect the quality of the horas env1rsement. and there.
'f<
fore did set require sa entireesental Sapact state est utt.ar 60 Cf1 11:C*
sase by the DCE. sad if se, by whee sad Tbst is, was a negative declarstfee wksaf to a copy available? Cid it addresa the f ollowin g guestisse ?:
2.
What de field er laboratory taste demenetrate to be the e1 gratias potential of radioastsee was t a s ent rapped is the Osw Chasical selvest, assusteg este were to escape free buried sostalters (ste the saviransent?
is -frieett. Tel. 200 30 Jose 1973. by Ateerding to se article publishedJames ).gvas. chelsessg agents mere fswad Jeffrey Messe. David Crerar and outstences respons1%1e for the settlirsties of radissocities to be the very i
...~,-
.g.
free disposal pire and treachee la the Oak Ridge Mattesal Laboratory. In a per essel comeue1 cat ion free Dr. Crerer. the soviressental 1sp!!c e t t ene are describe 1 as follows:
{
"While chelates are used because of their power f ul se ta 4-binding propertise. It to this ease cha racteristic which say have vedesireble estireescate1 ceasegue, aces. For sesople. EDTA. which to used la l
Se causteg the aigrattee of esse ggeleardecentamisattomoperattene.lat e rmedia te-level 11guld wa s te dis posal pit e eed trenches Ce free la the Oak Ridge satiemal Laboratory burial grounds. Because it forse estremely strees complenes with tore earthe and actinides.
EDTA sed sistler cheletes say also be contributleg to sob 111 sat.se of these radteau T *.dce f ree warteus terrestial radleestiva vaste diesessi estee 6,ved the country. 1DTA to relatively resistant to desespeetties b; redsstion, therse11y stable up to eneut 1C0-230' C.
f and rather'alewij blodegradable. Consetweetly. it le paraistoat is the envireesse*, ledeed, the presence of attnificant concentracione of 1DTA in 12 to 15 year old radteoctive waste at CRWL esteste te its perelatence. Tbstefore, wherever IDTA and etsilar centounde have bees 1stroduced into the estural environsent. the atueous traceport of traesitten metale, rare earthe. and traesuransce, shtth c ha r a ct e r-(
1stically fore the most stable complease with chelat es, will be
.4pected to ectur.
I tagradotten rates of all three c hela t es (MTA. 1DTA. and CTPA) *. s e set rapid onewgn. even under ideal laboratory tendittens. to preclude I
senters about their rolease to the enviroenest. Reavy sete1 l
esbilisattee ces occur at extremely low chelate contentretiene, as witnessed at CENL. 31cdegradation. if elow or incomplete, esy be se inadaquats barrier to their various undesirable enviressettal comeetuences. Cestructies of chelates by thereal er chealcal sease (such as steestion) prior to environmental discharge appears to be such more efficient than biedegradaties af ter discharge."
3 For how easy years base radioactive corresten products, boeded with the proposed Dew Chemical selvente, resateed free of water after betag solidified by the tow Chemical polymer procese?
According to tow Chestral's publicatica entitled "So!!dificaties frecess for Low-Level Radioactive Vastas". (Fors Me. 173-1016-ft), caly a few descriptions of the s o l i d i f i c a t ie's process, which 1 sederstand to to be used for the Dresdes wastes, e r,e int!vded:
"The Dev felidificettes procese esmeiste of ste testiesties of e blader -- a se :af t ed v tay1 e s t e r re s t e -~ uit b esall assusta of a catalyst ses a promoter. The procese estepeulates the lev-level radioac tive was t es isto a stable. solid and homogeesous matris.
The Frecese. usteg polymer cheelstry, dictates that it svor solidify stueeus and elurry wastes. tecludieg tes aschange reatne, evaporator
/
bottsas, opset dessetaminaties celutteas, and filter aludges.
The ew precaps es11diftas radiasettve weets with se free liquid.
... The tov definities of ' free liquid' to 11guld se er es tbs spectnes er is tLe container spea completten rf se11dificaties or after 3-7 days of aging."
a.
See the Dow se11dificettes process been tested en rescler correstes products comparable to these vbith will result free the Dresdea esperisest? What assurasse le there that the ame capsulated waste is geleg to be low-levelf I
b.
Whee did tow Cheetcal first develop its es11dificaties process for low-level radiesctive wastes!
- hat le the lentest f u r a t t e r.
persed f o r se e o f s t e "sene11t he" o r sat rine s -- t ha t i s. h e v.
p-hee such a solidified Dew substasse ressieed free of liquid?
Ubat would be the long-ters. stability of the se114 polyser ever a persed of thoussade of years?
e.
Vtat le the lestb rate of the polymer under burial condittens. dr the potential for diffusion and release of setspeulated radis*
suglifes. selvente, etc.?
. VV-J
.}.
d.
During ths evaporatten step. is the solvent volatile. and if as, will as les eschange resta completely scrub chelated radionuclides from the evepotate? (I as told by one person that his espertance 1sdicatee it vill not).
6.
For how easy peere have the terrels designed for burytag the seltdified wastes been found to roasta resisteet to corresten from both the proposed coetente and from outrounding envitenmental tapactef a.
Accordtag to a letter I received free Mr. Paul Festit(tight Water teactor section, Divistoa of Nuclear power Developeest. DOE) dated February 6, 1979, the se1141fted wastes free the Dresdee espertaeot are to be shipped is drums to a cessercist low-level weste disposal sit e.
51mes addittees! wastes are as longer being accepted at the esarty Sheffield. 1111 meta tuttal ette(1s fact, the licensee has just welled awav. with the NoC is het purevit),
will tte westes he shipped to sevede. tooth Carelles, or Vash-Logton? Vere the druse designed to comply with the Departaett of Transpor etten*e packagint and shipping regulettens for low-level er high-;evel wastes (69 Cft Parts 170-178). er to cessly with the NRC transit retulattens for fissile astertala(10 Cf1 !! and 71)? And/or wate the dewee destined for indefinite burial?
b.
Jhat le the settssted lifespan of the barrele? What precautlose 9
o are going to be tekee at the life-end of the barrels to ensure conticued coetainment of the residual r&dioactivity? Rave any estale been found that will resist the corrosive acties of the proposed contents for even a dotade? Is there ap. to be any che-tesi reaction between the compounds gotas late the barrels and the esteriale of wh1ch the barrele are cetposed?
e.
In the Juse 30 1978 5eteece article. Dr Crerer and celleagses describe the accelerates etstersal through the groundammar and j
the Secreased optake by vegetetten of the fasionuclides when bonded to acebtodestadable chelates. If the buried drums with the r.olidified Dresden affluent were to corrode and tbs estria d'
were to coes into cen**ct with water, would the redtesuclide.
chelate comptes set becsas soluble agala? Cauld this soluties
]
than atgrote through the en,troenent is the e s.s e manner found at the Cak Ridge buriel ette?
I d.
If chelates are to be used, esa ther ta deactivated therselly, y
cheatc a !!y. er biologically bofore evaporation and ee1141ftsattes?,
3.
Is it possible stat say of the selvent with or without diess;ved redie-autlidea may *esale after the pristipal effluent and first rinse water have been ressved for evaporaties and solidificatica== and then be flushed late the 1111este tiver! If es. alght the radiomuc11 des absorbed by the river's sedleset osar the plast's coolleg water outf all to yeare
.e e s e becese resuspended and s1grote late the feed chataf are aspected e.
Eev auch radioactivity and reeldual chelattag agent in the first r!ssef Row easy addictesal riasse will there be?
Scientiste have told es that they did set think that stelated, radteactive estal lose would be resoved by a desinara11rer:
although desteeralisere have a high afflaity for asked metal less, I have bees laterned that eney generally de not renews chelsted forse. Cr will the chelettsg agsat perhaps le charged.
6 and thereby be resevable by the d estee re11s te g e t st? Fesple with whos I have spokes sees surprised te lasra that *be puriflestise of the first tisse.. the reseval of the reeldval chelattog agente.
and.neleted metal fees -- was to be done with a desimera11ser.
What le the esplanaties for thle apparest departure fren traditiesel practice!
b.
Actording to Mr. Festit's les:er of Tettuary 4 1979. "the f orsv14tsee af abe Dew Chemical solveet is *. sews se Det staff.
Det la grotested fres release to :he public by a propstetary agressent." Selesets used for decentaminatten purpeees et suelear facilitise have been described else6here, he sver ly CVlie
f'
.o.
DCf. Dow and Cossemwaalth (disse representatives ss salag that is. a
- thalating agente" (proeeunted key-lay-ting) chasical compo.nd(typically orgetic) rapatte of formint clav11ke e61ttpls tends with a metal tom. Ty)1celly these agente are also non-taritating to skin or ayes, a charactetterle of the solvent which Mr. Fetttt haspened to saattoa.
L asevelas the coeposeste of the solvent fit the delimitten of a shelattag agent. is there say like!! hood that thers will be eesugh reatdwel after the primary effluent end first rinse vetor have been removed. that some right be f1webed late the 1111aele River slots with future to, tite releases of the coolant water? (The coolaat-water discharge canal emettes into the i
p Illisets tiver at the confluence of the Das plaines and tankakee 115ere at 1111mota River Mile 111.6). Row tightly dose the solvent g
need metale! That is. if acee were tr pese through the sedisent
,h l
esar the cans 1's disc >arge icint. sight it 1each out sdditional radiensc11 des which have accumulated in the sediment meer the 1
entfall? Or if it it a relatively weak agent. sight the sediaante f
l attract redt-active natals out of the chelate soluttoe. thereby p
secroselng the amourt of radioeuclidee in the sadlaent and the' 0
3 potential ist further centseleat1om of the toothee? (The EFA
]
taport entitled " Radiological !wrveillance studies at e Su1*ing k
V4 ter Nuclest power teactor". L t.N / D E R 70-1 descelbes the contents
~
of the Dresden Celt Ces 11guld waste affluents during tests is l b 1967 see tytt. Two later cespacion studies at reactore to U
Massachvasettes and Comnecticut describe the significance of f
the conconerstana of radionuc1t(ee in the sediments).
4 a
e.
V>at will ne the tasses of the solvent de the future esf a operstica of the
- f Dresses plast?
g s
b4 f
atettele, by according to the bock. Da,ege jus Froperttee of Todustrial w
fI M. Irving fan. published _ la 1*63:
h.L "Das f&1 lacy is the initial cencept of stainiees steel or other
'ispervious' s os t is c e s
- e
- het they are trvty layervtsus. Tbio has 1 J been shows to to false. Statalees steel after one vigorous cleaning 4 j is fomed to toterie. ate in that etre and sore esterial say to p
atoerbed er adsortes and retained on the surface. Succ ess tve cleaalege j i have been found te necess sore difficwit and to retwire more l [
vigorous sethode ef decostseinattom." (p. 149) l 4
s.
I vederstaed that the NRC to responettle for sektes c$rtais that
[
this prejstt will est cenereaise the 1stegrity of tbs teatter 1
vessel and its parts. What sesuraecas. hovaver. does either i
the stC or the DOE have that thle sesolve cleantes effort will est 1streses the surface fauttag of the reacter system in the 1
{
future, rauste3 an accelersties la the buildup of crvd la its e
I many seeks, craentes and blied holes? Vill even stranger chelatlag aseets he esaded et Dresdes Colt Des for futwre decostasiasties efforte. assuntag the statelses steel properties quoted above free the las teek are correct?
i b.
Could se accelerettes is the rat e of t s11 der of c rud after the
. l desentamisatten project increase the poteRE1A1 for pipe tracklog er rupture? And sise Secrease the radiaties hasarse te verkers?
7.
What asserseras are there that the see who participate la the Dresden dersetselaattee esperlaset v111 mot suffer fres aspesure to the scalisaties of the selvent aed the radioactive =storials swapended is the esivset id q
either the aqueous at gasseus fores?
C o. e o f the peselhis respece 1er the i t. c r e a s e d inctlante of lev'at:ta end I
cancer at portateuth and other saval shipyarde vetch Dre. Thetas Salertaa
~N and Theodore Caltaa samties le thats tartunication published in the teacet.
May 1). 1978, le thatJ "Daher factero(asteetes, onestag. indvetrial voirects) say have interacted synergistically with radiation to cause s e t s s e a t h e f re a" c a r.c e r a nd leukseta ihan tsdistice alsne vovld have caused." (a:phasis adled). 1 realisa that one of the prizary resesas for j
tryle* to dersley at effective decostas'sstica process is to reduce the e scasslaties af gagra-seit tleg te rree tes prodvets which to t.re sawee high redistles fielfs withis aparettog ecclear power pisoss. and stereif me:essitate the hielsg sf estesetve sustere of repois and taintenasse
.e*e r
w n
I..<
.s.
h J,,
j
- ~
k1 a.
According to a letter dated March 13 1971 from Mr.
A. David 2
Rossin(Systes Nuclear Research tasineer. Csesonwealth id1*en),
q'.
thirty workere will be needed during the presently proposed ICC-hour project. And although I was told by Mr. Paul Pettit g j of the DOE that his agency to not concerned about the temicity g
1 j
of the Dew selvent itself during the decentamine t ten ev e rsties.
w.J
{j.
what hasorde say it pose to workers when it to la teeltaattaa l'.
vith resteactive materiale?
b.
What procedures are to be takes to aske certata that the radienuclida-cbelattag agent to totally contained and will l
not in fact cess la contawt with the workerst What le the J
i f
radiation dear expected per hour at ene meter from the reactor cener.nasnt veteel. the effluent piping, the evaporaties a
and seltitficaties equipacet. and the druse preparatory to d
and during shipping.? Wh*C Pielding will be tracted to protect the '(
[
I workers?
a,e.vestions of,rofound ta,ori. re,coceed.ith the Dresde. e sort.ent t
f
( ne s e while they resala unseswored would be alregious folly. Tcf the safety of
- I i
the public and the workers, and for the protection of our country, can we
{ count sa rev to desacd that a full environtental tapact statement be prepared 7
[
4
\\ tamediately?
l l
m
\\
i.I &
i
\\
l D
I E
', 5 V
U m
m.
Ve t' 1
u, 1 g
/
l
_s 4
h t
I l
?"
e 5
i
. i ll 8
a a.
g k-t h
t t
y b
4 v
h I
ATTACFFIh"r 2
.e i
h s
?
4
.~
. a r
=
)
I 5
i F
P a
t i
)
I e
?
e
~
c2u-s r
Mu CiI khb f
March 19, 1980 Mr. Harold Denton 34 Director of Nuclear Reacter Regulation yl
}
U.S. Nuclear Regulatory Comission Washington, D.C.
20555 r
Dear Mr. Denton:
A petition by Kay Drey dated March 19, 1979, requesting that an Environ-nental Imoact Statement be prepared on the proposed decontamination of Dresden Unit I, was treated as a request for action under 10 CFR 2.206 i
(44 Fed. Reg. 22529). Under subsection (b) of 2.206, the Nuclear Regulatory Comissicn (NRC) must decide "within a reasonable time after i
a request" whether to act on that r(quest or not.
To date, neither Kay Drey nor Citizens for a Better Environrent (CBE) are aware of a l
response to Mrs. Drey's petition.
In lish of the delay since Mrs. Drey's petition, and to emhasize the serious need for an Environmental Impact State:ent, CBE has filed a petition, dated March 13. 1980, reques t.ing that an Er.sironrental Impact Staterent be prepared on the proposed l
decontamination of Dresden Unit I and that the decontanination be stayed until the Statement is prepared. With regard to these two petitions and the preposed decontamination, we have several questions to which we i
would appreciate your response.
1.
When will the NRC respond te Kay Drey's petition?
f 2.a.
If no Environcental Impset Statement is prepared, will the NRC publish an environrental appraisal?
If so, when?
b.
If an environ:: ental appraisal or negative declaration is j
issued, will there be a public coment period?
If so, when?
3.
If the NRC decides not to prepare an Environmental Impact Staterent, will Comonwealth Edison Comany (and/or a subsidiary) be immediately authorized to go ahead with the decontamination precedure?
If not imediately authorized, when can Edison begin the procedure?
4.
Under what specific regulation is the MRC acting with regard to the decontamination?
5.
Does the proposed decontamination at Dresden ! require a proceeding to mvise, rodify or arend Edison's license?
We would appreciate answers to these questions as soon as possible, G
l
...~.n.
.. u._ r.m 1
hM4 t;, :
page 2
, u.:. -
1 I
I prt'cularly because of Edison's public position tost the decontar.irsticn p.:- 9;re will begin en April 1. 19T;0.
1 l
Sie.. c,l y.
4 f1
. / ~. / i i sis'
{
-[,,. /. -[:..r.h? % ~
i T'
.t.'old,.ith
- L *. '
- y for C;iirons for a Setter Environe.ent Ed ?:.irie Alliance 59 E. */:n 3.;ren Street si A 1(C3 C'.i. o. IL 65605 314;'e19-1 E 33
'.*. Th N sdrie Chaire.6n. Nuclear Regulatory Cornission cc:
- 2] ::cy
' :o n.%kuler. Assistant Attorr.ey General. State of Illinois
":rdil R<.ed. Coman ealth Ediscn Cor.pany
' 2'ide Alliance
~
6 9
e l
l e
e e
. fc.2G.8**
a 13.*.aich 19PO
.. M L
.f!:'l Uil S:
E.1c. ed please fired The pr. TIT 10'4 FOR A!i E'.*/lF.0'e'E';7At IP. !.CT P.i : i'iT I.*e I ;). A 5 ;Y filed with the U.S. Departr:ent of Er.crey and t'.o U.S.
'b-
.' 2rE;' *:ry C.v.its i r. by Citi:t :s for a 2etter Er.vi. c".; :r.t and 'r.i-e i: /,11 a e.
Atto.cred is a list of pcrties to who. copics of tr.!s p.ti-
. led.
c s
J Sincerely.
\\
a -
N/./
.r d..'
I Rotscrt Goldsreith
~
Attorney for Fetit13aers 6
e 9
4 b
r i
~
e.rge:3W* " -
cc ;./rN1c:vres:
- ;'r Jor i W. D. cre.
Cirector, Tc:Fnical Assessnent Ishe :, I f r.:ch & f eel:
Civision
.. c. % rs 4: Law Of fice of Radi. tion Prcgrt: s
." e T i. st ':a:1o".i1 ?1a:h, : r.d F1oor
{Ll: ' 59)
't.ferg.+, Illinois 6C603 U. S. Enviror. entel Frctect 'en l g e r.cy "r.
?. i. ft:;3e s:i Cr s t 21 ".411 /2 21:. :., r. -t r *e nt A-is ;t:n, Vir gir.ia 2;;60
- 7.. :. :
. : t r ' o. t r 5 : s t io n
- '. :1 T
..e el U. S. Er.virce. :-r.;al Frctect hn
- rr s, : lit <c's f *.' C A;eacy Te'e rel A:tivitie s ?. anch
'.t. 5. '.. : :. - t + ;U e ::.rj C;.--' : s i : n Aiit::
IIS D:::.M.u::R l - j L. ?!-: er
?.13 Sc th teerb:rn Street
- 7. O.
~:>.:5 Chi:4go, Illinois 60624
~
",5,
- 1 4..;'s f*
- 0 Fs. 1.5y Drey
.t-
. 5. :.;tr 515 West Point keenue 1
- ,'t:
..t r.ey *e eral t r.h ersity City. V.issouri 0110 i
I:.
.- el Cor.: ci ':vitica
- 55 '. '
- !; S $:ree:
l'r. Paul Tetit i
i.I'i Dc, t ricer.t of tr:rrgy
~.< :,:, :'1
..:s f M:.1 F. il S* op 8 107
- i :. r. i t.; t on, D. C.
2;i:5 I
"; r s ; : ". L i'er2 y f N. :
- . ?. re:
CesJcl1 Eeed Fctr 5, :1:i!015 t0;51 f ssistant Vice Fiesidcnt.
I
~
C:r.tr. wealth Edison Co.
D.'*.-
P 0. Dox 767
".ar; f !. :E s$sers cf Chic 390, Ill. 63600
~. :
- .-ty e
G r.. y
- j C :.u -:bu s e Harold R. Denton, Of rector "rs e's. :1:.r v s 60:*0 Of fice of Naclear Reactor Regalation U.S. Nuclear l'tsslatory Comission r e.. r
. : :f r.clic F*alth W2 5 hi'*9 ton, D.C.
20555 i
- i t:
'vis'en of
.c'.+:- tefe:)
- r... :
... r :...
- s. o. t r.,. n
~. ; r. ; ' + '. :, :ii:n:is 6*:7?1 l
i h
.I 8
4 1
4
l I
i tNns STAn:s & AmIcA i
f
,f. Iff1 EAR W2AIch. CCrtCSSICN
.. p, n,4. g.,,.
s CGICEALIH DISCH CCt@ANY
)
)
i Drs.'sdan Neelear Po.er staticn )
t eket !b.
50-10 Unit 1
)
PETITICH FOR PREPAPATICN T DNIPCI:MD7IAL IMP 1.CT STA*IGNT A'O FCR STAY e
ikw ccries Petitioners, CITUDG FCR A BETTER EWIRRiDiT and i
PEAIRIE AU.IANCE, both Ibt-for-Profit Cegations registered in the State of Illinois, and hereby petition tla United States Nrlear Rc.gulatory Cmmission as fo.cus:
1 1.
Pursuant to the National Dwircrrental Policy Act, as a cnded, 42 U.S.C. 54321, et. seq., the Atcmic Energy Act, as areMod, 42 U.S.C.
52011, et. seq., the Council en Environmental hdity Regulaticns, 40 C.F.R. Parts 1500-1508, and 10 C.T.R. Part S1, Citizens for a Better Dwircrrent (hareinaftar "CBE") and Prairie Alliance (hereafter "P5")
petition the thited States Nuclear rqalatory Ommissicn to prepara an Environrental Irpect Statement cn the proposed chemical deconta:ninaticu at Ccnactr ealth Edison Ctrpany's Dresden Nac1sar Power Station, Unit 1.
2.
Petiticnar CBE is an Illinois not-for-profit corporaticn with approxicataly 5,000 members residing in Iliinois.
CBE files this petition cn beb1f of its rer1 bars who reside near the Dresden Naclear Powar Station, thit I and whoss health, safety and prqarty cay be adversely af facted by any I
cavircrrental 1 pset of the chenical decontanination. -
1 3.
Petiticnar PA is an Illirois not-for-profit oorporaticm with vproxirately 350 perbers residing in Illinois.
PA files this petition
]
cn behalf of its re-bars who reside near the Dresden Nrlear Power Statien, J
thit 1 and stese health, safety and preparty may be advarsely affected by b
i
- any enviro rnantal irpect of the chemical decontamination.
- 4..Petiticners and their nerbars have a rabstantial interest in tha proposed chanical decontaninaticn at Dresden thit 1 in that 1
1 1
. '.O W.
(a) ne Dresden staticn is located in the State of Illircis and is within 50 miles of r.everal of the state's rest pcpalated areas in-
.. s cluding the Chicago Matelitan area, Aurora and Joliet, in which a large portion of E's and PA's m-bers reside.
(b) Any misFap or accident occuring during the preposed decontamination releasing radionuclides into the environment will ateersely affect C-2's and PA's morters in the vicinity.
ic) 24 Dresden station is located near the confluence of three rujor wate.r rercarces, the Illinois, Tankakc-e and DesFI*.ines Rivers; any reic.mse of rcidiation contrJ.ating these water.cys will adversely affect N's and PA's rerters.
(d) ne rc:6ers of CPE and PA desire to presene the future environ-rent of the area sarrouMing the Dresden station for themselves, their fxai)ies aM desceMents..
5.
The preposed c}mical dectnta:rdration at the Dresden Nuclear Pcuer Staticn, Unit 1 is a rajor federal actico in that:
(a) ne Depart ent of Dergy (D'E) funded approximtely 58.2 mi311cn cf the cost of the prcscsed decontrdnation.
(b)
CCE intends to ronitor, assist, aM receive reports en tie proposed decontaminaticn in order to use the tec.%igoes_and_ infocraticn e
aegaired in the proposed decontednation for future deccntaminaticn
- tjects.
(c)
On Naclear Tegalatory Cermissicn (NFC) is reviewing the prcpessi deconts.imtion.
(d) ne hX staff r.ust review aM approve the presosed decentednation prior to its ccrrren errent.
(e) ne bT staff rust reviev and apprcve procedures for returnLN the ructor to sedice after the decontami. nation.
(f) he NFC intends to use the info = ration acqui. red in the decentam-inaticn as a basis for reviewing and apprtuing any future large scale reactor syste n deconta-dnaticn projects.
6.
The proposed decontarinaticn at Drasden Unit I significantly affacts the bran environment in that:
i SW 3_
(a) 'Ihe proposed action is the first large scale decontamination l
of a ccrrercial nuclear plant; (b)
Palicnuclides ray be releasai to the envircrrient daring the l
decontamination, (c) Falicauclides nay be rele.asai to the envircrre:t during storage, l
trans;crtation, and disysal of the radioactive " crud" rernoved frcm the reactor during the decontaninaticn; (d) The chelcal solvent used to decontamJnate the reactor may
.f cn its own or in cambination with radionuclides adversely affect the e.nvirarent if it is not properly handico, stored, transported and disposed of; e
(e)
Studies have s5cr.c that storage end dispesal of radionuelides so treated pose a greater threat to the envircnrent and public health l
than other exrparable 1cu, interrediate and high level radicetin j
wastes; (f) h rethM used in the decontrinaticn (including but not limited j
to the nature of the polvent,the nature of the chelating agent, the l
acidity or alkalinity of the decontaination so'.rtien, t}e terperature of the deconteination solutico during the actual treat.ent, aM the langth of time the decentaninaticn solutico caes in contact with the affected pipes) ay weakeh or inpair the integrity of the reactor's pipes and cooling system, thereby crsating health and safety hazads; j
(g)
N proposed decantaminatica cay increase expasure to radiation, j
toxic chemicals and k:oc c potential carcinogenic certounds for l
~
workers and others near the facility, near the storage and dis;osal
{
sites and fcr those involved in the trans;crtation of the decontaminaticn r.ixture, before and after its use at the facility.
7.
In a petition of March 19,1979, 7:ay Drey of thiversity City, Misscuri, regaested an Dwimi.mtal Inpact Statawnt, which the NIC treated as a regaest for action under 10 C.F.R. 2.206.
Pursuant to 10 C.F.R. 2.206 (b),
action on such reqaests is to be 'taken "within a reasonable time."
In light
'l of the delay since that request, CBE and PA urge the NBC to take action on a
this petition as well as T.ay Drey's petition as soon as possible.
j 9
i 1
_s.
-4
=
')
EETEJCE, Petitioners, Citizens for a Better Envirce.: uint aJxl
.*i Pralrie Alliance, reqJest tMt the hbclear Fogulaterf Ccrrdssion prepare an EnviJummtal Lyct Stattn=t on the proposed chemical decon*d.ation
of Corenwalth Edison's Dresden L5it 1 ard to stay said decentednatica
.. il it is prepared.
Fcspectfully submitt(*3, CITIZDG FOR A ECTER ENIR3007r PFAIRIE ALLLWr.2
/3 &d /9/0 v _/c e./)1/' Jg a:
TC WtGO115 %
hir Attorney 59 E. Van Baren Street Suite 1600 Chicago, Illinois 60605 312/939-1530 f
i
.=
r t
I i
{
t 1
i I
1 i
?
r f
4 ATTAC'rDGh"r 3 I
A t
r s
,I a
e t
?
=
Y i
>t I
k y
v i
e n
k i
I L
s h
f f
i
,I i
i.
e 1
k t
4 a
t
?
?
6 k
b 4
1 2
9
?
1
fy..
2 i
1.S.E.A.
ILLINOIS SAFE ENERGY ALLIANCE l
P.O. Box 469 Ar.tloch. I!!inois 6C002 i
Meetings:
407 South
Dearborn,
Room 370 Chicago. Illinois 60605 1
Ss; tenter 20, 1979 PCT"'!OF $3 KEGIFCS CN TECONTAFINAT!CN CP DEESOU I. Mor-ie. Ill.
Dr. Harold Denton, Director p
Office of Nucisar Rsactor Regulation U.S. Fu: lear Pegulatory Cennission W shir.gten. D.0.
20553
Dear Dr. Centon,
i Under the previsions of the U.S. Nu: lear Eesulatory Cor_=issi:n Rules and Regulatie::s 2.206
.trilyn Shinoflug, with the support of r4:. ten of the
{
s'
~
Illinois Se.fo Energy Aniance, request that public hearings be held on the dec:n-l tAnination of the Oresden I nuclear reactor near F. orris, In. Since thers is no
)
assursnee that the N.R.O. will decide to conplete a forral Environ:. ental In;act
-J Statensnt for this experi:. ental pject, pub 3 te hearings are needed tot 1) answer previously..ansvered or inadequrialy answered questionsY and 2) investigate iis significance of new infornation :tssriing poe.sible environnental and haalth effects of decon:Aninstien. Accunte, cor.plete a..svers ars needed to the fonowing questions:
1.
What effect(s) win the admittedly corcosive solvent NS-1 have on the ructor's pipi:g systea? As stated under Categer/ A Technical Activity No. A-15, "The i
prinary N3C concern n1Ated to the decon*m-ination is to assurs that the decon-l tar.ination e.ethod does not dagade the integrity of the prirary coolant system i
boundary. This considention involves both inreiitte degndat'en during de-contar,inatien ani latant effects that could cause degndation during subsequent j
operation of the Isactor." Eow can sn the c:xial welds, valves ani joints, etc.,
- Any o.f which an haceeesiiQ, be inspected to assure dec:ntamination has not caused darA6s1 2.
What standards or guidelines win to uti.lized for "' baseline' inspection ami appropriate fonovup ins;4ctions to provide a high degree of confidence that no degradation has occuz ed"? Reliance on existing Technica.1 Specifications and i
"s >ecial inspections" seens inadequate in lig".t of the fonowing N?C admissions l
"Since this is an arst @ecentaninatioQ when the N2C staff has limited expe:tise and ex erience with connercial nuclear power plant.s. it win be difficult to j
establish the necessary meaningful guidance and criteria for the decentaninstion I
of opersting reactors in advance of these anticipated licenses subnittals."
l (Inphasis sided) To ny *,cneviedge the N?C has not yet published a XUREG Documentp i
di
-enene... _
i
-2
~
on rec: star.bation and/or a Ferdatory Caide whi:h identifies a.:ceptable r.eth:>ds of decentaninati:n Ard establishes caterials t'setb6 criteria, that sunt be satisfied to qualify eten :lecontamination r.etho?. for li:ensing apprevs1.
Whether or not a Re6ulatory Quide has teen put11sted may be noot if Fe621stor/
Guides a o net enforceatie. H:vever, sines the inte6 ity of the pri.ary coelant system is nser.tial for pr:tection of the ;-iclic hetith, decentar.ir.atiem should not ereceed_ u.tti this ime_ ant unresolved cer. erie safety issue is r* solved.
3)
Whethar or n:t decer treirAtion we.stes ce.. accuntely be classified s.s " lev-level" rt ra ins una..cv e red. What rsii:nuclides and in what cen:entaticna a:s ex;ected kaides cotalt j8 & 60, carius, =angnese, streenius and ceniun? According to NEO inforution, 3000 curies of rs.iicactive ratorial vill be re:.:ved tad eventutur
- laced in 1200 55 puen drara. E the rNiica
- tive satorial is unifornly distributed through:ut the soli:iification gent, one ein conclude each barrel 2
Ca.c vill contain 2} curies cf :.ii:, activity oi 12,500 nanocuries per 6nn.
waste with this concentation of radionuelides be defined as 1:w-1svel? W hat i
ta-~ ~es dees the ;"blic tave that significant t: cunts of tunsuranies won't be present? Accoriin6 to Mr. Steve lan6e of Oone:nwealth Edison, "transurs.nics
)
If the i
are net expseted," but appsrently their presence ca.n.ot to r:. led out.
vv e ::ntainz 10 or nore "na.nocuries of transunnie. c:ntaninants per grs of sterial," when win it 14 buried? Or will it rensin at the Ortsden site fmver a.s stated by Mr. lange?
4 What is the 1:ng torn envi.r00:en*Al ix;s.ct of combining radicactive waste with chslathg gents? A4 you know, Dn. Means, Crear a,xi Duguid found chelating E6e.to to to the very agenta resp:nsible for radionuclide mobilizatien at Cak Ridge,Tenn. (See Scie ~ e, Vol. 200, June 30,1978) The E response that decon-taninati:n vastes frca Drasden I win be buried in "iry" a.rsas is not adequate in ligt of ran's inability to predict cline. tic c:nditi:ns over the long time spans this wasta r-rains :iangerous to lif e.
Furthe rno-e, rsdionuclides can leach out (in a unner similar to the operati:n of a flea cellar) even 1.n dry area.s ard At least be carried fron original bu-ial sites by scant anunts of nin water.
one n:ent study shows ndionucli:ie-chelate complexes are persistent over time ed can retilly be tC en up by plants, etc.
3 H:w stable will the vinyl ester ;1sstic resin be which is supposed to encapsulate the decentamination va.ste s? Acccrding to NU?%-%71, "hers are no curren.
crit 4ria for acceptability of solidification gents." Therefore, eat is the be.ais established by the NSO (sad not L:w Chemietl or Conmenwealth Edisen) for concluiing tnis solidification process will be acceptable? What considention has been given to the fact that orpnic solvents present in cue.. radiotetive vs.ste can disselve the Dew Solidification agent?
6.
What tre the raxi=ua levels of rsdiation exp:sure workers could receive wnile carrying out dec:ntanination? Vhat tre thw expected levels of radiati:n exposun workers ray nesive? If FS-1 is repried as corresive or e, " strong chenical decentani.. ant," (NUPE-@lo), h:w can it be eleined that "it is essentiany non-irrits ting when applied dirsetly to the skh or eyes...*?
(I.etter fre D.C.I.)
This 6.
H:w nany trxki: ads of vaste will have to te shipped a:d at vnat risk?
questi:n FAs not been a.dequately a.nswered locause it is possitie NS-1 win have to be flushed througn the system more than once. According to Mr. Iange, *he absorption espacity of the solvent nay te taken up by tren batead of "cr.d" rveultbg in the produ: tion of twi:e os such vaste.
What is the status of the N C's conside:stion of the need for an Invironnental 7.
Inps.ct Statensnt for the Oresden I dere:ntanination?
An arly considention of this request will be e;;reciated.
S he mly, f.d
, [I *d',
.< W
._ y o.,
~.; :&
l.S.E.A.
1 ILLINCIS SAFE ENEAGY ALLIANCE P C. Ecx 269 Antecch. Illinois 60002
- 'eet;ngs:
.t? South
Dearborn,
Room 370 C'
ago. tihnces 60605
.jl tTG2R CPCUPS 4
APP!2 SED, 3raidwood, III.
s.
ASSOC. Arc C ENS Ft3 ??cIEC-~CN CT 7.I !"hY;3CNt'.E:C, 9
Sneffield C:'*IT, dis ACA:MT NUC!IAR FC ER, Chier.e;c CITI2DS CPPCSD TO RA.D;CACTIVE POLLU;'~0N, Higniand Park CF.'CACC ',iCPIN TCR PEA 0E DEY.AI.3 AREA ALLIANOE FCR R.C:K:ISDLE CEMY j.
!LLINOIS 00FSORTIL'M 0;! CCVEPJ;hD;TAL CONCEPJ:5, S ringfield
?
ILLINC~5 LEC:5LA!!?E Oct.tICD; 0F ThI NA~!CNAL ODL*NCIL CT
..y.:..C,.
- e.....;..,S PCe. J Y u--.. y sc s...
.s..
l PEACE A!O.;L"iT!OE CE:.TX, ihesten PCLLLT!:::. Af D DNIRC:l!I!CAI, P3CELD.S. Palatine F3A131E ALL*.ASCE, Ohtstaign, 310cning*.on, Charleston, Feoris and Sed. gfield Rf.1ICIOUS t.DLL'A!! :. 007.I.'.i;;7Y, 'Jheaton SI:i.'U.iI?.-I AL*.In:.CE F03 T-I E.V".<.;!:.i.?T, 3eckfo.d
'i A L'KI.0A : 0 TIZi.::5 ACT!C:4 P.E I;7 3
l 87.M CAY 01;;CER FCA.L'S!!OE
.a............... :
.g
,r.
3.,.
e t
L..... A..,._.......,.. 35, s..tevens rt. mis.
w:
wa...a... w
.a -..w SATE EAVT.!I, 3he b ygtn, ~4is,
r
r~
ATTACH'GNT k l
1 O
i p
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION MAROLD R. DENTON, DIRECTCR In the Matter of
)
)
COE*hvE ALTH EDISON COMPANY Dock et No. 50-10 (Dresden Nuclear Power Station Unit No. 1)
NOTICE OF ISSUANCE OF DIRECTOR'S DECISION UNDER 10 CFR 2.206 1
On April 16, 1979, notice was published in the Federal Register (44 FR 22529) that$s. Kay Drey had requested by petition dated March 19, 1979, that the Nuclear Regalatory Cormission (the Comission) prepare an Environmental Imact Statement on Corronwealth Edison Corpary's proposed chemical decontamination of its Dresden l
Nuclear Pcwer Station Unit No.1.
The Director has treated this request as a request for action under 10 CFR 2.206.
l By petition dated September 20, 1979, Ms. Marilyn Shineflug, on behalf of the Illinois Safe Energ Alliance, requested public hearings on the decontamination based on the the lack of assurance that the NRC would issue an environmental igact statement.
Notice of receipt of the petition was published in the Federal Re::ister l
November 7, 1979 (44 FR 64577).
By petition dated March 13, 1980, Mr. Robert i
Goldsmith, on behalf of Citizens for Better Environre..; and Prairie Alliance supported Ms. Drey's petition requesting the preparation of an environmental impact statement.
Although the results of the Comission's staff review indicate that the chemical decontamination proposed for Dresden 1 will not significantly affect the quality of the human environment, I have concluded that an environnental
i 1 -..,
impact staterent should be prepared because of significant interest and concern e xprtssed by r. embers of the public.
The staff has by seperate action issued a Draft Environmental Statement. The requests of Ms. Drey.and Mr. Goldsmith l
i are, therefore, granted.
The public hearings requested by Ms. Shineflug l
were predicated on the lack of assurance that the NRC would issue an environmental impact staterent.
Since the NRC has issued the statement, such hearings will net be necessary.
Ccpies of the Director's Decision, ar.d the staff's response to the petition' i
I (Appendix A) enc 1nsed thereto are available for inspection in the Commission's s
Public Docur.ent Room,1717 H Street, N. W., Washington, D. C.
20555 and at the Morris Public Library, 604 Liberty Street, Morris, Illinois 60451.
The Draft i
Environmental Staterent ray be examined in these locations.
A copy of the t
decision and Appendix A will also be filed with the the Secretary for the C ommi ssion's review in accordance with 10 CFR 2.206(c) of the Cormission's reoulations.
I.1 accordance with 15 CFR 2.206(c) of the Commission's regulations the decision will constitute the final action of the Cornission twenty (20) days af ter the date of issuance, unless the Commission on its own cotton institutes a review of this decision within that tire.
f f.anton, Director
/
e IIaro d Office of N":Icar Reactor Regulation l
Dated at Bethesda, Maryland this 26th day of June 1980 l
I 4
, g,q:ty%
.g,/~
.~
4
'l APPENDIX A STAFF RESPONSE TO QUESTIONS CONTAINED IN PETITIONS FROM THE PUBLIC F
e
=
I
STAFF'S REspCNSE TO QUESTIONS CONTAINED IN MS. OREY'S MARCH 19, 1979 PETITION (DOCKET NO. 50-10)
QUESTION First, is it possible that an environmental imaet assessrent and a 1.
negative declaration have alrea@ been written regarding the proposal to decontaminate Dresden Unit One?
REspCNSE The Nuclear Regalatory Cccraission evaluated the envir:nnental imact of the Dresden decontamination in 1975.
As stated in our December 9,1975 Safety Evaluation, the decontamination will take place within the closed cooling system located inside of the containrent sphere.
No decontamination effluents will be released to the environrent as either liquids or gases.
All of the radio-active wastt will be solidified for shipment to a burial site authorized to accept the waste.
The packaging and shipping of the waste will be in accordance with applicable Department of Transportation and NRC re7J1ations.
Our 1975 review did not id.ntify any adverse environrental inact associated with this project and the facility changes did not involve a change to the Technical Specifications or an unreviewed safety question.
Therefore, no Environ ental Icpact State ent or Negative Declaration and Environmental Icpact Appraisal was issued to support our conditional approval to begin the work necessary to prepare for the decontamination of the reactor.
However,because of expressed public interest in this actlen we have prepared a Draf t Environrental Staterent in support of our final approval to decontaminate.
QUESTION 2.
What do field or laborator[ tests demonstrate to be the migration potential of radioactive wastes entrapped in the Dcw Chemical solvent, assuming some were to escape from buried containers into the environment?
RESPONSE
The migration of radionuclides at a burial site is determined by the physical form of the waste, the rainf all at the site, and the geological and hydrologic features of the burial site. The risk associated with potential migration is further defined by the land uses in the vicinity of the buried waste.
The migration of radioactive waste which you have referred to was reported by The referenced paper Means, Crerar and Du?Jid (Science, Vol. 200, 30 June 1978).
discusses the disposal of 35 million gallons of Ifouid waste in burial pits at
l
.,yr e APPEhDIX A J Oak Ridge Natienal 1.aborato v between 1951 and 1965.
Cernonwealth Edison, i
I the licensee for Dresden Un16 No.1, has agreed to dispose of the Dresden 1 I
solidified waste at either Beetty, Nevada or Hanferd, Washington cornercial low level waste burial sites.
These sites differ significantly in their geologic and hydrologic characteristics from the Oak Ridge site where chelant-
.J aided migration of radionuclides was observed by Means, Crerar and Duguid.
Specifically, the Oak Ridge site, where migration occurred, experiences very high precipitation and has a water table so shallow that it probably intersects
^
j the disposal pits and trenches during periods of heavy rainfall.
In addition, the Oak Ridge topography is hilly with steep slopes underlain by fractured shale raterial which allcws underground water and radioactive waste to flow down hill for approxir.stely 50 :neters through the fractures until it seeps to the surface i
within 75 meters of a perennial stream.
Conversely, the comercial waste burial sites at Beatty and Hanford, where no i
migration of radionuclides has been observed, are flat desert areas with very.
low precipitation, a water table approxir.ately 90 meters below ground level and a distance of 13 to 16 kiloceters to the nearest perennial stream.
4 In addit on to these site characteristics, which prevent the migration of i
radioactise material from the desert weste burial sites, another significant j
difference between the proposed waste disposal technique and the now discontinued 3
Cak Ridge inethods is that Dresden waste will be disposed of as a solid.
At
)
Oak Ridge cver 35 million gallons of liquid radioactive waste was puped inte the dispcsal trenches.
We esticate that approxirately 7 million gallons of liquid waste was disposed of in Trench No. 7, which was identified as a source l
of chelated radionuclides.
Because of the differences we have concluded that solidified Dresden wastes, in a dry burial site will not migrate in the ranner that liquid waste migrated at Oak Ridge.
i We do not have field or laboratory tests results which quantify the migration potential of radienuclides associated with Dow solvent, assuming that some escapes from solidified waste and into the soils of a disposal site.
The j
rate of water covement at a particular disposal site is the limiting factor g
for migration.
Migration potential of chelated radionuclides is decreased when placed in a solid waste matrix and disposed at an arid disposal site.
ihe upper bound of the migration potential of non-volatile contaminants is determined by the availability of water and its rate of revenent through soils.
The lower bound is achieved when contaminants become fixed on solids or are held long enough to undergo decomosition or decay.
In the absence of j
interactions with soils, such as adsorption, the migration potential of soluble contaminants is governed by the potential for water to carry contaminants from i
a source.
I i
\\
I i
I
y.
I APPENDIX A -
Migration potential of dissolved centaminants is generally assessed in laboratory tests using dispesal site soils and water spiked with traces of (K ) is typically c ont ar:-i na nt s.
In the tests, the distribution coefficient d
ocasured and it is assured that with a few adjustrents the ratio of the velocity of dissolved contaminants to tbr velocity of water passing through the soil con be esticated.
Referring to the examle of migration at Oak Ridge site it has been observed that water ficw rates are ext remely rapid, and have been en the order of 100 feet in less than one renth))at a trench similar to the ene in which chelating agents have been found' Since the migrating radionuclides were Strontiu -90 and Cesium-137 (which do not form strong co@lexes with chelating agents), it appears that water flowing at high vclocity througn f,actures caused these radionuclides to migrate.
Fractures probably augrented the =igration of chelated radianuclides at Oak Ridge as well.
We assur.a that the tcsts of migration potential which are addressed in your question refer to the adsorption of racionuclides by soil or Kd measurerents.
There are several caveats which cvst be censidered in using Ke values from laboratory and site tests to predict conditions at other sites.
In the case of lab:retory tests, there is considerable uncertainty as to the chemical conditions which should be used to represent the disposal site environment in lab:ratcry tests.
Eh, pH, microbial activity and other dissolved substancas are am:ng the variables knxn to influence the distribution ccefficient.
- Also, there r.!y be differences in the results obtained under the sane chemical ccnditions but with different testing techniques.
Pield tests ray avoid setne of these problers, but they have drawbacks in that r.any years of sacpling may be required and the results may only apply to a limited range of conditions such as at the site being tested.
QUESTION 3.
For how maqy years have radioactive corrosion products, bonded with the prcposed Dow Chemical solvents, rerained free of water af ter being solicified by the Dow Chemical polymer process 7
RESPONSE
Radioactive corrosion products, bonded with the Dcw Chemical solvent, have been tested to reedin free of water after being solidified by the Dow Chemical polycer process since 1974.
il) Loerenica, Jacobs, aad Struxngs, Healg7 Physics, Pergenen Press 1957, Vol.13, Behavior of Sr and Cs in Seepage Pits at Oak Ridge National Lat> oratory.
o APPENDIX A !
QUESTION 3a.
Has the Dow solidification process been tested on reactor corrosion products comparable to those which will result f rom the Dresden
~
esperiment? What assurance is there that the encapsulated waste is going to be low-level?
l
RESPONSE
i The Dresden decontaminatior. is not an experiment, it represents the application of a proven method of decontamination that has been specifically i
developed and tested before being used on the Dresden Unit I primary cooling
+
sy st em.
1 The Dow Chemical polymer solidification process has been tested on rtactor l
corrosion products comparable to those that will result from the Dresden Unit I decontamination operation.
In June 1976, a Dresden Unit I corrosion test loop was decontaminated with the Dow Chemical Solvent, NS-1, to provide i
data on future decontamination operations.
The test loop was originally installed to obtain stress corrosion data.
Isotopic surveys indicated that j
the crud in the loop was representative of the rest of Dresden Unit 1 primary system.
The spent decontamination solvent was solidified by employing the Dow Chemical polymer process.
l Isotopic analyses of crud samples have been used to identify the type and i
amount of radioactivity.
The total arount of. radioactivity from the decon-tamination of the Dresden reactor system is estimated to be approximately i
3,000 Ci and each 55-gallon drum of solidified radweste will contain up to approxicatrly 3 Curies of predominately Co-5B and Co-60.
These radioactivity i
concentrations are not unlike thos~ norrally produced by typical operating i
e reactor reewaste systers.
These types of-waste are considered to be low level for waste disposal purposes because they do not contain high concen-l trations of fission product nor transuranic isotopes.
l i
e QUESTION i
i 3b.
When did Dow Chemical first develop its solidification process for low-l level radioactive wastes? What is the longest duration period for one of its " monoliths" or matrixes -- that is, how has such a solidified Dow substance remained free of liquid? What would be the' long-term stability of the solid polycer over a period of thousands of years?
j
RESPONSE
The basic forrulation of the Dow Chemical solidification process was developed
{
in the late 1950s under tha trade nace of NAJVAR.
The first solidified sample
]
)
1
si APPENDIX A.
i of prototype test has remained free of liquid since 1974 when the test was ma de.
Analysis has shown that the longest lived significant isotope that will be solidified after the decontamination is Co-60 wi',h half-life of 5.2 yea rs. Tests have been performed to demonstrate that tne stability of the solid polyrer will not substantially alter for over 50 years, corresponding to 10 half-lives of Co-60.
These tests include accelerated aging, biological degradation, radiation degradation and temperature cycling (f reeze and thaw resistance tests).
After 10 half-lives the original 3,000 curies will have decayed to approximately 3 curies.
t
_ QUESTION 3c.
What is the leach rate of the polymer under burial conditions, or the potential for diff;sion and release of encapsulated radionuclides, solvents, etc. ?
J ESPONSE We do not know the leach rate of Dow polyr.er under burial ccnditions.
In arid dispesal areas the potential for water to contact waste is very srall, ifmiting the potential for leaching.
The potential for diffusion and release of encapsulated radionuclides has been corpared to other commonly used solidification agents under standardized laboratory conditions.
D ow polyre r was found to leach more slowly than cerent, urea formldehyde, and bitumen for strontium and cesium isotopes.
Cement showed a lower leach rate for Cobalt-60.
There is not as yet any test which can sirulate leaching under burial conditions.
The potential for release of radionuclides has been corpared on a relative basis, in the NRC funded study "Froperties of Radioactive Wastes and Waste Containers", conducted at Brookhaven National Laboratories in Upton, New York.
Dow polyrer was compared to other common solidification agents (urea formaldehyde, cement, and bitumen) and found to have generally superior radioisotope leach rates.
Cement was found to have a lower cobalt leach rate, however, the tests were performed with Cobalt-60 in an unchelated state.
In the tests, small samples of solidified reactor wastes (excluding decontamination wastes) were innersed in salt, distilled, and ground waters for one to four months.
Dow has perfonned leach tests using westes similar to those in the Brookhaven work and the results shewed close agreement.- Dow also perforced leach tests with NS-1 decontamination waste solidified in Dow polymer, and found that the leach rates were slightly better for Cobalt-60 when the NS-1 waste was compared j
i 1
1 1
APPEhDII A '
to the other rea. tor wastes tested.
It is possible that the reason for lower Cobalt-60 leach rates in the presence of NS-1 may be due to association with a lar5er eclecule, resulting in slcwer diffusion through Dow polycer.
The 4
tests shewed that after cne week of innersion 0.7 percent of the cobalt leached from the solid waste and an additional 0.2 percent of the cobalt leached during the following two conths.
These results indicate a rapid reduction in leach rate af ter the first week.
It has been proposed by the International Atomic Energy Agency that the results of small sanole leach testing be scaled by the ratio of the volumes te the surf ace areas of the sample and the actual waste (55 gallon drum dicensions in i
this case) using a formula specially derived for use with the leach test p rocedu re.
This scaling would result in a reduction by a factor of approximately 0.1 for com)aring the cuculative fractions released in the drum sized wastes to the laboratcry samples.
The leach rates measured in the laboratory are costly of use for estinating leacning under saturated conditions, or as a basis for ccaparing various solidification agents.
In actual burial conditions at the low-level waste disposal sites considered for the dispesal of Dresden 1 decontamination wastes, the waste is disposed in a dry unsaturated environment with very little coisture available.
This is explained in more detati in the response to Question 4c.
QUESTION 3d.
During the evaporation step, is the solvent volatile, and if so, will t
an icn exchange resin cotpletely scrub chelated radionuclides from the' evapcrate?
(I am told by one person that his experience indicates it i
will not).
RESPONSE
At the evaporation tenperature, the chelating agent pertion of the solvent is not volatile except for annonia and organic compound components.
Carryover of chelated radionuclides entrained in the vapor mist is an insignificantly small f raction.
This carryover will be further reduced as the spent solvent is further processed by a mixed-bed demineralizer which has been tested to be effective in removing chelated radionuclides.
The conductivity of the liquid is a strong function of the solvent concentration.
In order to purify the water for reactor grade and suitable for plant reuse, the processing required has to reduce the residual solvent concentration to an insignificant amount.
J i
Ar f th01 A A
-/-
QUESTION 4.
For how many years have the barrels designed for burying the solidified wastes been found to remain resistant to corrosion f rom both the propcsed contents and f rom surrounding environnental impacts?
RESPONSE
The barrels were designed to meet the packaging requirements for transpcrt of the solidified waste and are not designed to serve the purpose of rec.alning cerrosion resistant after barial.
However, although there is no experience with buried barrels ef the same Dow Cnemical polymer content, actual experience with barrels of similar design and chemically cocparable content at the burial sites has shown that most barrels remain resistant to corrosion and maintain their integrity for up to 5 years.
_ QUESTION 4a.
According to a letter I received f rom Mr. Paul Pettit (Light Water Reactor Section Division of Nuclear Power Development, DOE) dated February 6,1979, the solidified wastes from the Dresden experiment are to be shipped in drums to a commercial low-level waste disposal site.
Since additional wastes srt no longer being accepted at the nearby Sheffield, Illinois burial site (in fact, the licensee has Just walked away, with the NRC in hot pursuit), will the wastes be shipped to Nevada, South Carolina, or Washington? Were the drums designed to 'cocply with the Cepartment of Transportation *s (DOT) pack-aging and shipping regulations for low-level or high-level wastes (49 CFR Parts 170-178), or to cocply with the NRC transit regulations for fissile raterials (10 CFR 71 and 73)7. And/or were the drums designed for indefinite burial?
RESPONSE
~
The solidified radwaste will be shipped to a licensed corrercial low level waste barial site located at either Beatty, Nevada or Hanford, Washington.
Prior to shipment, estfrates of radioactivity content and direct radiation measurtrents of the drums will be made.
The Ifcensee has committed to reet the applicable packaging, labeling and transportation regulations under 10 CFR Part 71 of the Nuclear Regulatory Commission and under 49 CFP Part 170-178 of the Department of Transportation.
Regulations pertaining to fissile materials will not be applicable since the reactor fuel is removed prior to decontamination and no fissile material is expected in the decontamination waste.
APPENDIX A '
QUESTION 4b.
What is the estir.ated lifespan of the barrels? What precautions are going to be taken at the life-end of the barrels to ensure continued containment of the residual radioactivity? Have any metals been found that vill resist the corrosive action of the prcpes.ed contents for r <en a decade?
Is there apt to be ary chemical reaction betw('n the compounds going into the barrels and the raterials of which the barrels are composed?
RESPCNSE It is not our present policy to rely upon barrels to contain wastes after dispesal.
The hydrogeological conditions of the disposal site and the waste solid are reliec en to provide containment after containers sre no longar i nt a ct.
The specifications of the container are based on transportation requirements, not disposal requirements.
The lifespan of the barrels has not been relied upon to contain the westes after disposal.
This has been the usual practice in the past for evaluating the performance of disposal sites.
The waste container (DOT approved 55 gallon drums) metal has been tested by our contractor, BNL, and based on the test results we find the container is adequate for waste in this solidified forr.
In the first series of tests we requested ESL to reasure corrcston under the condition that the waste does not s oli di fy. Under this assurption corrosion breakthrough could occur to a 55 gallon drum in abcut one month.
In view of the assurance provided by the quality control and system design features of the solidification system,
~
if the ccnditions that would result inithe. pre'sent of liquid NS-1 were to occur, they would be detected and appropriate corrections would be made.
The corrosion rate was also detarmined for a more realistic hypothetical bounding case where a layer cf liquid waste was tested in contact with the drum steel to sirulate the worst case for condensate in the drum.
Such a layer of liquid waste has not been observed in wastes solidified by BNL or the mancfacturer (Dog Chemical Corporation) when the wastes were solidified in accordance with the procedure specified by the c.anufacturer.
The results from this test show that the barrel could be expected to last one or two years, based on corrosion observed af ter 4 weeks of contact.
This indicates that assuming the above as a trial worst case, corrosion would not penetrate the wall osring handling and storage, if buried within a few months of solidification.
A container corroding through in the disposal site would not present P problem since the waste is a solid and the quantity of cendensate which could leak from the drum would be easily absorbed in the undersaturated soils at a semi-arid disposal site.
Further corrosion tests conducted under expected con-ditions show that after 4 weeks of exposure no significant corrosion occurs
APPENDIX A -
to the barrel steel in contact with solidified waste or vapor from liquid The corrosion rate in contact with solidified waste indicate that waste.
the barrel could last tens of years and the vapor was f ound to be non-corrosive.
QUESTION 4c.
In the June 30, 1978 Science article, Dr. Crerar and colleagues describe the accelerated dispe'rsal through the groundwater and the increasec uptake by veoetation of the radionuclides when bonded to nonbiedegradable chelat es.
If the buried drums with the solidified Dresden effluent were to corrode and the matrix were to core into contact with water, would the radionuclide-chelate cceplex not become soluble again? Could this solution then migrate through the envirsnoent in the same manner found at the Oak Ridge burial site?
RESPONSE
The migration of radionuclides at Oak Ridge was associated with the disposal No.
of 35,000,000 gallons of liquid waste.
The significance of the migration at Oak Ridge was addressed by Means, Crerar, and Duguid in 1976 ar. follows:
"A seep approximately 50 mg+ ers east of trench 7 within the OgNL restricted area cogtains o in concentrations of If2 to 10 dpm/g in the soil and 10 dpm/ml in the water.
Traces of Sb and various transuranics have also been detected in the soil.
However, because
-~
the volume of water discharge from the seep is scall, the total radionuclide contribution from the trench 7 area to White Oak Creek and the Clinch River is insignificant."
7.._;._. _
Migration as observed at the Oak Ridge site would not occur at the Beatty, Nevada or Hanford, Washington commercial disposal sites.
A solid waste is to be disposed at the comnercial sites. The climate, geology, and hydrologic conditions eliminate the possibility for flew to saturate soils and transport radionuclides as cbserved at Oak Ridge.
l ME ANS, J. L.,
A. CRERAR, and J. O. Duguid.1976. Chemical 12)
Mechaniscs of g3Co transport in ground water from intermediate-level liquid waste trench 7: Progress report for period ending June 30, 1975. ORNL/TM-5348. Oak Ridge National Laboratory, l
Oak Ridge, Tennessee.
I
APFENDII A
- The rdgration as observed at the Oak Ridge site would not occur at the disposal sites which ray receive the solidified Dresden 1 decontamination wastes, assuming that container corrosion and leaching of soluble radionuclides occur.
Connonwealth Edison has notified NRC staff that the dispcsal sites which are Leing considered for the Cresden 1 wastes are the Beatty, Nevada and Hanford, Washington cornercial lew-level waste disposal sites.
Table 1 gives a briEf summary of the disposal and envircnmental conditions at these sites, with a comparison to the region of disposal y
p;ts 2, 3 and 4 and trenches S. 6 and 7 at Oak Ricge.
These pits and trenches are t
clustered in the vicinity of Whiteoak Creek.
There are many similarities between the:e disposal units, which include trench 7.
This trench was found to be a source r
of chelated radionuclides.
The m.ajor difference between the Oak Ridge site, where f
migration has been observed, and the comnercial sites, where no migration has been J
detected, is the general lack of water at the commercial sitet and the abundance of water at the Oak Ridge site.
Oek Ridge experiences very high precipitation, has a water table which pretably intersects pits and trenches, and the weste disposed was enti rely liquid.
For trench 7, which was identified by Duguid, Means and Crerar as a source of chelated radienuclides, we estimate that approxicately 7 million gallons of liquid weste was disposed dering a threl year perf oc from 1962 to 1965.
Con-sidering the liquid to be evenly distributed over the area of trench 7, the equiv-alent water flew in terns of precipitation would be on the order of 100 feet per year.
This is f ar in excess of the f ew inches of precipitation incident at the desert sites, where the rajority of the precipitation is rapidly returned to the atraosphere by evaporation. The estimates of water flauld be present in the distillate.
Additional treatment by demineralizer of. the distillate and/or subsequent rinses may be performed if necessary.
The licensee's tests indicate that the demineralizer is effective in remving radioactive metals tonded by the chelating agent.
QUESTION Sb.
According to Mr. Pettit's letter of February 6,1979, "the formulation of the Dow Chemical solvent is known to DOE staff, but is protected f ron, release to the public by c proprietary agreement." Solvents used for decontamination purposes at nuclear facilities have been described elsewhere, ho,<ever, by DOE, Dev and Cocnonwealth Edison representatives as being
" chelating agents" (pronounced key-lay-ting) -- that is, a i
chemical cecpound (typically organic) capable of forming clawlike multiple bonds with a metal f on.
Typically these i
agents are also non-irritating to skin or eyes, a characteristic of the solvent which Mr. Pettit happened to mention.
j
9 APPENDIX A.
Ass.; ming the cc7cnents of the solvent fit the definition of
}
a chelating agent, is there any likelihood that there will be j
enough residual after the prirary ef fluent and first rinse water have been removed, that seme might be flushed into the f
Illinois River along with future routine releases of the coolant g
water?
(The coolant-water discharge canal emties into the Illinois River at the confluence of the Des Plaines and Kanakee Rivers at Illinois River Mile 272.4).
How tightly does the solvent bond retals? That is, if some were to pass through the sediTent f
- r. ear the canal's discharge point, might it leach out additional radienuclides which have accumulated in the sediment near the n
[
cutfall? Or if it is a relatively weak agent, might the sediments y
attract radioactive t.atals out of the chelate solution, thereby increasing the amount of radionuclides in the sedirent and the 2
I poter.tial for further contamination of the benthos?
(The EPA
}
re;crt entitled " Radiological Surveillance Studies at a Boiling i
2 Veter Nuclear Pcuer Reactor", BRH/ DER 70-1, describes the contents I
i of the Dresden Unit One liquid weste effluents during tests in 1957 and 1g68.
T o later companion studies at reectors in i
F.assachusetts and Connecticut describe the significance of the corcentration of radienuclides in the sediments).
f J
fESPONSE 4
No liquid waste, including water from all the rinses, f rom the decontamination i
operatien will be discharged into the river.
The licensee has committed to l
proce3s all liquid waste to meet reactor coolant (RC) purity requirerents for recycle as plant rakeup water.
9C purity requirerent precludes significant quanti:ies of cheiating agent.
Ir addition, arty trace anounts of chelating agent will be det:mased to si@le m:lecules at plant heatup during startup (chelating agent decomosition temerature is around 300*F).
f)ESTION 6.
What will be the igact of the solvent on the future safe operation I
of the Dresden plant?
'ccording to the book, Dangerous Propertv. of Industrial Mate.1eis, by N. I rvi ng Sa x, published in 1963:
"One fallacy in the initial concep'
- afnless steel or other
'irpervious' surf aces is that the) cruly igervious.
This has been shcwn to be false.
Stainless ::ael after one vigorous cleaning is found to deteriorate in that more and core material say be absorbed or adscrbed and retained on the surf ace.
Successive cleanings have been found to beceme more difficult and to require m:re vigorous methods of decontamination." (p.149)
O.'
APPENDIX A.
a.
I understand that the NRC is responsible for making certain that this project will not compromise the integrity of the reactor vessel and its parts. What assurances, hwever, does either the NRC or the DOE have that this massive cleaning effort will not increase the surface fouling of the reactor system in the future, causing an acceleration in the buildup.of crud in its marty necks, crannies and blind holes? Will even stronger chelating agents be needed at Dresden Unit One for future decentaminaticn eff orts, assuming the stainless steel properties quoted above f
from the Sax book are correct?
b.
Could an acceleration in the rate of buildup of crud after the decontamination project increase the potential for pipe cracking or rupture? And also increase the radiation hazards to workers?
RESPONSE
a.
There is no evidence based upon decontaminations that have been perferned at the Canadian reactors and at the Britisn reactors to indicate that the rate of recentamination or the rate of crud deposition on the cleaned surfaces would be accelerated by the decontamination process. 7n the surfaces of cleaned carbon steel, subsequent rates of deposition of copper have been shown to increase, but in the Dresden 1 cleaning process this copper will be removed by a " copper rinse".
In f act, rather than using stronger chelating agents at Dresden Unit 1 in the future, it is quite pessible that, following the strong decontamination solution to be l
used in August of 1979, the utility c:ay elect to use a weaker but ecre frequent decontamination process on line that is currently being developed under EPRI sponsorship by Battelle Northwest.
b.
There is no evidence that the buildup of crud either dUring' routine operation or following decontamination could increase the potential for pipa cracking or rupture.
The initiation of pipe cracking a;; ears to require rilatively high stresses and perhaps a specific rate of straining of the stainless steel in conjunction with the oxygen in the coolant.
There is no evidence that crud deposits influence this initiation. Various laboratory tests on specimens that have been decontaminated and then re-exposed to typical BWR primary coolant water have shown no increased sensitivity to integranular stress corrosion of the type that causes the pipe cracking incidents that have occurred in boiling water reactors.
Since there is no anticipated acceleration in the buildap of crud, it would appear that the-e would be no concomitant increase in radiation hazards to workers.
In fact, the pritrary reasons for doing the decontamination in the first place is to reduce these radiation hazards.
In some units the rate of recontamir.ation has been shown to decrease simply because a substantial
~.
APPENDIX A.
portion of the Cobalt 59 has been removed from the surfaces of the piping raterials by corrosion processes earlier in operation of the u nit, so that the buildup of Cobalt 60 following the decuntamination is reduced substantially.
- iUESTION 7.
What assurances are there that the men who participate in the Dresden decontamination experiment will not suffer fron. exposure to the coebination of the solvent and the radioactive materials suspended in the solvent in either the aqueous or gaseous forms?
Or.e of the possible reasons for the increased incidence of leukemia and cancer at Portsmouth and other naval shipyards which Ors. Thomas Najarian and Theodore Colten mention in their comunication published in The Lancet, May 13, 1978, is that:
sther f actors (a sbestos, smd'ing, incustrial solveng) may have interacted synergistically with radiation to cause recre deaths from cancer and leukemia than radiation alone would have caused."
(erphasis added).
I realize that one of the primary reasons for trying to develop an effective decontamination process is to reduce the recun.tlation of gamm.a-emitting corrosion products which in turn cause high radiation fields within operating nuclear pp<er plants, and thereby necessitate the hiring of excessive numbers of repair and maintenance workers.
RESPONSE
~ -
~~~
~~
~ ~ ~ ~
"~
~:
j The concerns about operating personnel receiving radiation exposure and being exposed to the deccntamination solution are synonymous.
Since the spent occatamination solution contains radioactivity, exposure to the solution will result in exposure '
.diation.
The design of the system i
is such that personnel should not nave direct physical contact with the radioactive decontamination solution.
Personnel working near such solutions generally wear protective clothing, e.g., face rasks, to further minimize the possibility of contamination.
The licensee is comitted to comply with limiting radiation exposure to personnel to within the limits specified in 10 CFR Parts 20.101 and 20.103.
The licensee is also comitted to ceet the objective of limiting the radiation exposures to as low is reasonably achievable (ALARA) level in accordance with 10 CFR Section 20.l(c).
APPENDIX A 17 -
QUESTION 7a.
According to a letter dated March 13, 1979, from Mr. A. David Rossin (System Huclear Research Engineer, Communwealth Edison), thirty workers will be needed during the presently proposed 100-hour project.
And although I was told by Mr. Paul Pettit of the DOE that his agency is not concerned about the toxicity of the Dow solvent itself during the decontamination operation, what hazards cay it pose to workers when it is in combination with radioactive materials?
RESPONSE
Although there is no demonstrated synergistic interaction between the Dow Chemical NS-1 sc1 vent and radiation exposure, the AL ARA consideration for radiation exposure should be sufficient to limit the exposure to the Dow Chemical NS-1 solvent.
The licensee has submitted the plans and has ccamitted to maintain the radiation expcsure to personnel to ALARA. The NRC staff has reviewed the AL/RA plan and concluded that the AL ARA objective can be ret by the proposed plan of actions.
QUESTION 7b.
What procedures are to be taken to take certain that the radionuclide-chelating agent is totally contained and will not in fact come in contact with the workers? What is the radiation dose expected per hour at one reter from the reactor containaent vessel, the effluent piping, the evapceation and solidification equipment, and the drums preparatory to and during shipping? What shielding will be erected to protect the workers?
I
RESPONSE
The licensee is committed to cocply with radiation exposure limits to operating personnel pursuant to 10 CFR Part 20.
In addition, the licensee is cocmitted to design features and operating proc:dures such that radiation exposure to plant personnel will be naintained ALARA.
Since radioactivity is contained in the decontamination solution, contact exposure to the solution will also be kept at a cd nicum.
i l
i
o.
AFPENDIX A.
The radiation dose varies depending on local equipeer geome t ry, plate-out distribution and self shielding f actors.
The radiat. an at one rete from a reactor system ccmponent during the decontaminatf ea Erccess is gerarally less than that during normal operation and is expect (d to be in the 5 acral Racs per hour range.
The radiation near evaporatican Anf sclidif) etion equiptent should not be core than an order of ragri*.ude nigher.
Tresa kinds of dose rates are not uncon.9.on at radwaste equi,ntnt during r out ee i
cperation.
Hesever, it should be noted that perse re? secess :e thcs,+
areas is not expected because of remote control features.
The cbjective of the decontamination process is to redut - the total red'ation exposure to plant personnel.
The decontamination will rei..;ee the n4cw-source of radioactivity encountered by workers during operation 3..; ceintenance of the plant and, thus, significantly reduce personrel exposure in perforring these activities.
It is estimated that the saving in radiation exposure to persennel over the r.ert 10 years is 10 tires the radiation exposure to personnel expected f or performing the decontamination operation.
Date:
June 26, 1980 w
e-
~
~
.o STAFF'S RESPOSSE TO QUESTIONS CONTAINEO IN THE ILLINDIS SAFE ENERCY ALLIANCE'S SEPTEMSER 20, 1979 PETITION 1
(DOCKET NO. 50-10)
QUESTION 1.
Vhat effect(s) will the admittedly corrosive solvent NS-1 have on the reactor's piping system? As stated under Category A Technical Activity No. A-15, "The prirary HRC concern related to the decontamination is to assure that the decontamination method does not degrade the integrity of the primary coolant system boundary.
This consideration involves both irradiate degradation during decontamination and latent effects that could cause degradation during subsequent operation of the reactor." How can all the crucial welds, valves and joints, etc., many of. which are inaccessible, be inspected to assure decontaminatien has not caused damage?
RESPONSE 1 All primary cooling system materials that will be in contact with NS-1 have been tested extensively to assure that the integrity of the primary cooling system will not be degraded by the cleaning.
The corrosion research program covered se,eral thousand individual corrosion tests of all the basic Dresden Unit No.1 primacy cooling system raterials that will be expcsed to the sc1 vent under conditions of tire and temperature exceeding those proposed for the actual decont ami nation.
Based upon tl.e staff's review of the tests carried out by CECO, we tave concluded that the plant materials will not be significantly. damaged by the. decontamination soletion.
The successful laboratory testing program has provided a significant basis for authorizing this action. In addition, pilot scale projects utilizing NS-1 have been successfully carried out at the Peach Bottom Nuclear Power Station where a heat exchanger was deconta=inated and at Dresden Station where the Dresden Unit No.1 Corrosion Fatigue Test Loop was decontaminated.
These decontamina-tions, carried out on full scale corponents of portions of the primary cooling systers at these facilities have provided assurance that full scale operations utilizing NS-1 will produce similar results to the laboratoty scale experiments.
The inspection program that will be carried out by CECO after the cleaning will i
be used to determine whether the decontamination has caused the structural integrity of the primary cooling system to be degraded.
Only a very srall nurber of the " welds, valves and joints, etc." are physically inaccessible for inspection.
These components are inaccessible only because it is impract-ical to inspect them while they are radioactive.
The chemical cleaning will allow the inspection of these components and will increase the level of con-fidence that the primary cooling system does not contain incipient defects.
j
In the case of the few welds that are physically inaccessible, there is no reason to exoect that their condition following decontamination will differ from the condition of the inspectible welds that have beea cleaned by the same NS-l Therefore, if the solsent under identical conditions of tire and temperature.
inspection of the accessible welds indicates that there has been no significant degradation caused by the cletning, there will be reasonable basis to cenclude that similar welds in inaccessible locations will exhibit similar results.
QUESTION What standards or guidelines will be utilized for " baseline'-inspection 2.
and appropriate followup inspections to provide a high degree of confidence Reliance on existing Technical that no degradation has occurred?"
Specifications and "special inspections" seems inadequate in light of the follewing NRC admission:
"Since this is an area (decontamination) where the NRC staff has limited expertise and experience with conTecial nuclear power plants, it will be difficult to establish the necessary meanincful 9;1dar.ce and criteria for the decontamination of operating reactors ln
~
advance of these anticipated licensee submittal.*
(Euphasis added)
To ry knowledge the NRC has not yet published a NUREG Document on Decontamination:
and/or a Regulatory Guide which identifies acceptable methods of deccntami-nation and establishes materials testing criteria that must be satisfied to qualify each decontamiration method for licensing approval.
Whether or However, since the integrity of the primary coolant system not enf orceable.
is essential for protection of the public health, decontamination should not proceed unsil this important unresolved generic safety issue is resolved.
~
RESPONSE 2 The integrity of the prirary cooling system is inspected on a continuing basis in accordance with the requirements of Section XI of the American Society of Mechanical Engineers Boiler and, Pressure Vessel Code and Addenda.
Section 50.55a(g) of Title 10 Part 50 of the code of Federal Regulations establishes the requirements for inspection of the primary cooling system The inspection program f or Dresden Unit No.1 is in accordance int e grity.
with the requirements contained therein.
Facility Operating License No. DPR-2 issued to Dresden Unit No. I requires that Commonwealth Edison operate the facility in accordance with Section XI of the Code and periodically update their inspection proram to agree with the Edition of the Code currently required by our Regulations.
We have concluded that inspection of the prir.ary cooling system in accordance with Section XI of the ASME Boiler and Pressure Vessel Code provides adequate,
assurance that the system is free of incipient flaws larger than those 311ewed by the ASMZ code and therfore provides adequate assurance that the primary cooling system has not been significantly degraded.
QUEST:0N Vhether or not decontamination was*es can accurately be classified as 3.
"lew-level' rerains unanswered.
What radionuclides and in what concentra-tions are expected besic%s cobalt 58 a 50, cerium, ranganese, zirconium and According to NRC inferration, 3000 cu-ies of radioactive raterial cesium?
snd eventually placed in 1200 55 gallon drur:s.
If the will be recr.
radioacti rw ' rial is uniformly distributed throughout the so1Eification can conclude each barrel will contain 21/2 curies of radioactivity agent, or, Can waste with this concentration cf radio-or 12,500 nanocuries per gram.
What assurances d0es the public have that nuclides be defined as low-level?
significant a ounts of transuranics won't be present? According to Mr. Steve Lange of Co rcnwealth Edison, "transuranics are not enected," but apparently If the weste contains 10 or rcre their presence cannot be ruled out.
'nanocuries of transuranic contaminants per gram of material,* where will it be buried? Or will it rec.af n at the Dresden site forever as stated by Mr. Lange?
PESPONSE 3 The redicnuclides eg ected te be present in the Dresden decontarinaticn waste are listed in Table ' below along with the estimated total activity of each isotope expected.
Radioactive wastes are separated into two broad classifications:
'high level westes' and 'other than high level wastes".
High level wastes are radioactive wastes produced in the first solvent extraction cycle of fuel reprocessing If fuel is not reprxessed, the unprocessed fuel will be classified cperations.
High level wastes are highly radio-as high level waste should it be dis arded.
active, contain significant quantiti:.s of transuranic radionuclides, and require extensive shielding, sophisticated rccote handling techniques, and often require cooling to re-cve the heat generated by the decay of the contained fission productsq The second waste classification 'other than high level wastes
- includes wastes that are not produced in the first st of the sc1 vent extraction cycle of fuel reprecessing or the unprocessed fuel.
The Dresden 1 waste that will be produced from the decentamination falls into this class and ther 5.re ray be buried in a cocrercial waste burial site.
These wastes The Dresden decontamination vaste will not be high level wastes.
will be packaged and shipped in full conferrence with all applicable NRC and Departnent of Transportation requirerents.
Com erwealth Edison has corn:itted to reasure the concentration nuclides in the waste generated by the decontamination of the Dresden 1 primary The presence of transuranic elenents in levels in excess of j
cooling system.
10 nanocuries per grat is definitely not enected based upon reasurerents of the transuranic content of the corrosion product film observed on artif acts and sacples recoved from the Dresden Unit No. I pric.ry system and other boiling 4
_--..-.g
(
. i i
TABLE 1 ESTIMATED
- NUCLIDE CURIES HALF LIFE C1/55 Gal. ORlM 60 2160 5.3 years -
1.80 Co SB 630 22 days 0.53 Co 144 144 117 290 days 0.10 p
E4 30 25 days 0.03 g
21 63 days 0.02 953, 95g 57 15 270 days 0.01 141 15 32 days 0.01 Ce 103 9
41 days
.01 g9
. 01 MFP 3
l
- 7. U 3UUU
=
- Assumes that the waste will be uniformly distributed in 1200 drums.
" The half life of mixed fission products may be approximated by assuming that T 1 = t where t is the time since fission.
I.
f i
l
-a-t water reactors.
However, the actual waste will be analv ed f or transuranic content and if greater than 10 nanocuries per gram (10-9:
C1/gm) is detected, the weste will not be disposed of et a commercial waste burial site that has a 10-Y Ci/gm limit for transuranics.
In the unlikely event that transuranic radionuclides are discovered present in concentrations above these applicable limits, the waste will not remain at Dresden " forever".
The waste would be disposed of at a waste depository operated by the U. S. Government which is authorized to dispose of transuranic waste.
QUESTION 4.
What is the long term environmental icpact of combining radioactive waste with chelating agents? As you know, Drs. Means, Crerar and Duguid found chelating agents to be tae very agents responsible fer radionuclid mobilization at Oak Ridge, Tennessee (See Science, Vol. 200, June 30,1978).
The WRC response that decontamination wastes from Dresden 1 will be buried in
- dry" areas is not adequate in light of man's trability to predict climatic conditions over the long tire spans this waste remains dangerous to life.
Furthermcre, radionuclides can leach out (in a manner similar to the operation of a flea collar) even in dry areas and be car ried from original burial sites by scant amounts of rain water.
At least one recent stu(y shows radionuclide-chelate corplexes are persistent over tire and can readily be taken up by plants, etc.
RESPONSE 4 Migration as observed at the Oak Ridge site would not occur at the Beatty, Nevada or Hanford, Washington connarcial disposal sites.
A solid waste is to be disposed of at the commercial sites.
The~ climate, geology and hydrologic conditions eliminate the possibility for flow to saturate soils and transport radionuclides as cbserved at Oak Ridge.
The migration as observed at th'e Oak Ridge site wnuld not occur at the disposal sites which ray receive the solidified Dresden 1 decontamination wastes, assuming that container corrosion and leaching of soluble radionuclides occur.
Commonwealth Edison has notified NRC staff that the disposal sites which are being considered for the Dresden 1 wastes are the Beatty, Nevada and Hanford, Washington commercial low-level waste disposal sites.
Table 2 gives a brief summary of the disposal and environmental conditions at these sites, with a cocparison to the region of disposal pits 2, 3 and 4, and trenches 5, 6 and 7 at Oak Ridge.
These pits and trenches are clustered in the vicinity of Whiteoak Creek.
There are many similarities between these disposal units, which include trench 7, which was found to be a source of chelated radionuclides.
The major difference between Oak Ridge site, where migration has been observed, and the commecial sites, where no migration has been detected, is the pneral lack of water at the commercial sites and the abundance of water at the Oak Ridge site.
Oak Ridge experiences very high I
i
'.c,o j
~
i Comperison of the conditions at the Hanford, Washington,_
Tatie 2 and Beatty, llevada, cornercial low-level radioactive waste 4
disposal sites to the conditie.s at the Oak Ridge, Tennessee, i
liquid vaste disposal area.(Pits 2, 3, and 4, and trenches 5, l
6, and 7)
Dek Ridge Beatty Hanford j
A se re;e 50"/ year 4.5*/ year 6.25"/ year precipitation Vette to aquifer 0
300 feet 290 feet 4
distan:e Dir tz.:e to 250 feet 10 miles 8 miles g
nearf st peren-i r.ill stretr.
r Avere;e evapora.
34/ year 70"/ year 42"/ year i
j tien fro. open weter s urfaces Ves te fo :.
25,000,000 gallons Sclid' Solid
- i; (liquid)
Gereral c'escrip.
Killy, humid Fitt, desert Fitt, desert tica of site a rea area area
(
s?
q
-5:.e li:uid was es were solidified on site or received sorbed on solids or j
pt:1 ;ec' in s or' ~nt rateriai.
i i
+Tr.e ater trb1 ntersects some trench bottor.s in the Oak Ridge disposal areas.
l i
t f
i
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 1 l
precipitation, has a water table which probably intersects pits and trenches, and the Oak Ridge waste was disposed of as a liquid.
For trench 7, which was identified by Duguid, Means and Crerar as a source of chelated radionuclides, i
we estir. ate that approxicately 7 million gellons of liquid waste was disposed during a three year period from 1962 to 1965. Considering the liquid to be evenly distributed over the area of trench 7, the equivalent water flow in terms of precipitation would be on the order of 100 feet per year.
This is far in excess of the few inches of precipitaticn incident at the desert sites, wtiere the rajority of the precipitation is rapidly returned to the atmosphere by evaporation.
The esticates of water flows at Oak Ridge are based on figures reported by 1.onunick, Struxness, and Jacobs and trench dimensions from Duguid.
Migratien of radionuclides from the Oak Ridge disposal trenches to the surf ace was also pre eted by the type cf geologic raterial in which the trenches were excavated.
The trenches were founded in fractured shale which may have small solution cavities as well as fractures available to conduct water at rapid rates.
Trench 6, which received liquid wastes for approxicately one renth, had to be taken out of service dJe to the breakthrough of radionuclides at a seep 100-f eet dcunslope.
Cesium-137 and strontium-90 were present in seep water, having migrated 100 feet in less then one conth, due to fracture flow.
In comarison, I
the corrercial dispcsal trenches at Beatty and Hanford are excavated in a weakly cenented alluvial fill and unconsolidated sand and gravel, neither supporting fracture flow. The tepography and location of the Oak Ridge disposal sites pro-moted mi gration to surf ace seeps.
The trenches were excavated on hills, such l
that trench bottoms were higher than wet swamy areas downslope.
Thus, when the trench bottoms are saturated, a hydraulic gradient exists to drive flow to surface seeps.
The slopes leading from the wet low areas up to the disposal trenches are often in the range of 1:5 to 1:10.
The corr.ercial disposal sites at Beatty and Hanford on the other hand are characterized as flat desert areas with slopes on the order of 1:100 to 1:300, providing a n;th longer path between the trench bottoms and points where the surf ace are at equal elevation.
Also, the intervening raterial is undersaturated, and volumes of water which are cuch greater than available in the desert would be required to saturate the soil before any significant flew to the surface could occur (for example as would cause the swacpy regions associated with the Oak Ridge seeps).
Also, the solid wastes disposed at Beatty and Hanford are covered with three to five feet of dry sane raterials, which would absorb precipitation.
This provides some protection against the xcurrence of waste leaching.
Should water be suppcsed to enter a desert disposal trench, it would tend to be
- 4...
.g.
abscrted by the trench walls and bottor:s rather than collect in the trench bcttom, thus preventing saturation of the wastes and minimizing the tire of contact of wastes and water.
OUESTION Haw stable will vinyl ester plastic resin be which is supposed to encapsulate According to NUREG-0471, 'There are no current 5.
the decontamination wastes?
Therefore, what it the criteria for acceptability of solidification agents."
basis established by the NRC (and not Dcw Chemical or Comonwealth Edison) fo What consideration concluding this solictfication process will be acceptable?
has been given to the fact that organic solvents present in cuch radioactive
.este can disolve the Ocw solidification agent?
FESPONSE 5 The basic ferrulation of the Dew Chemical solidification process was developed The first solidified sarples in the late 1960s under the trade nam NMVAR.
of prototype test has remained free of liquid (since 1974 when the test was Analysis has shown that the longest lived significant isotope thati h half-life of 5.2 re de ).
will be solidified after the decontamination is Co-60 w t Tests have been perfor ed to demonstrate that the stability of the substantially alter for over 50 years, corresponding to years.
These tests include accelerated aging, biological solid polymer will not 10 half-lives of Co-60.
degradation, radiation degradation and temperature cycling (f reeze
~
resistance tests).
have decayed to less than 2,16 Cf.
The use of the 06w solidification redia' is eglicitly acthorized in the state of Weshington license issued to the Ranford, Washing *en corrercial waste The NRC staff has reviewed the Dew solidification process disposal operation.and has concluded that the solid waste form resulting from the process acceptable f or burial.
OUEST10N What the the traxirum levels of radiation exposure workers could receive while What are the epected levels of radiation 6.
carrying out decontamination?
If NS-1 is regarded as corrosive or a " strong ecosure workers stay receive?
chemical decontamination." (NUREG-0410), hcw can it be claimed that "it is essentially non-irritating when applied directly to the skin or eyes
...?
(Letter from D.O.E.).
l
.4.
s,
I i
RESPONSE 6 Workers are norra11y limited to 1.25 rem to the whole body per calencar quarter.
Hewever, in accordance with the provisions of 10 CFR 20 Section 20.101, a licensee may permit an individual in a restricted area to exceed 1.25 rem per quarter if
- 1) the dnse does not exceed 3 rem, 2) the total cumulative occupational dose to the whole bo(y shall not exceed 5(N-18) rers where "N" equals the individual and 3) the licensee has determined the individual's accurulated occupational cose The exposures at Dresden are expected to be maintained below these on Form NRC-4.
limits.
Durin; the decontamination regular industrial safety ceasures will be employed Experience to prevent all hazardous chemicals from contacting the skin er e l
QUESTION This How many truckloads of waste will have to be shipped and at what risk?
question has not been acequately answered because it is possible NS-1 will 7.
According to Mr. Lange, have to be flushed through the system more than once.
the absorption capacity of the solvent may be taken up by iron instead of
" crud" resulting in the predaction of twice as nach waste.
RESPONSE 7 The exact quantity of solid waste that will be' generated by the decontamination The uncertainty cannot be identified until the decontamination has been corpleted.
exists because it is the concentration of radioactivity that will limit the con-centration of waste placed in each barrel.
gallon drums Based upon Ceco's preliminary estimates, approximately 600 to 1200 55The number of ba of solidified waste cay be produced by the decontamination.
that will be placed on a truck depends on the radiation levels at the drum surf ace We estimate that and will not be known until the decontamination takes place.
between 10 and 100 truck loads of waste will be generated.
QUESTION What is the status of the NRC's consideration of the need f or an Env T
S.
Irpact Statement for the Dresten 1 decontamination?
RESPONSE 8 As stated in the Director's Decision on your petition, the NRC is preparing an You will receive a copy as environnental impact statement on the decontamination.The statement is exp soon as it is available.
May.
,1]Y~
T UNITTD STATES OF AMERICA NUCLEAR REGULATORY COMK!SSION OFFICE OF NUCLEAR REACTOR REGULATION MAROLD R. DENTON, DIRECTOR In the Matter cf CONEALTH EDISON COPPANY h
Dock et No. 50-10 (Oresden Nuclear Power Station (10 CFR 2.206)
Unit No.1)
DIRECTOR'S DECISION UNDER 10 CFR 2.206 By petition dated March 19, 1979, Ms. Kay Drey requested that the Nuclear Regalatory Ccmission (RRC) (the Comission) prepara an environcental i@act state:2nt on the Conron,<esith Edison Cotpany's (the licensee) proposed chemical decent emir.ation of the Dresden Mucletr Power Station Unit No.1.
This request has been considered under the provisions of 10 CFR 2.206 of the Cocznission's re g.'l a t i ons. Notice of receipt of the petition was published in the Federal Register April 16, 1979 (44 FR 22529).
By petition dated Septeder 20, 1979, Ms. Marilyn Shineflug, on behalf of the Illinois Saft Energy Alliance, requested public hearings on the decontamination based on the the lack of assurance that the NRC would issue an environcental icpact s tat eme nt.
Notice of receipt of the petition was published in the Federal Register _
Noveder 7, 1979 (44 FR 64577).
By petition dated March 13, 1980, Mr. Robert Goldsmith, on behalf of Citizens for Better Environment and Prairie Alliance supported Ms. Drey's petition requesting the preparation of an environcental inact statement.
Ms. Drty's petition raised seven questions related to tha decontaxination and asserts that these questions estabitsh a basis for the preparation of an environrental inact statement.
Ms. Shinaflug's petition raised an additional eight qu6stions. These questions ar.d the NRC staff's response to each question are contained in Appendix A attached to this decision.
M3@4 e'
-2 F
L yh The NRC staff has co@leted its environmental evaluation of the Dresden k;'
decont ami na t i on.
We have evaluated the occupational exposures estimated by the licensee, reviewed the construction of the support facilities at Dresden Station, 4
and have evaluated the system to be used to solidify the waste.
Based on this 3
re <1ew we conclude, as we concluded in 1975, that the decontamination will not
,N cause any adverse environmental i@ acts.
8 Although the results of the staff's review indicate that this action will not
[
significantly affect the quality cf the hur.an environrent, I have concluded that c
an environmental i@act statement should be prepared because of significant i nt e rest and concern expressed by members of the public relating to decontamination:
[
of Dresden Unit No.1.
The Comission's staff has, therefore, issued a Draft n
I Environrental Staterent.
l The questions raised by Ms. Drey and Ms. Shineflug and the NRC staff k
answers are incorporated as Appendix A to this statement.
1 L
CONCLUSION
)
Based on the public's expressed concern over this action and the i
s provisions of 10 CFR 2.206, I have determined that an environmental l
i@act statement should be prepared for Dresden Unit I decontamination.
j The requests of Ms. Drey and Mr. Goldsmith are, therefore, granted. The l
public hearings requested by Ms. Shineflug were predicated on the lack of I
assurance that the NRC would issue an environnental i@act statement. Since i
i i
the NRC has issued the statement, such hearings will not be necessary.
i l
a i
i
3-i O
i A copy of this decision and Appendix A will be placed in the Comission's Public Docurnent Roo:n at 1717 H Street, M. W., Washington, D. C.
l 20555 and the Local Public Docurnent Room for the Dresden Nuclear Power Station l
located at the Morris Public Library, 604 Liberty Street, Morris,. Illinois 60451.
The Draft Environmental Stater.ent will also be placed at these locations. A copy of this decision and Appendix A will also be filed with the SecNtary of i
the Comission for its review in accordance with 10 CFR 2.206(c)ofthe Comission's reg;1ations.
In accordance with 10 CFR 2.206(c) of the Comission's Rules of Practice, this decision will constitute the final action of the Comission 20 days after the date of' issuance, unless the Comission on its own motion
)
institutes the review of this decision within that time.
Y$
IWr_old R. Denton, Director l
Office of huclear Reactor Regulation Dated at Bethesda, Maryland this 26th day of June,1980 Attactrents:
1.
Appendix A -
Staff Response to Questions Contained in Petitions from the Public s
l
7[
T UNIT eD sT ATEs S
NUCLEAR REGULATORY COMMISSION h
I C AD4l**Q T ON, D. C, 20064 June 26, 1980
%,..... /
Dociet No. 50-10 l
Ms. Kay Drty 515 West Point Avenue University City, Missouri 63130-
Dear Ms. Drey:
This letter is in response to your petition dated March 19, 1979, requesting that an environ ental impact statecent be prepared concerning the proposed chemical de:or.taminathn of the priury cooling system at Dresden Nuclear Pwer Station Unit No.1. We haYe considered your request under the provisions of 10 CFR 2.206 of the Cocmission's regulations and have concluded that an environcental treact statenent should be prepared. Therefore, your petition for action has b:en granted.
A copy of the Draft Environ: ental Statement is enclosed.
A copy of this decision and Appendix A attached thereto will be plac 2 in the Corr::ission's Public Document Room at 1717 H Street, N. W., Washingt.n D. C.,
and at the Cormission's local Public Document Room at the Morris Public Library, 604 Liberty Street Morris. Illinois 60451. A copy of this decision will also be filed with the Secretary of the Ccccission for its review in accordance with 10 CFR 2.206(c) of the Comission's replations.
Because of the public interest that has been expressed in relation to this action the NRC staff vill hold a pubif e reeting in the vicinity of the plant to discuss our findings. The decontmiriation will not take place until the staff has evaluated all ccments on the Draft Environmental Statement and published a Final Enyt roncental Statenent.
A copy of the Notice of Issuance of the Director's Decision which is being filed with the Office of Federal Register for publication is also enclosed.
Sincerely,
/2fSb Harold R. Denton, Director Office of Nuclear Reactor Replation
Enclosures:
1.
Draf t Environmental Statenent (NUREG-0585) 2.
Director's Decision w/ Appendix A 3.
Notice of Issuance cc w/ enclosures:
See next page
I#
Ms. Kay Drey
, Juna 26,19B0 Ce Isham, Lincoln & Beale Dirteter, Technical Assessment Counselors at Lew Division-One First National Plaza. 42nd Floor Office of Radiation Progrars Chicage, Illinois 60603 (AW-459)
U. S. Environmental Protection Mr. 8,' B. Stephenson Agency Plant Superintendent Crystal Mall #2 Drtsden Nuclear Power Station Arlington, Virginia 20460 Rural Route il Merris, Illinois 60450 U. 3. Environmental Protection Agenqy U. S. Nuclear Regulatory Cor.tnission Federal Activities Branch Resident Inspectors Office Region Y Office Drtrden Station ATTN:
EIS COORDINATOR RR #1 230 South Dearborn Street Morris, Illinois 60450 Chicago, Illinois 60604 Susan N. Sekuler Mr. D. Louis Peoples Assistant Attorney General Director of Nuclear Licensing Environmental Control Division Commonwealth Edison Company 188 W. Randolph Street Post Office Box 767 Suite 2315 Chicago, Illinois 60690 Chicago, Illinois 60601 Morris Public Library 604 Liberty Street Morris, Illinois 60451 Chairran Board of Supervisors of Grunty County Grundy County Courthouse Morris, Illinois 60450 Departrent of Public Health ATTN: Chief. Division of 4
Nuclear Safety 535 West Jefferson l
Springfield, Illinois 62761 i
6 t
m