ML20049H167

Partially Withheld Commission Paper Re Petition for Hearing Re Proposed Decontamination of Dresden Nuclear Power Station

ML20049H167
Person / Time
Site:	Dresden
Issue date:	12/02/1980
From:	Malsch M NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:
Shared Package
ML20049A457	List: ML20049A456 ML20049A612 ML20049H021 ML20049H150 ML20049H152 ML20049H153 ML20049H156 ML20049H157 ML20049H158 ML20049H161 ML20049H162 ML20049H167 ML20049H175 ML20049H224 ML20049H226 ML20054K065 ML20055C161 ML20055C162 ML20055C164 ML20055C168 ML20055C169 ML20055C170 ML20055C171 ML20055C172 ML20057B502 ML20057B511 ML20057B512 ML20057B515 ML20057B516 ML20057B520 ML20057B537 ML20057B538 ML20057B545 ML20057B547 ML20057B549 ML20057B552 ML20057B554 ML20057B555 ML20057B560 ML20057B561 ML20057B563 ML20057B565 ML20057B566 ML20057B568 ML20057B571 ML20057B573 ML20057B574 ML20057B576 ML20057B577 ML20057B579 ... further results
References
FOIA-92-436 SECY-A-80-188, NUDOCS 8110300072
Download: ML20049H167 (86)

Text

n -

, * ~.

e 1

UNITED STATES

(.

NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 CONSENT CALENDAR ITEM SECY-A-80-188[

~

December 2, 1980 Ul DGMY~

For:

The Commissioners From:

-Martin G. Malsch Deputy General Counsel PETITION FOR A HEARING IN THE MATTER OF THE

Subject:

PROPOSED DECONTAMINATION OF THE DRESDEN NUCLEAR POWER STATION Discussion:

Background

Commonwealth Edison Company (CECO) operates the Dresden Nuclear Power Station, Unit No. 1.

On December 19, 1974, CECO proposed to shut down the reactor and chemically decontaminate the fac-111ty's primary cooling system.

(Attachment 1)

The proposed chemical cleaning program was based on extensive research which led to the formulation of a new cleaning compound and_to the determina-tion of the corresion effects th~at~compoundowould have on various reactor. materials with whichlit.7--

would come in contact during the cleaning process.

CECO also initit,ted a program to evaluate the effects of decontamination on primary. system inte-grity.

The NRC's regulations (10 CFR 50.59) pro-vide that changes in the facility or operating procecures which create an unreviewed safety ques-tion cannot be mtde withod an amendment to the operating license.

Although CECO took the posi-tion that the cleaning program presented no unre-viewed safety questions, CECO conceded that the return to power after cleaning was outside the scope of the original safety avaluation for the facility.

Accordingly, CECO stated that if the

!aformation in this tccctd was dMd NRC deemed a license amendment to be necessary for a return to power operation after cleaning, in accordance with the f rfidom of inictmatianCECo would apply for an amendment to Dresden's Act, cramptions f

d echnical Specifications.

On April 1, 1975,. CECO

[01A_g2-R.7j--

informed the NRC that the development of Techni-cal Specifications for post-cleaning operation would require additional time, and requested

'y--

interim authorization to conduct the cleaning

'x j, program with the return to power contingent upon bl!DBOU M

~

K0' the completion of several open items.

(At tac h-y(

91f(J ment la) 1 l

CONTACT:

3

____.s

s Y

1 w

A 2

I

.. i

,: r,

" y' Previous Staff Action On December 9, 1975 the7NRC authorized CECO to 1

initiate the proposed chemical decontamination of Dresden without requiring any' license amend-ments.

(Attachment 2) 1/

This authorization

~

was contingent on CECO's completion of three unresolved items: (1) completion of a testing 4

program to be reviewed and approved by NRC prior to chemical cleaning; (2) submission of a pre-service inspection' program for NRC review and approval prior to the return'to power operation; and (3) submission of a post-cleaning surveillance program for NRC review and approval prior to the return..to.. power oper.at. ion.

A two and one-half pageT5Efety_svaluatioh d6W6spidi~ed.".I'?f"~

the NRC decision.

In that~ evaluation, staff reached no conclusions'about'the possiblelexis--

~

tence of unreviewed safety questions _but concluded that authorization of initiation of the program l

was warranted because staff anticipated the successful resolution of the unresolved issues.

l' i

/!kf 1/

Staff also found that the project did not involve a significant hazards consideration.

o 3

s R

Thus, a fai reading i

i as is discussed below, f

/

Current Status Since the staff's authorization in 1975, CECO has completed construction of the support fac-ilities needed to carry out the project.

On November 14, 1979, CECO applied for amendments to two Technical Specifications: (1) deletion of the requirement to maintain primary contain-ment integrity during the chemical cleaning when all fuel will be removed from the reactor; and (2) exclusion of radioactive liquid storage tanks (which are inside seismically qualified struc-tures) from the above grade storage curie limit.

( Attachment 3].

f i

Y Petitions Between late 1979 and early 1980, three petitions were filed 2/ pursuant to 10 CFR 2.206 request-ing the NRC to prepare an environmental impact statement (EIS) and hold a public hearing on the proposed decontamination.

On June 2 6, 1980, the Director, NRR granted the requests for NRC pre-paration of an EIS and enclosed copies of that

~2/

Petitioners were Ms. Kay Drey, Mr. Robert Goldsmith, on behalf of Citizens for a Better Environment and the Prairie Alliance, and Ms. Marilyn Shineflug, on behalf the Illinois Safe Energy

i 4

statement with his replies to the petitioners.

The Director denied the request for the public hearing because that request had been premised on the lack of NRC assurances that it would prepare the EIS. 3/

On July 8, 1980, several persons and groups, com-prised mainly of those who had previously peti-Commission to hold hearings o,1y petitioned the.

tioned under 2.206, 4/ joint.

n Ceco's application for a ' license amendment and on the BIS related to the proposed decontamination { Attachment '4);

In addition, petitioners contend that a proper deter-mination of "no significant hazard" has not been made regarding the proposed chemical decontamina-tion and that a proceeding to make such a deter-mination and a hearing are required.

us we consider

/

3/

See SECY-A-80-101.

4/

The only new petitioner is Ms. Bridget Rorem; Ms. Drey and

~

Ms. Shineflug are now individual petitioners and not just representing their respective organizations, and Mr. Goldsmith is no longer a petitioner but, in s tead, is representing them as counsel.

m..

aj I

8 7

,y y

ij.~1../[ lj'.6/%.--.

Martin G. Malsch Deputy General Counsel Attachments:

1.

CECO letter 12/19/74 la. CECO letter 4/1/75 lb. CECO letter 4/16/75 2.

NRC letter 12/9/75 2a. Staff memo 5/29/80 3.

CECO letter 11/14/79 4.

Petition for Public Hearings 5.

CECO letter 11/14/80 6.

Draft-Order

]

Comissioners' coments or consent should be provided directly to the Office of the Secretary by c.o.b. Wednesday, December 17, 1980.

i e

+. =. = ~.,.

Comission ' Staff Office co',ments',1f'a'ny; ~should'be submitted-to the.Comissioners NLT December 10,1980,~with an~ information copy.to the.0ffice of the Secretary, j

If' the paper is of such-a nature that it requires ' additional ~ time for analytical review ard comment, the Commissioners and the Secretariat should be apprised

-i of when coments may be expected.

j This paper is tentatively scheduled for affirmation on'an open meeting during the week of December 22, 1980.

Please refer to the appropriate Weekly Comission Schedule,'when published, for a specific date and time.

q DISTRIBUTION Comissioners Comission Staff Offices Secretariat 1

_ e y

w m,

M [\\ ' one hrst Hebonal P 42a, Chicago. Encis Commonwealth Edison -

~

i

/

'i

.C g

\\ (A a~/ Acorcss Reply to: Post Othce Box 767

',,e Chicago. Ilhnois 60590 55h.

=.=...:

~~'

December 19, 1974 z==

,. /.~~' p

,/. * ;: --.. t Mr. Edson G. Case

~

i

. ~.

Acting Director

>f/

-f

"[

/

l

.r y

Directorate of Licensing Office of Regulation

\\}, ^ - g,:-

\\

U.S. Atomic Energy Co:r:nission Washington, D.C.

~20545

Subject:

Dresden Station Unit 1 " Chemical cleaning Licensina Submittal", AEC Dkt. No. 50-10

Dear Mr. Case:

If deemed necessary by Onsite and Offsite review, Commonwealth Edison will_ request by March 1975.an amendment to DPR-2.

The purpose ' of this amendment wi" A be to incorporate into the Technical Specifications primTJy system boundary structural -intecritv : limits which are 'a".iecuate to allow power

,d

(=gi: ooeration of the unit followinc thAchemical cleaning-discucced

'=r '

in the attached report "Dresden Unit 1 Chemical Cleaning Licensing Submittal".

The following areas.will be considered in developing the proposed Technical Specifications change.

1..The existing metal surveillance specimens are-being evaluated i

for.ssefulness in a continuing program after chemical c1 caning.

• 2.

In addition, various metal specimens will be fabricated and installed in the reactor prior to the cleaning.

some 6se specimens will be removed for metallographic examination immediately after the cleaning.. others wi,11 remain in the reactor and be removed during succeeding refueling outages for metallographic examination.

i The exact materials to be included in the program cannot be specified. at this time., because they may be -li2nited by the space available for er:posure in subsequent service.

At the minimum, they will consist of sensitized and as-l welded 304SS, 4105S, A3023, and sensitized and as-welded l

9

';ncenol 600.

liopefully, other materials of interest can

• ' (.5 s

• s-s*v i

Mr. Edson G. Case pfg.3 Page Two E5f December 19, 1974 also be included and these will be chosen when it is known that space is available. As many materials of current and potential future interest will be. included as is practical. 3. As part of the post-cleaning acceptance, a representative-number of welds will be examined prior to the cleaning to determine as accurately as possible the characteristics of the indication. Following the chemical cleaning and during at least two subsequent refueling outages, these same welds will be reexamined to determine any change in the characteristics of the indication, which might be attributable to the chemical cleaning process. The licensing submittal contains an evaluation of the safety considerations involved in returning the primary coo 3 nnt system to service following the chemical cleaning. This evaluation will serve as the basis for the proposed Technic.21 Specifications which are being prepared for submittal. by March .;.. z_._ 9..=i=. ? 1975. One signed original and 39 copies of 'this licensing N sub=ittal are provided for your review. Very truly yours, iq, . S. Abel Nuclear Licensing Administrator Boiling Water Reactors / Attachment

0;;b::.::. was _ = -. I i i + DRESDEN I r CHEMICAL CLEANING g. t LICENSING SUBMITTAL t t u 12-16-74 \\ t i i i b f h I k f 5 1 4

0-c' CONTENTS ....e_ scr ' Z~ I. Summary II. Introduction to Cleaning Program III. Process Development Program A. Evaluation Of Alternatives B. _ Solvent development C. Loop test D. CPS (Argonne) demonstration E. Pilot testing F. Full scale cleaning G. Solvent quality control IV. Material Compatibility A. Material identification

!;!?jff B.

Materials test program - - :g - 3: C. Irradiated metals testing D. Residual solvent effects V. Facility Safety Evaluation and Design Basis A. Summary B. Source terms C. System design and performance D. Safety evaluation VI. Post Chemical Cleaning A. Quality assurance B. In-service inspection VII. Schedule 4

l 1 j i 1 Ju;=_ I.

SUMMARY

i n=== It is the purpose of this document to provide an overview 1 of the research, development and engineering that has been carried out to insure the feasibility and safety of Dresden Unit 1 chemical cleaning. The Dresden Station Unit 1 chemical cleaning program has been established on the basis of an extensive development pro-gram, as discussed in parts III and IV. Enenulation of a new chemical cleaning solvent was found to be naeattaty because exisfins icwhniques were inertective. The new solvent has been demonstra ted to provide sufficient reduction in radiation levels to improve plant access significantly. It has been.shown to be compatible with the materials in the Dresden. Unit 1 primary system. Furthermore, a program of post chemical cleanin_g ~ assessment has been established to evaluate _the effects _on the primary system integrity. possible public hazards and environment effects of the chemical cleaning program have been considered in develonment of the cleaning procedures and chemical cleaning system design. The procedures and design will preclude any new or adverse effect to the environment or the public. The full-scale cleaning of Dresden Station Unit 1 primary =_ system is scheduled for the first half of 1977. =- N

2 II. INTRODUCTION TO THE DRESDEN-1 CLEANING PROGRAM .= = =?fif Recent studies of occupational radiation exposures at f operating U.S. light water reactors show a three-fold increase in yearly average exposure per plant between 1969 and 1973 (188 man-ren in 1969 compared to 544 man-rem in 1973). Roughly 80 percent of this exposure is received in performance of plant maintenance. Certain individual plants have shown auch sharper year-to-year increases due to the necessity of performing repairs in high-radiation areas. At one plant, operational exposure for example, increased from 834 man-rem in 1972 to 5160 man-rem in 1973, due largely to the repair of defective welds. At Dresden Unit-1, radiation levels have also shown sig-nificant and consistent increases. Commonwealth Edison re-cognizes that access to primary components is necessary. A method of reducing occupational radiation exposures at its operating pl ants mus t, therefore, be developed. One tool to accomplish this is total plant decontamination. Oow Industrial Service was engaged to evaluate existing technology and, if necessary, develop new technology for the total de-contamination of Dresden Unit-1. Existing technolocy was found inadequate. A new solvent was thu's developed and tested on contaminated samples taken from Dresden-1, with very promising results. They are now comoletin_g a comprehensive ma teri al s-tes ting program enconnattinc AII Draemen-i oressure rounuary naterials. A preliminary design for facilities, IyTtems and equipment required to implement a full scale + decontamination of Dresden-1 has been developed. A s In establishing this program, the following goals were identified as being of primary importance: 1. Paduce radiation levels to improve plant accessibility 2. Ensure future safe and efficient operation of Dresden-1 3. Develop and prove techniques usable on other reactors a. Encourage broad vendor, manufacturer, and consultant participation This project is being managed by Commonwealth Edison with Dow Industrial Service Division of Dow Chemical Company serving

3 as Edison's prime contractor. Suntac Nuclear Corporation, a subsidiary of Catalytic Construction Company and NUS, is Dow's ,!EEEi subcontractor for architectural, engineering and construction Es-activities. In addition to the above participants. Edison has con-tracted with the following to serve as consultants: 1. The Nuclear Energy Division of General Electric Company 2. Craig F. Cheng of Argonne National Laboratory 3. T. A. Hendrickson of Burns & Roe, Inc. 4. Roger W. Staehle o'f Ohio State University i b

4 III. PROCESS DEVELOPMENT PROGRAM d#iht- _"55f A. Evaluation of Alternatives i Various methods of radiation level reduction have been ~ considered. These can be grouped into four categories: 1. Mechanical Cleaning 2. Water Flushing 3. Operational Techniques 4. Chemical Cleaning l Evaluations of each of these categories, and of numerous sub-categories were performed, and are summarized in TABLE I. Of all the techniques evaluated, chemical cleaning appears to be the only one capable of providing significant reductions in plant radiation levels. B. Solvent Develoonent F _: : = The-ineffectiveness of the known solvents discussed in part 4.a of TABLE 1 can be attributed to the chemical differ-ences between deposits formed in BWR and PWR primary systems, for which mos t of them had been developed. This led'to the need of developing a new solvent for the Dresden-1 project. The greater difficulty in removing the film from BWR plants compared to PWR's is based on the greater stability of the film produced in the more oxidizing environment of the former. In general, oxides deposited f rom the more oxidizing solutions tend to be more insoluble, since higher valent oxides are more stable. The criteria for this new solvent include the following:

1. Greatest possible reduction in radiation levels 2.

Complete dissolution of film 3. No reprecipitation and redeposition 4 Low corrosion rates 5. One-solution treatment

.f 1!! b l [i ~ ur TABLE i ALTERNATIVE METHODS FOR REDUCING RADIATION LEVELS IN DRESDEN-1 l Reduction _. Method Advantages Disadvantages _ Evaluation Mechanical Cleaning a. Brushing, wiping, S'imple - No chemical was te Not highly effective Cannot be used as scrubbing 1. scouring Filtration disposal Access not possible a solution to in many areas total problem High personal exposure b. Poly-pig (pumped Waste handling cased Applies only to piping Does not meet scouring projectile) Technique available High radiation expo-program goals sure for reduction l Access not possible of radiation in many areas levels Leaves residue l c. Ultrasonic cleaning Mo system modifications liigh radiation expo-Does not meet l required sure program goals Waste handling cased Access not possible for reouction in many areas of radiation Gives only localized levels effect d. Component replacement Achieves minimua Expensive Cannot be used as radiation level High radiation expo-a solution to the ~ sure total problem Partial solution only Consider supple-Haste disposal diffi-mental use for cult certain problem areas u, 9 ,,r-e -r ,-.s .-n e

o glplih' MH T l TABLE I .(Con t i nu ed ) I Reduction Method Advantages Disadvantages Evaluation l I I Water Flushing ~' a. Fill & drain Simple - No significant Ineffective on scale Does not meet additional equipment and crud traps program goals for, reduction of ra-diation levels b. liigh pressure Waste handling eased Piping access diffi-Does not meet jetting cult or impossible program goals for without major changes reduction of Not effective without radiation levels I chemical addition Requires extensive' Airborne contamination Pressure boundary l problems disturbance e i 3. Operational Techniques a. On-1tne chemical No or minimum outage Proven or even prom-Not feasible at l addition (transport Provides on-going solution ising method unknown this time i i deposit to cleanup for future at this time I system) Licensing / safety questions difficult to answer l / ? b. Improve feedwater Minimite future buildup long response time Does not meet Does not remove scale program goals for or crud trap material reduction of Does not affect pri-radiation levels mary system generated corrosion products m t ~ m. .4 m

b e!* ,.ci !!p! 'li!!!f iI!!!d! TABLE 1 (Continued) Reduction Method Advanthges Disadvantages Evaluation 4. Chemical Cleaning a. riushing with existing Techniques well known Extensive corrosion Does not meet solvents shown below: Treats total system testing required goals for re-No substantial system large waste disposal duction of radi-modi fica tion required problem ation levels Low decontamination factors Lower solubility than desired EVALUATION OF DECONTAMINATION SOLVENTS DESCRIBE 0 IN Tile LITERAL'URE WITil DRESDEN 1 SPECIMEN i Code Name Chemical Formula g[1 Conditions of Use Decontamina tion Factor for Cobal t 60 APAC (Shippingport'1964) (AP) KMnO 13 24 hrs. 121*C 1 4 Na0H 100 (RC) (Nil 4)2)(C 0 0657 s. 1.15 AP-Citrox (PRTR 1965) (AP) KMnO 30 2 hrs. - 105'C 1 4 Ha0ll 100 (Citrox) HC0 25 224 (Nil )2 tlc N 0 50 3 hrs. - 81*C 1.15 4 657 Fe (50 )3 2 2 4 diethyl thiourea l 00% ll P0 (Dresden 1968) 4 4 Il P0 600 4 hrs. - 121'C 2.0 3 4 y 6

~e "~ 4 , t, Il! ^ ~ p

jr i"

l i' . ~t s EVALUATION OF "KNOWN" DECO,TAMINATION SOLVENTS USlHG N CONDITIONS DIFFERING FROM " Tile LITERATURE" Conditions Decontamination Reason For-l- Code flame Chemical Formula 3/1 of Use Factor for Cobalt 60 Rejection A l' Na0li 10 12 hrs. - 97*C 1 Low DF KMN0 30 4 4)2lC "5 7 100 pil 5 450 Insufficent removal ACE ( Nil 1 0 6 of fissi n Products & 130*C EDT A+ NH 011 0.4 100 hrs; 4 sloughing } inhibitor l Citrox 11 C 0 24 pil 2.4 780 ~ Corrosion 224 ilC "5"7 50 100 hrs. - 130"C ( Hil4)2 6 Fe(NO3}3'9"20 2 inhibitor 130*C 45 Sloughing and low DF ilC "5 7 100 100 hrs. AC ( Nil 4)2 0 6 inhibitor l Sulfox 11 50 30 100 hrs. - 130*C 928 . Corrosion 2 4 ll C 0 9 t 224 inhibitor } (AP)(AC) Each used in sequence; formulated etc, 547 2-stage system anr! as above AP and AC sludging l (AP)(ACE) Each used in sequence; formulated etc, 230 2-stage system and i as above AP and ACE sludging (AP)(Citrox) Each used in sequence; formulated etc, 1350 2-stage system and as above AP and Citrox sludging ^ co v-, .-r-..

,ill,:". ' [

• 4

!!!!!!J b. New solvent flushing Techniques well known Extensive corrosion Effectiveness (NUTEK-L106) Treats total system testing required questioned No substantial Large waste disposal Test resul ts not modification required problem (demin resins) available Low decontamination Cannot consider, factors at this time Lower solubility than desired c. New solvent flushing Same as 4.b Extensive corrosion Appears to be th Dow Solvent NS-1 Single phase system Testing required best alternative close to 100% solu-Waste Processing to achieve pro-bility required gram goal r liigh decontamination l factors liquid waste problem l reduced by factor of 2 to 3 over known solvents t 8 9 l I l I f f I 1 M) { . _, ~

10 5B@pt In order to develop such a solvent for the actual film ~EM.:7 (adherent to surfaces) and sludge (non-adherent) at Dresden-1 a series of samples was obtained from the plant and tested with different solvent formulations. These samples included hand-hole covers, from the B and C Secondary Steam Generators, and pipe specimens from the cleanup loops. In addition, samples of sludge were vacuumed from the bottom of the reactor pressure vessel to determine the type of material to be found in loose deposits throughout the system. Analysis of the corrosion products on pipe surfaces showed the material to be a spinel-type metal oxide, high in nickel and/or chromium. The final solvent Dow Solvent NS-1, was demonstrated to give decontamination factors ranging up to 1000 on the various specimens containing the radioactive film from the reactor primary system. This range comes about from the experimental results in which the most highly radioactive specimens show the greatest percentage reduction in activity, while all samples tend toward a similar, low level of residual activity. At least three possible explanations for the residual can be offered: 1. Exchance of radioactive metal atoms with the surface of the base metal. 2. Diffusion of radioactive corrosion products into grain boundaries in the base metal. 3. Very minor activation of base metal. by' ~ the neutron flux arising from iY,n)-reactions on deuterium in the water. Since these residuals are very low -- usually under 0.1 mr/hr on the test coupon inner surfaces -- an overall decontamination to low levels is confidently indicated. Estimates of the total quantity of film vere made by consideration of the radiation levels throughout the system, based on actual measurements at the site. Various approximation methods yielded a figure of about 3000 curies (+ 1000 curies), primarily cobalt-60. Consideration of the specific activity of the sludge and film samples led to an estimated quantity of 450 to 1100 pounds of total deposit te be dissolved during the cleaning operation. C. Loco Test A special test was carried out to determine the ef fectiveness of the solvent under deadleg conditions. The test was desigree to show any possible redeposition onto clean metallic surfaces. It was also capable of detecting undissolved sludge wnich might be transported to other locations within the loc;. For this purpose, the Dow Industrial Service Dynamic Test Loo; was em:leyed. A special stainless steel spoolpiece cer.tairi ; :hree serpie wells (deadlecs) and filters was con-c:octe: an: i-stal e: w":-i-tne circulating loco (see FIGURE 1).

j =., - 11..

=.=..

h5E

== i FIGURE I HIGH PRESSURE. CIRCULATION LOOP l t ) Filter 1 f i b 2* 5.5. Pipe Sample Holder-f i 1 2..... ~TJsiie No. 3 I9/ e No. 2 i ~ Steam Control .No. 1 .I N _f s re =3' Flow Control ^ gb* . M p / Pump Reservoi i x i I I m y i t a f 'Q' k e f r i .w.e.wa** i

12 A total of thirteen test coupons were mounted on two different sample holders which, in turn, were placed in two me =+s deadlegs for this test. Seven coupons were contaminated metal '= 5:3 specimens cut from the primary system of Dresden Unit-1. The remaining six specimens were material test coupons with clean surfaces representative of the materials of construction of the primary system. The solvent was circulated at 21 GPM which represented a linear velocity of 2.0 ft./sec. in the pipe section adjacent to the deadlegs. It was heated to 250*F, the temperature of the intended cleaning of Dresden-l. Shortly after the test started, it was observed that the activity spread almost uniformly to all parts of the system, indicating + rapid dissolution of the film. At the end of 75 hours, the test was interrupted and specimens were removed, rinsed, and. counted for total radioactivity. They were once again returned to the loop until a total of 100 hours exposure time had elapsed. The specimens were once again counted. Decontamination factors ranging from 114 to 936 were found for these specimens, with the highest factors occurring in the case of the most contaminated coupons The lower decontamination f actors were measured for specimens that had been pre-cleaned ultrasonically prior to the solvent exposure. Noticeable reprecipitation or plating of radioactive components did not occur. The results indicated acceptable performance of the solvent under these dynamic conditions. D. CP-5 (Arconne) Demonstration s The Dow Solvent NS-1 was recently used to clean a stainless steel heat exchanger in the CP-5 reactor at Argonne National L a b o ra t o ry. This exchanger, used as the main' heat sink for the reactor, has been in service for 15 years. It had experienced severe water-hardness deposit and bacteria, impeding heat transfer. The solvent was used with a microbiocide additive to remove this deposit. The solution was circulated through the cooling water side of the exchanger for 24 hours at 120*F. This treatment resulted in a 2.5 fold increase in heat-transfer capability and a 50% reduction in pressure drop across the system. No physical examination of the exchanger was possible after the cleaning, but stressed stainless steel test coupons were installed before the start of the operation and were examined metallurgically after the cleaning. There was no evidence of any adverse effects. The heat exchanger has been in normal service since the cleaning in early September, 1974, with no evidence of deterioration.

13 This chemical cleaning at Argonne is not direct engineering proof of the ability of the solvent to remove BWR-corrosion gs c._ product scale, nor is it complete evidence of its compatibil-6.;2# ity with stressed stainless steel. However, this operation has -EM= tiven experience with the solvent under field conditions and ,as added to our laboratory data. E. Pilot Testino Prior to actual full-scale cleaning at Dresden-1, if feasi-ble and practical, a test of the solvent and cleaning process in a pilot plant model will be carried out. The EBWR reactor at Argonne National Laboratory is currently being considered as a candidate for this pilot. The intent Ts to perform de-tailed before-and-after materials examination; 'This will en-sure that a field condition test will have been,.run in addition to the extensive lab testing. A section of the EBWR primary system will be isolated and the solvent circulated through that section under the actual temperature and pressure conditions expected for the Dresden-1 cleaning. It is anticipated that the isolated section will include representative piping and materials similar to those existing in the Dresden-1 plant. Prior to the pilot plant test, an intensive liquid penetrant and volumetric surf ace examination of the sections to be tested will be performed. The same testing will be conducted after the cleaning and flushing procedure. Any anomalies will be investigated thoroughly. _ : :+- _ F. Full Scale Cleanino The actual full-scale;chemica-1 cleaning of-~Dresden-l~is-expected to be accomplished within~ a-two~-week' time span. Written procedures will be developed to control the sdminis-tration, ope ra ti on, and emergency responses during the clean-ing. Prior to using chemicals in the system, a full-scale trial run with demineralized water is planned with the fuel removed. Following a successful trial run, the chemical clean-ing process will begin. The entire procedure will consist of seven steps:

1. Preparation of the primary system and water trial

2. Addition of chemicals

3. Chemical cleaning 4

First water flush and rinse 5. Subsequent flushes and rinses as needed 6. Recommissioning of plant 7. Treatment of waste

i 14 i The first five steps describe the actual chemical cycle azuse of the process. Following removal of the fuel, the primary l "E{if system (See FIGURE II) will be filled to operation level with ~~~ demineralized water. Auxiliary heating equipment and the reactor recirculating pumps will be operated to heat the metal surfaces to 160-200 F. Premixed chemicals will then be injected into the circulating system through an auxiliary i piping system. The same heating methods will be used to raise i the temperature of the system and maintain it at 250*F. for a;: expected 100 hours. Various circulating schemes will be utilized to insure good solvent / system contact. Extensive radiochemistry, wet-chemistry and radiation monitoring techniques j will be employed to follow the cleaning process. Emergency procedures will be developed to handle laakage or equipment j failures. Equipment and piping of the chemical cleaning sys-tem has been designed so tha t any leakage *cr failures will be contained and processed in controlled areas. At any t'me dur-1 ing the chemical phase, the major equipment pieces (RPV, Steam Drum, SSG's, etc.) and connecting piping in the system can be rapidly drained to minimize the consequences of unforeseen events. When indicated by analytical results and agreed upon by the controlling parties, the solvent will be drained to i holding tanks. The system will then be flushed through stra-l tegic points. A complete water fill, recirculation, and heat-ing cycle will follow to rinse the system. The rinse and drain procedures can be repeated as indicated by chemical _f.:=s analysis to assure removal of solvent *from the system. Follow-E+:2;E ing the chemical cleaning, the plant will be available for extensive inspections and maintenance of comp ^onents. Radio i ,= active waste will be stored, concentrated, and solidified for disposal. s G. Solvent Ouality Control Material compatibility testing.as defined'in Section IV, will be utilized to define an envelope of operating conditions within which the chemical cleaning will be conducted. The envelope will define limits in the following areas: 1. Operating temperature range 2. Maximum solvent contact time 3. Maximum-minimum solvent component concentrations 4. Maximum-minimum corrosion-inhibitor concentration 5. Maximum allowable golvent-impurity concentrations (e.g. C1~, F~, Pb S~~, etc.) E. pH limita tions 7. Oxygen concentrations

.7, .j i Figure 11 PRIMARY SYSTEM ...y._.. i PRIMARY { "" ~ "" * ~ ~ "S TEA M PRIMAR Y STEAM DRUM y l ~( \\ o 3 (O 03 N PRIMARY VENT FEED WATER s u 1 RISERS eve REACTOR F -- ---] , r i l CORE l L -- - J DowncOMERS ^ $ r s UNLOAD HEAT EXCH. SEC. STEAM \\n/ RECIRC. PUMP' CLEAN- ~ n UP DEMIN. r a w n DOW INDUSTRIAL SERVICE DIV. T32 DOW CEEMICAL COMPA.N7 i

i, 16 GbZ. -?555 Solvent analyses will be conducted in order to monitor-cleaning and decontamination progress. These solvent analyses will include the following: 1. Fe 2. Ni ~3. pH 4. Residual sol vent capacity. i 5. Gamma ray counting (primarily'for cobalt 60) 6. Cu 7. Oxygen 8. Redox potential 9. Temperature wggs This series of tests will be used as input to determine AE{![ the effective end poin.t.of..the proces.s. s b

s a .~ - 17 IV. MATERIAL COMPATIBILITY . = = _

• 255/59 4223" Since the solvent is active 'and has been shown to provide an effective means for removing the Dresden 1 film, we.have also considered adverse eff ects of the solvent on materials of construction.

A program has been organized to evaluate the following: 1. The ef fect of the solvent _on the materials of m nstruction during the cle3ning ornc#ss 2. The possible residual effect of the solvent an the materieis vuring suosequent operation of the plant Work to evaluate these concerns has been conducted primarily by Dow Industrial Service but confirinctory work has been at General Electric Company, Argonne, and Ohio State University. A. Materials Identification In order to evaluate the compatibility of materials of construction with the solvent, it was necessary first to identify such materials. This matter demanded particular .m_ .=.Jfss attention because of the age of the plant. A major effort Lak was, therefore, organized to identify the following: 1. Materi al s which will be exposed to the~ ~~~ ~^ solvents 2. Heat treatment and fabrication conditions of these materials 3. Crevices and similar geometric configu' rations where solvent might sequester or where crevice corrosion attack might occur 4. Locations where two metals are connected and where galvanic corrosion processes might occur 5. Existence of other materials such as gaskets or bearings which might dissolve, slough, leach or absorb chemicals during the cleaning or subsequent operation In order to obtain this information, Dow engineers thoroughly analyzed the system by conducting:

s i = gr= tw .w e 18 1. A search and study of the available drawings and records -~~ 2. An inspection and study of the Dresden-1 primary system 3. A review of original records from vendors and suppliers From these ef forts, it was possible to establish an inventory of materials and conditions. The materials identified are listed in TABLE II. TABLE III summarizes the various bi-metallic coupled and crevice configurations. The information in TABLES II and III was used to organize the materials testing program. All of the materials and conditions identified in these tables were incorporated into the materials test progrem. In certain cases it was necessary to substitute similar materials for lack of availability of the exact alloys. All of these substitutions were reviewed and approved by Commonwealth Edison and the consultants. B. Materials Test Procram ~: :Az, A major effort was made to evaluate the compatibility ~ of materials.of construction with the cleaning solution. r: .:.s The test program was designed to evaluate the foT1owing:- s 1. Alloy chemis try 2. Alloy heat treatments including sensitization of stainless steel and temper embrittlemen+ of low-alloy steels 3. Environmental conditions, including the effects of impurities such as oxygen, halides, sulfur species, as well as dissolved corrosion products 4. Effects of crevices, bi-metallic junctions, surface conditions, welding and applied stresses 5. Effects of prior irradiation of the structural materials

.n_. 19 '~ II TABLE Materials Found in Dresden-1 That Will Contact Chemical Cleaning Solution

=.. =

NiETTEDMATERIALS: AISI ASTM ASME 302 A53-B SA48-25,30 303 A105-2 SA53 304 A106-B SA105-2 1 316 A155-KC70 SA107-1137, 1141 347 A167-3 SA108-1035 410 A182-F304, 304 ELC, 316, F22 SA113 416 A193-B8, 416 SA120 816 A194-B, 1 SA132-304 B113 A212-A, 8 SA155-2-1/4, CL1 C1040 A213-304 SA182-Fil, F6, F304 C1045 A216-WCB SA194-C12H C1213 A240-304, 304L, 405 SA216-WCB, WCA A249-304L SA217-WCL, WC9 A264-304L SA234-WP22 WP22W WPB, WPE A268-405, 410 SA266-2 A269-321 SA269-304 SAE A2 7 6-304, 410, 410H, 4 20 SA278-25 A296-CA15 SA285-C SAE 40 (Brass) A298-304L, 308, 309 SA298-308L. 209 _.n_. S A E 6 4 A302-8 SA335-P11 52!s2AE 660 (Bronze A312-304, 316 SA336-F8 ~E5E4AE 1112 A335-F1, P22 SA351-CF8 <4 ~ A336-F1 SA358-5 A371-309' SA403-WPW 304, WPW 326 A376-304 SA511-MT321 ' A479 SB30 SB62 A516-70 ~ SB143-A2 ASB2 B371 SB145-4A P-3442B OTHERS Asbestos Carpenter Mirromold Cast Iron C130 Co-Cr-W Alloy ( AWS-5.13) Copper Copper and Neoprene Everdur Flexrock 401 Ga rlock 24 Graphitar 14 Haste 11oy C Haynes - 25, 21 .Inconel

'onel

.hrile Si-5ron:e 5.ete 6 ~F '.7 4?h

~ y TABLE III 20 BIMETALLIC JUNCTIONS OF WETTED MATERIALS IN ORESOEN-1 d??% +:ee ~ ~~;22~ Junction Material Equipment Piece 303-304* G-17 304-304L* C-2, C-3 304-316* G-17, Pipe: C-1, Valves: SP115M2, 108M2, SP213-M2 304-347* G-17. Yal ve : 108M2 304-405* F-4, F-16 304-410* C-2 304-410H* F-16 304 ANN -410 G-125 304 ANN -420 G-125. G-39 H.T

• 304-1020*

C-2, E-2. E-4, E-7, G-3 9 304-1112 C-2 304-H25 Alloy

• Valve:

208M2 304-TP17-4PH* G-4, G-17 304-Copper

• G-17 304-Chrome
• G-17 304-Graphitar*

G-17 304-Flexatallic 304* Valves: SP115M2, Sp213M2 304-Inconel* G-4, G-17 304-Ste111 te # 6* G-39, Valve : A208M2 2.es 304-Monel Valve: A208M2 ~ ' ' C-2 304L-405* 304L-410* C-2 2 304L-1020* C-2, C-8, E-2, {-3,~E-4 308L-1020* F-4, C-2 309-1020* F-4,-C-2 316-347* Valve: 108M2 . 316 4 P 4

• Valve:

Sp115M2 347-Copper

• G-17 347-2 1/4 Cr 1 Moly
• Valves:

198M1,110 347-Ste111te #6* G-17, Valves : 108M1,110 347-Haste 11oy C* Valves: 108M1, 110 405-410* C-2 405-410H* C-2, F-16 405-416 C-2 410-410H G-125 410-230 G-125 410-1020* Valves: MV10, MV6 SP A116, 223 410- Ca r p e n t e r Valve: MV10 Mirremold* 410-Ste111te #6* G-39 410-Fl exa tallic 304* Valve: MV6 SPA 116 410-Tung s ten, Cobol t, Chrome Valves: 223, 401 Alloy

~ ~' TABLE.181 (Continued) -21 Junction Material Equipment Piece a==== 416-A151 C1213* G-54 410-18Cr8Hi: StSt1* Valve: 401 - ~ ~ 416-Cast Iron #30* G-54 416-SAE 660* G-54 410-420* G-39 1020-1137/1141* E-7 1020-1112 G-125 1020-Nitrile (0-rings)* G-39 1020-Flexatallic* G-125, Valve: MY6-SPA 116 1020-70/30 Cu/Ni* E-7 1020-2 1/4 Cr l' Moly

• Pipe:

C-1, C-2, C-3, C-4, Valves: 108M1, 110, 10BM 2 1020-Cast Iron C130 G-125 1020-Asbestos

• Valve:

223 1020-Carpenter Mirromold* Valve: MV10 1020-Stellite

• Valves:

MV10, MV6 SPA 116, 110,108M2 1112-Cast Iron C130* G-125 21/4 Cr 1 Moly-Tungsten Valve: 401 Cobalt Cromium Alloy 2 1/4 Cr. 1 Moly-18Cr'8 Ni Valve: 401 StnSt1 2 1/4 Cr 1 Moly-Stellite f6* Valves: 108M1,108M2 H25 Alloy-Ste 111 te #6* Yhlves: 108M1 ..;.ML Graphitar 14-Ste111te #6* G-17 . 21.. f 40 Brass-B1113* G-54 ~~ B-62-Everdur* 1 G-125 B-30* G-125 B B-62* G-125 s Cast Iron #30-SAE660* G-54 Crevice Conditions Eouipment Piece Number Identification: 'C-2 Reactor Pressure Vessel C-3 Drum, Primary Steam C-8 Tank, Reactor Clean-up Demineralizer E-2 Secondary Steam Generator E-3 Heat Exchanger, Regenerative Clean-up Demineralizer E4 Heat Exchanger, Regenerative, Clean-up Demineralizer E-7 Heat Exchanger, Reactor Unicading E-111 Cooler, Reactor Enclosure Drain Tank F-4 Turcing Vane, Reactor Pressure Vessel l F-6 Vessel Thimble F-15 Diffuser Basket with Poison Sparger F-16 Guide, Grid F-17 Plate, Core Support F-21 Control Rod Drive Tube Assembly G-4 Pump, Clean-up Demineralizer Rectrc. G-17 Pump, Reactor Recirculating e _ G-39 Pump, Unioading Recirculating "r G-54 Pump, Reactor Enclosure Drain Tank G-125 Pump, Reactor Area Sump

.fih .9' l{f l, R,I

p !E j

.i. i!j

ii' g

TABLE IV

SUMMARY

OF CORROSION 0ATA AISI 1YPE GENERAL CREVICE GALVANIC STRESS AI.LOY_ CORROSION

• CORROSION CORROSION
• CORROSION COMMENTS 1070 017740 General Corrosion - Each number represents an 304 0.0096 none 304L (0.0001) to none average weight loss from at least 5 specimens 1020 (0.35) converted to penetration (mils)/300 hour test 304 Sen.

0.1061 none 304L (0.0027) to none time. All testing done under air saturated con-1020 (0.824)(1:10)** ditions, with test temperature set at 275'F. 304L (0.0011)(10:1) none 304L 0.0089 none i 1020 (1.406) 304l. Sen. 0.0890 none 304L (0.0009) to '~ none 1020 (2.0396)(1:30) Crevice Corrosion - Each alloy has been tested 347 0.0233 none 347 (0.0011) to none 1020.(0.3305) with artificial Teflon crevices and in a double U-bend configuration (stressed crevice). (No [ 405 (0.4759) )to crevice initiation occurs on stainless alloys, none 405 0.1233 none 1020 (0.0002 copper alloys, or nickel based alloys.) { 405 (0.0046))to .304 (0.0010 446 0.0086 none 446 (0.0013) to none Aluminum alloys have not been tested. Tests 1020 (0.2032) were run at 275*F from 100 to 300 hours. I Galvanic CotrosiotiN Each alloy couple has a (1:1) inconel 600 0.0116 .none none area ratio except dere noted. Couples were l 17.4 Pil 0.0377 none 17-4(0.0009)to i 304 (0.0013) made by rubber ba6 ding coupons together.(long-Ilaste11cy S 0.03356 none none term welded couples;are under. test at present. The galvan 16 tests were made in air saturated Cnpper 122 0.05136 none none l and 715 conditions at 250*F for 16 hours. a d-Aluminum 5 - 10 Al (0.2706) to l none l 304(0.0009) Stress Corsit k - Each alloy was tested in a / series of double U-bend tests. In addition, the 1 l ' Corrosion numbers represent total mfis penetration during; test 304 stainless alloys were sensitized before U-l {1 mi1=10-3 inches). Penetration assumed to be uniform over bend (heated to 1200*F for.50 hrs with a furnace the surface of the specimen. cool). The 405 and 446 stainless alloys were f

• Numbers in parenthesis refers to area -ratio of active.to noble.

tested after temper embrittling (at 885*F for 100 t hours with a furnace cool).. The stress tests i metal. ~ were under static conditions for.112 hrs at 275*F. j -All corrosion tests were without added impurities,

23 Special attention has been given to assure that the . ::.;= _ 02@?k solvent chemistry, as defined in section 3-G, used in mat-TE5r erial testing is the same as that to be used in the full scale process. The experimental portion of the test program found that there were no metallurgical or environmental conditions which are expected to be encountered during the chemical cleaning which would adversely affect the integrity of the materials of construction. The detailed materials testing program consists of the following six parts:

1. General Corrosion Testing Specimens representative of the materials in TABLE II (as determined and agreed on by a panel of metallurgical and corrosion testing consultants) were exposed to the sol-vent to evaluate the rate of general corrosion.

These speci-mens were exposed for 100 to 300 hours and evaluated to de-termine the loss of weight and occurrence of localized pitting or intergranular attack. TABLE IV summarize the results of this work in the second column. Examination of the specimens after erials testing .= showed no evidence of pitting or intergranu' attack. Re-sults of visual examination were confirmed t optical metal-lography-2. Crevice Corrosion Testing Crevice corrosion tests were conducted. The results are summarized in Column 3 of TABLE IV. No. acceleration of attack was observed over that of the general corrosion attack in the first column. No localized attack was observed on surfaces exposed inside the crevices.

3. Galvanic Corrosion Testing.

The fourth column of TABLE IV shows the results f rom Galvanic Corrosion tests. These results show that the corro-sion of the more active materials in each couple is accel-erated in each case. However, these increased rates are s'till small and are not considered significant. 4 Stress Corrosion Testing Stress corrosion testing was conducted on all materials using U-Bend specimens which were exposed for 112 hours, i Table IV, Column 5 shows that no cracking was observed for the alleys exposed to the cleaning environment.

+ 24 5. Electrochemical Studies ___;;;;; :r. 3E=.E55 Electrochemical studies of sensitized 304 stainless "iF steel conducted in the Corrosion Laboratory at Ohio State University have shown that the protective character of the film is stable and shows no tendency to pitting or other forms of breakdown. 6. Boundary Conditions A series of reasonab12 " worst-case" experiments were organized wherein several of the above conditions were tested simultaneously. The most significant of these experiments in-volved specimens which incorporate stresses, sensitization, crevices and cold work. These specimens did not crack under the environmental conditions specified for the cleaning operation When these " worst specimens" were exposed to conditions of increased oxidizing potential achieved by adding oxygen or ferric ion, stress corrosion cracking was observed.

However, subsequent tests with the same specimens in deionized water showed that the solvent was no more aggressive than the water.

A review of the results by General Electric concluded that the manner and rate of cracking in the solvent was identical to that observed in their previous tests in oxygenated deionized .=a. nater.

.yp C.

Irradiated Haterial-Testino The effects of chemical cleaning on highly-irradiated stainfesc <taal is

• cohject on whien littleid_s known and little has been published.

Since same of the critical reactor conconente have hann in hinh neutron tields for a long~ time, it is necessary that experimer.ts be designed a'nd 7caFried cut to determine any such effects. Tests conducted with actual irradiated metal are difficult and expensive due to the high radiation fields associated with them. For this reason, a test has been designed-which should yield a maximum amount of data. 1. Materials The material te be tested has been acquired from 30455 cans that had been used to contain surveillance coupons in the reactor core. Coupons of approximately 1/2" x 4" x 1/16" will be prepared from these cans. In addition, non-irradiated coupons of the same size will be prepared for comparision.

.... -... : ~:-. '. ~ .25 2. Test Method d((1.. The coupons, 6 irradiated and 6 nonirradiated, ~ia;;f will be mounted in tensile fixtures, strained 1% and stressed to yield. These fixtures will be mounted in a circulating loop along iith several other tests such as " wedge open loading" precracked-specimens and crevice corrosion coupons, both nonirradiated. 3. Test Conditions The environmental conditions for~the test will be as fo1~1ows: ~ y, _ a. Temperature 255 + 5'F b. Contact time 200 hrs. 1 c. Normal solvent concentration, oxygen saturated at ambient temperature i d. Deposit components and solvent impurities such-as iron, nickel, halogens, and copper at con-centration levels expected during the cleaning process. 4. Evaluation R. A visual examination of the specimens will be made to check forncracks or other.. surface: attack.. Weight,. ~i=- ~ ~ ~ loss will be evaluated and ' compared;.tolthe non_irra.diated-coupons. D. Residual-Solvent Effects Additional tests will be performed-to determine any i residual solvent ef f ects on the primary system materials. These tests will determine the effects on 304S5 during cleaning and subsequent service -at operating temperature and pressure. The planned' test will comprise: (1) Inter-granular Stress-Corrosion Crackin.(IGSCC) Tests Under + Simulated Cleaning Conditions, IGSCC Tests in Simulated BWR Environment, and Tests for Cheraistry and Corrosiveness of Decomposed. Solvent. The following is a description of these tests. 1. IGSCC Tests Under Simulated' Cleaning Conditions These tests will consist of 'e'xposure of slmple rectangular bent-beam saeples -- roughly 3" 'x 1/2" x 1/16" -- strained 1%-2% by bending over a radius block, with both ends anchored to maintain residual stresses. The exposure conditions would be the tire and temperature anticipated for the cleaning operation in 'resh solvent and in solvent w m 4 m ..m

26 containing Fe+3 and Ni+2 Data will be obtained by optical [Fyijg and metallographic examinations for IGSCC. 2. IGSCC Tests In Simulated BWR Environment These experiments will consist of exposure of un-stressed samples to solvent containing Fe,Fe+3 and Ni+2 for the time and temperature anticipated for the cleaning operation. The samples will then be rinsed with water.and exposed to oxygenated 550 F water as both bent-b'eam and constant-load uniaxial tensile specimens. Data will be obtained from a statistical analysis of the IGSCC behavior of the samples exposed to the solvent in comparison to <ontrol samples which had not seen prior exposure to the solvent. It is planned to perform both of the above tests using a heat of 304SS known to be susceptible to IGSCC. All samples will be made from the same heat of material. 3. Test for Chemistry and Corrosiveness of Decomoosed Solvent This test was accomplished by connecting two short pieces of 304SS tubing with a 304SS Swageloke fitting. The fitting was filled with solvent during assembly. The assemblies were then tested in solvent for 300 hours at 250*F under static conditions. Following this exposure, = the assemblies were placed in deionized water at.57.5'F for. ~ 100 hours. When. disassembled, the internal sur. faces of the fittings which had forced the crevices showed no crevice attack or stress corrosion.

27 j Y. FACILITY SAFETY EVALUATION AND DESIGN BASIS Q. A. Summary Although substantial amounts of radioactive material (3000 Ci as Co-60) will be removed f rom the Dresden-1 Prima ry System, the cleaning process is not considered to impose any unreviewed safety cuestions. However, returnius to power operation tollowinj t_ne chemical cleanino faiis outsloe or scope of previous safety evaluation for Dresden Unit 1. JAls Licensing Submittal contains an evaluation of the safety c'onsiderations involvec in the pricar) ~ coolant system returnato-service TollowinQ Ine cnem1 Cat C l e a n_1_n g. lased on this evaluation, it -was concluded that-une proposeo ~ post chemical cleaning inservice inspection requirements proposed in the License Amendment are adequate to ensure that there will be no reduction in the safety margin of the structural integrity i of the primary coolant boundary. This conclusion is based on consideration of the source terms, the design basis selected for ~ the f acility, and the planning and procedural aspects provided. In addition, since the cleaning system will actually be in use for a short period of time, the probability of adverse site conditions occurring during the cleaning is considered low. B. Source Terms During the cleaning, the radioactive source will consist ~ of activated corrosion and wear products removed from reactor plant surfaces by the solvent. Fission product concentrations will be negligible. The specific activity of the. solvent, after the cleaning, is estimated to be 10,Ci/cc (as Co-60) based on the analysis of samples taken from the primary system. The total activity which will be removed is estimated to be 3000 Ci. The solvent will be concentrated in the liquid waste processing portion of the cleaning facility, a.n d the concentrated portion will be solidified for off-site burial. C. System Design and Performance .r. The major components of the cleaning facility are tanks, l pumps, heat exchangers, connecting piping and valves. Storace tanks V201, V202 (See plot pl an A-101 included at the end of i this report) are used to collect the used solvent and initial rinses which comprise the bulk of the radioactive materials. The tanks will be constructed of reinforced concrete, with stainless steel liners, and will have a total capacity of 300,000 gallons. Each tank will be classified as Seismic Category I, and will meet the structural design basis used for Dresden 2-3, Class I structures. The tanks will also meet requirements for withstanding the design-basis tornado for Region I as defined I in Regulatory Guide 1.76. Tanks V201 and V202 are equipped with vents and overflows which are directed to the interior of the radwas Any leakage from these tanks will be containec, ge building. in tne bulicing. i

~ 28 Storage tanks V203 and V204 will contain low-activity rinse water and processed liquid wastes. These tanks will be iMMM. f reestanding coated (Carbolene 300) carbon-steel tanks and will be surrounded by reinforced concrete dikes of sufficient " = = size to contain any leakage from the tanks. The tanks will be '~ designed to meet API standards. The radioactivity content of tanks V203 and V204 will be limited to that allowed under the existing Dresden Unit 1 Technical Specifications. The system piping from the reactor containment building to storage tanks V201 and V202 will be compatible with the commercial standards of ANSI b.31.1.0. This piping will be contained in a buried concrete vault of sufficient design to contain any leakage and provide necessary radfation shielding. 1 The remaining cleaning system components will.be 'provided in accordance with commercial standards and specifications. There are no mechnical modifications required for the reactor-coolant pressure boundary. Af ter completion of the cleaning, the temporary piping tie-ins will be removed and the original ~ flanged connections will be replaced. The cleaning and liquid radwaste processing equipment will oc located in a Seismic Category I building. The building will be oes'9ned to withstand the design basis tornado for Region I as defined in Regulatory Guide 1.76. All equipment will meet the requirements of Quality Group D Components per Regulatory Guide 1.26, since their failure see= would not result in dose rates exceeding 0.17 Rem at the .})! site boundary. The expected 3000 curies of radioactivity, contained in approximately 200,000 gallons of liquid, will be concentrated into approximately twenty 1000 gallon batches. The con-centrated waste will be solidified in approximately 800 drums (55 gallons each) or other approved containers for off-site shipment in shielded cas ks, The remaining 180,000 gallons of decontaminated water will be further polished and recycled into the plant makeup system. ) D. Safety Evaluation i 1. Cleaning Facility Prior to performing the Dresden-1 cleaning, the reactor plant will be shutdown, the fuel assemblies removed, and the reactor coolant system drained. There will be, therefore, only a negligible inventory of fission products or other volatile radionuclides. The radioactive materials encountered will consist of nonvolatile activated corrosion and wear products. During the cleaning and subsequent waste processing, the radioactivity will be dissolved in the solvent. - Y .. l

. _ _ ~ _ ' _... 29 For these ' reasons it is expected that off-site doses from the releases of gaseous waste will be negligible. The lack of E5il fission product activity, especially radiciodine, eliminates the potential for exposure via inhalation or ingestion, since ~ there is no potential for airborne release or later dep-osition off-site. Specific dose calculations, as presented in Regulatory Guide 1.42, are thus not required for the cleaning operations. Storage tanks, V201 and V202 will contain the radio-activity removed from the reactor primary system until the waste is processed. These tanks will be designed and fabricated per Seismic Category I, and will be designed to withstand the design basis tornado for Region I.as defined in Regulatory Guide 1.76. The tanks will form one wall of a Seismic Category I building also designed to the requirements of Regulatory Guide 1.76. "In addition, the tanks and buildings will be designed to withstand site flooding. With these design considerations, even under safe shutdown earthquake (SSE) or tornado conditions, failure of the tanks or building is considered very unlikely. The solvent and radioactivity will remain contained and the release of radioactivity to the discharge canal or to the Illinois river will be prevented. 2. Cleaning Operations fiEL Prior to the cleaning, a preoperational test of all . c..., equipment, instrumentation and controls to be utilized during -~ the cleaning will be performed. All procedures and operations (as specified in Section III F.) will be performed to ensure that the process can be conducted safely % prior to the addition of cleaning chemicals. During the actual cleaning, process controls and instrumentation will provide necessary information to reduce the possibility of spreading contamination within the reactor containment. In the event of adverse site conditions, most of the Dresden primary system volume can be pumped out to the waste storage tanks in approximate 7y fif teen minutes. The ability to isolate and drain various sections of the reactor primary system and associated system will be provided to reduce the effects of any leakage which may occur. Since the cleaning will be performed at 35 psig and 250*F (a small fraction of normal operating conditions) and auxiliary heat removal equip-ment will be provided, potential radiological problems associated with high temperature (above 250*F) operations and/or leaks are eliminated. Process equipment and controls will be provided to ensure that the storage tanks will not be exposed to temperatures which could cause excessive expansion, or freezing, of the liner or damage concrete, i% -j

30 Operation of the radwaste processing system will be in accordance with existing Dresden Unit i Technical (ll.L.a Specifications. As low as practicable release levels will , =. ";.ar be maintained, and effluent monitoring practices followed. It is planned to reuse processed water, thereby reducing the total radioactivity released in liquid effluents. .t;5.: ~ ~ ' ~ * - ?. ,7.- e e o

VI. POST CHEMICAL CLEANING

==- A. Continuing Materials Surveillance The chemical control program for Dresden Unit I will comply with the technical specifications when the plant is put back into service af ter.,the chemical cleaning. The existing metal surveillance specimens 'are being evaluated f or usefulnes s in,[a continuing program a,f ter chemical. cl eaning. Ibdd[t'io'nDariobTmetal. specimens will be fabricated ~ ~ and ' installed in the reactor prior to the cleaning.- Some of these specimens will be removed for metallographic examination immediately.after the cleaning. Others will remain'in the reactor. ~ ' ' " ~ ' and be removed during' succeeding' refueling outages for' metallographic examination. The exact materials to be included in the program cannot be specified at this time, because they may be limited by the space available for exposure in subsequent service. At the minimum, they will consist of sensitized and as-welded 304S5, 41055, A302B, and sensitized and as-welded Inconel 600. Hopefully other materials of interest can also be included and these will be chosen when it is known that space is available. As many mit rials of current and potential future interest will be it 'aciuded as is practical. As part of the post-cleaning acceptance, a representative number of welds -will be examined p.rior to the cleaning to determine as accurately as possible the characteristics of the indication. Following the chemical cleaning and during at least two subsequent refueling outages, these. same welds will be reexamined to determine any change in the characteristics of the indication, which might be attributable to chemical cleaning process. B. In-Service Inspection Following chemical cleaning of the Dresden. Unit 1 Primary System an in-service inspection program will be performed, as complete as plant physical accessibility permits. It will be based upon the requirements of Section XI of the ASME Boiler and Pressure Vessel Codes. If necessary, this inspection will also meet the requirements in the Interim Acceptance Criteria for Emergency Core Cooling Systems for Light Water Power Reactors. = - 9

32 I n s p e di~o'n p.b i n t s sh i c h ~9 e r e d e l e t e d~ f r o m ~ t hT~i n-}_, ~ ~ service inspection prpgram due to high radiation levels since.. ti E E t h e 1971. '.i nfs e r f {c e..,j,n s p e c t i o h ~w i ll b'e i n c1 Fd e d ~ a s a~ p a rt c.- o f_..th'i s.,i_n s~p e c_ti. o.n.... 9 e 9 5 4 [ =: ~ s T i '..:Q: i

s 33 VII. SCHEDULE h ;.+_

• ~?

~ The attached chart presents our current schedule for the cleaning of Dresden-l. We expect to complete corrosion testing by March, 1975. Detailed engineering and construction of the chemical cleaning systems are scheduled to start March 1, 1975. The actual chemical cleaning operations including waste processing would start in January, 1977 and run for 2 or 3 months. This will be followed by an extensive recommissioning effort which will include in-service inspection and equipment overhaul. The plant would be returned to service in mid-1977. ~ s 0 W 4 6 6 6 4 6 4 t $ 6 6 6 4 6 4 0 $ 9 ~~7

~i ,1!ijp: j . ii + ii C

Il jil

!! ji .4, g +"

~

e + DRESDEN - 1 CHEMICAL CLEANING SCllE0llLE _L c

i =

1974 ~ 1975 ~t' 1976 l 1977 ^ e J S J M J S J M J S J M J S J Complete Corrosion I Testing Submit NRC Licensing I Approval Prepare Licensin9 to NRC greview Suomittal i I I I T i EDWR Pilot Ceco-ERDA7 Opera; ion Agmt. l i, --Plant Shutdown Engrg. Proc. } l Construction a 1 I' Chemieni Cleaning l l Operations I i I Waste Processing f I I Plant Returned i Plant Recommissioning I-to service a

e =y,o e 1 j I~ Conunonno it C'di:on g - or,. ., n....,% . n.,,..~ w.nn.,_ Adorcss heply to. Po:.t Ofhce Box 167 7, Chicago. libriois 60690 April 1, 1975 l c5 7) 1 h *h Mr. Edson G. Case. '[ ITI l Acting Director q Office of Nuclear Reactor Regulation O I U.S. Nuclear Regulatory Commission $5 N C< Washington, D.C. 20555 . }q n Dresden Station UElt i ~ E'p C -t. ~ Chemical Cleaning Licensing Submittal h w'd

Subject:

~ 50-10 ] _N_RC Docket No. i

Dear Mr. Case:

In a letter to you dated December 19, 1974 concerning this it was indicated that related proposed Technical Specifica-g, The intent was to

subject, tion changes would be submitted by March, 1975.

i develop Technical Specificationis adequate to allow power operation Tho general of the Unit 1 reactor following the chemical cleaning. Lin_ the Deccaber [ scope of those Technical-Specifications..was outline: 3

• -r'*

~~-

19, 1974 letter. ,. y ~ it is our conclusion dat these'"past After further review, chemical cleaning" T.nchnical Specifications can not be "deirclopetl Additional information nooded to develop fully prior to Janunry, 1976. detailed specifications will' be obtainod frod certain'owyoing testing inspections durincf the Pall; 1975 refuelin:7 programs and from plant cutage. 19, 1974 It is requested that your reviis 6f the December licensing submittal continun tosard issuance of an authorization of 1975. Since it is expected the chemical cicaning program by June, that some testing work and the detailed Technical Specifications will is suggested that the authorization not be conoleted by June, 1975, it l be conti : gent on completion of a specific list of "open items" prior This to return to power operation following the chemical cleaning. of open items would include the following: list l In c?dition to the eni sting metal surveillance specir'~ns; varir,un rmtal couponn will be fabricated and installed in-1. to tha cleaning. Some of these r.vei. mens the reactor crictlor nut.al%raphic examination L.unce u:tely - will le r cmona ..L f , ' i ) s' nm nn ? ?

,~ 3 1 Mr. Edson G. Caso Page 2 April 1, 1975 Others will remain in the reactor and after the cleaning. be removed during succeeding refueling outages for metallo-graphic examination. The new metal specimens will consist of sensitized and as-welded 304SS, 410SS, and sensitized and as-wolded Inconal 600. 2. can' also be included. Hopefully, other materials of interet included as practical. As many materials of interest will be As part of the post c1 caning acceptance, a represent 3. prior to the cleaning to determine as accurately as possibleFollowing the c indications. the characteristics of the cleaning and during two subsequent refueling outages, these same welds will be re-examined to determine any change in the characteristics of the indication which might be attributable to the chemical cleaning process, f as d. tailed on the attached test e The materials test progrem: Conclusions natrix, uill be enmpleted by September 1,1975. 4. and a sununas;y from these materials test program will be mede The successful completion of this available to the staff. test program will be documented by Dow Chemical or Generai performing the tout Electric Company depending on the part -Test results will oc audited a our independent consultants as well as by Commonwenith Edison work. Company personnel. Performance of a pilot plant test operation is scheduled. When this is. arranged, the staf f 5. Details are not yet firm.A report summarizing the operation will be kept informed. will be made available to the staf f on completion of the test. Proceeding in the manner recuccted will allow the cherict.1 procurement stnge or. n clenning progran to proceed to the equipment schedulo concirtent with performing the c1 caning in late NRC preliminary coproval, and resolution of the "open items" could early 1977. proceed in parallel without drinying the schedule of the chemical cleaning project.

~_ c, (. g 1 se' 1 i f f Mr. Edson G.' Case .f Page 3 ) April 1, 1975 signed original and 39 copics of thE5r' request One (1)

i for preliminary approval of the Dresden Station Unit 1 chemical-cleaning are submitted for your review.

7 i Very,t.ruly yours, ll ' / / ,# ;l'( as , j. : J. S. A,cl Nuclear Licene_*ng Administrator

l l

Boiling Water Reisctors l I, -t m m 't " W! g. W l i 1 r'#

a - m-i CoffWnOffwSt@ $0n { l- ' One First P4at onal Ch.cago. Iffenou m b A8" 004088

e. _t'lAJU Cb@ g s It UNITED STATES NUCLEAR REGULATORY COMMISSION g 1 W AsHINoToN, o. C. 20555 =. - -

===4 5EEM December 9, 1975 _~ .== Docket No. 50-10 m =EE'

== .E..=! Commonwealth Edison Co:::pany d'_ ATTN: Mr. R. L. Bolger 5 ..,. Assistant Vice President E Pdst Office Box 767 51-Chicago, D 11nois 60690 . i_:~i

== ~ 7_. ' Gentlemen: ~ = a

== 9 The NRC staff has: c.pletid its review of your requests dated December 16, 1974, April 1,1975, and April 14, 1975, for authorization to carry out a EE chemical decontamination of the interior surfaces of the Dresden 1 Primary EE - tNolant System. Based on our review of the decontamination program, we fs have, concluded that the program can be conducted with reasonable assurance M that' the health an'd f afety 'of the public will not be endangered. M m =. - - During ou'r review three items ' ere identified as unresolved. It is our E:E w under. standing that they will be resolved as follows: M__- 1he testing program will be completed and the results submitted for ->V

==

• . u 'c x

E5 1. the review and approval of the NRC staff prior to performing the ~*.- ] @ = =5 proposed chemical. cleaning. 5 =t=- .f r-- ~ 2. A pre-service insp'ection ' program for the primary coolant boundary 5 will be formulateH and sub=itted for.our. review and approval jfrior s. to returning the reactor to service. Es l EE. 3. h post-cleaning. surveillance program which includes additional 5 surveillance speci. mens and a specinen withdrawal and examination, U5 s'chedule' will be: submitted for..our review and appreyal prior to is'] c._ returning the reactor to service. On this basis the.Co$menwealth Edison. Company is,muthorized to initiate h !E grnpnc ed ehenical decontamination of Dresden Station. Unit 1. i'i i The staff's review is summarized in the attached Safety Evaluation. hl E= Sincerely, f. -T- = =. 1 .I En l Karl R. Goller, Assistant Director M for Operating Reactors grg Division of Reactor Licensing ge ??5

Enclosure:

[. Safety Ev:1ua:ien P.= AM mn 2 .... ~,. ..7

-s,. s - c

=

Comonwealth Edison Company Decemb ~ 9, 4 [5 =5 .. s.=;;: t== c: n.=. =; n--

==-:

==-

cc w/ enclosure: as: John W. Rowe, Esquire =g Isham, Lincoln 6 Beale Counselors at Law .__ :i One Firs National Plaza. =_..-n.. Chicago, Illinois 60670

==-

== C. =__:=- .=::.: .== n;n'

==. =i;'.:

==

..=.

C..

==

=

.*.u ;

==

= ::.

==

.-=

r

== ==:

==.

==

=:

== a':::::

== ==:

==

u;:.

~.L'.'

u.:::. =-

c...;

.:=.=. F gy am.....i -Di.m + W . a.:. ~ MT. =" .=..'.'.J.- / ~ "l:. C'*'",*^"

= *:

• • 1!.

" " ~ ~ ~~:: = C.. ~~~:: =: =~ =- . ~ -. wN e C.'.

=::

0::. C. =. C;;: C::: =*:L n ~, =74 at:: C.'. C.:. [ =2' i 2

C:.

=:: I I... 1 .m;. Y. i ..ai h. 5$$l

1.. :

( i e .r

.. ~. ~* N' UNITEo STAVES NUCLEAR REGULATORY COMMISSION h W AsHIN GTON. D. C. 205ss e-= 55 _ _Z_....

,5-;

=& 2 -,= SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION E 7."**.' SUPPORTING AUTHORIZATION TO CHEMICALLY DECONTAMINATE THE PRIMARY b COOLING SYSTEM AT DRESDEN UNIT 1 G. M CO)410hvEALTH EDISON COMPANY 55 5b DRESDEN NUCLEAR P0hTR STATION UNIT 1 5 E... DOCKET NO. 50-10 g= 5

== =E-IhTRODUCTION g;

.-=

=

By letters dated December 16, 1974, April 1, 1975 and April 14, 1975, R the Commonwealth Edison Company (CECO) requested authori:ation to carry 5 out a chemical decontamination of the interior surfaces of the Dresden 5 Unit 1 primary coolant system. g 5 The purpose of the decontanination is to remove a deposition of activated M corrosion products which is tightly bonded to the primary coolant syster. ~ piping and components. The presence of the corrosion products in the E.: syste results in high levels of radiation in adjacent areas and limits 55 "Z[ . access to these areas for the purpose. of._in-service inspection, routine _ js.L raintenance and plant' modifications. ~ ~~ ~ EE E CECO has tentatively scheduled the chemical cleaning proj ect to begin in Jaruary 1977 with an anticipated return to service scheduled for =:7. July 1977. g: EVALUATION ES = The. staff's review of CECO's proposed chemical decontauination of the b interior surfaces of the Dresden Unit 1 primary coolant system has been E~ co=pl e t e d. The results of this review are as follows: = 1. Environmental Impact fl5 The chenical decontamination of the Dresden 1 primary coolant syste= EO will be performed entirely within a closed decontamination system. E-The syste has been designed so that no chemical or radiological E wastes will be released to the environment from the decontamination

=g process.

All wastes generated in the process will be either solidified ~; for offsite burial at a licensed burial ground or reprocessed for reuse .g onsite. The solid __ wastes produced _ are similar in tvne and cuantity to E those hand!eB cutiaelv at tne s:te. Tnerefore, no adverse environmental

r '

imp;:ts are anticipated cue tc the decontamination. p

• e u.. _ _,

O

__._ - ~. _ _. _. E g_ : b.. ~ ~ 5E c_=..=... 2. Materials Compatibility M The staff has reviewed the results of the material testing program f;.Mf that has been carried out in support of the proposed Dresden 1 Q decontamination program. %e test program was organized to look E' at corrosive effects during the decontamination process and possible g residual effects during subsequent reactor operation. 'EE =: :: EE Lased upon our review of the results of the testing program completed-to date, we have concluded that the test program adequately evaluated EEE EU those aspects of the materials compatibility that we consider to be important. As a result cf our discussions with CECO's consultant, as Dr. Craig Cheng of Argonne National Laboratory, we find that the fg} remaining program will be conducted in a manner that will answer our g== presently unresolved concerns and the test results will be adequately is; !EE interpreted and reported. kt? We conclude that gen the successful completion of the testing program M described in the suonittals and with an acequate surve111ance and i'EI inspection program, the Dresden Nuclear Power Station Unit I can he jEE subjected to the d*=cribed r*H c a l cleamne vrocess without undue E~5 Errosion or other deleterious materials compatibility effects that

If j_y js would adversely effect the integrity of the primary coolant system and connected systems.

2... i=-T ~ A small number of ~ items of concern have not been-resolved-to-the -- -M staff's full satisfactionnat this time. :However; we' conclude that~ E= authorization to carry out the chemical decontamination should,be i=.=

== granted in anticipation of the successful resolution of these open items in the near future. The following open items are identified i" at this time as requirin2 resolution to the staff's satisfaction: en 7 eted and the test E 1 (a) The materials test procram will ha results will be analv ed and reviewed prior to the beginning gG o tne cleaning proces_s. Z.

== (b) Surveillance specimens in addition to those now planned will be 5 determined by mutual agreement with the applicant and a schedule

g_

for specimen withdrawal will be stated, a E5 (c) A pre-service inspection program for the primary coolant boundary and safety related systems will be formulated and performed prior g to return to power. .g g 55

== 0. h_ 5: ~

g;

r..

E 5.= T;.- u=.=+.0 v.=.. :... f 3. Effluent Treatment Systems E We have determined that the effluent treatment system, if conrtructed = as described in the CECO submittals, is capable of handling the types { and quantities of effluents expected to be generated by the decon- ~g tamination program. Our review was limited to the use of the system i for chemical decontamination only, and use of the system for any other M purpose subsequent to that program must be reviewed prior to such use. 5 E 4. Radiological Safety E We have further concluded that the radiological safety program 5 E described in the submittals is adequate to assure that the health and safety of the public and the onsite personnel wil.1 not be endangered ir by the Dresden I decontanination proj ect. { CONCLUSION F Ke have concluded, based on the considerations discussed above, that: ? (1) because the chemical cleaning does not involve a significant increase E in the probability or consec,uences of accidents previously censidered and { does not involve a significant decrease in a safety margin, t.e cleaning project does not involve a significant. hatards consideratic (2) there 2 =. 5"? ~ ' is reasonalle assurance that the health and safety of the p ^ic will not i? be endangered by operation in the proposed manner, and (3). _ch activities J.i will be conducted in compliance with the Commission's regulations and the issuance of this amendnent will not be inimical to the common defense and security or to the health and safety of the public. Date: December 9, 1975 T:- 1 i ip E

c-.-.. DISTRIBtfT10N { Docket HRDenton [ NRC PDR (w/ine) Berkow/ Russell Local POR (w/inc) RDeYoung z. 6';'[J35 ED0 Reading Dross h=2=et to. 50-10 N29 1980 NRR Reading RMattson ORB f 5 Reading OELD DGEisenhut OCA(3) Glainas G.Ertter (EDO-8467: RVollmer MGroff WDircks .DLZiemann... ME!CRANDUM FOR: Chairman'.Ahearne KCronell - PO' Conn th ~ ~ William J. Dircks D;kseOT. A.Ra%nr THRU: h ,L winer. Acting Executive Director for Operations SECY (3) c. CHeltemes, AEOD Harold R'.' Denton, Director EGCase ,FROM: _g Office of Nuclear Reactor Regulation {

SUBJECT:

DRESDEN DECOMTAMINATION Enclosed is our response to your en:x:randum dated February 27, 1980 which asked three specific questions: 1. tibet is being done at Dresden? 2. What type of approval did NRC give (license a:endaent?)? .3. Did we do a negative declaration or environ = ental assessment?

.h. As indicated in the enclosure, we have cor

pleted our review of the safety l_.s and environnental aspects of the prcposed chemical _ decontamination at Dresden -

'" "~ and expect to issue a draft environ:tantal statenent for cont:ent~bf;the end' of the month. s Cd:ti r'~ ~ ' 7 ,.o [;. T. * : TT ~ Harold R. Denton, Director 5T Office of Nuclear Reactor Regulation

Enclosure:

As stated cc w/ enclosure: Coe=issioner Gilinsky Cwd::issioner Kennectr Co::::issioner Hendrie Ccc:,issioner Bradford SECY J OPE OGC NRR HDenton 5/ /B0 +5ee previous yellow for concurrences A W t 2 cs ] m ....Y OA -,.Y . DL : pk.B, # 5, I pl: QRB#5* DQ8;,,AD/SEP! ,0 EL D,* D0,R* NRR* 9,- orr,ec ,DLZiemann RHvo11mer DGEisenhu. .EGCase.... P0'Connor:ct s... svw-c,. ...,,p.5/2/SO 4/7/80 4/7/80 4 /.16./. 80,, 5/12/8D . 5. /.1.9. /. 8.,0,, 1 .q. c

7 ,. = ~ - - - - - - DRESDEN DECONTAMINATION . =. 5:$:$:, 5.5..:5 (1) What is being done at Dresden? Since our 1975 authorization to initiate preparations for the Dresden Unit I decontamination, Commonwealth Edison Company,(CECO) has completed construc-tion of the support facilities necessary to carry-out the decontamination in a safe and environmentally acceptable manner. 4 Ceco has also submitted all of the information required hv the staff ta entisfy Yhe three conditient that were part of our earlier approvait We have prepared a safety evaluation and environmental evaluation for the decontamination project-and are prepared to issue an approval to proceed with the decontamination. We have received numerous requests from the'public to prepare ~an Environmental Impact Staterent (EIS) and to hold a public hearing on the decontamination project. Two of these requests have been~ accepted as petitions under section 2.206 of our regulations for action by the Commission. One of these by Ms. Kay Drey requests that we prepare an EIS and one by the Illinois Safe Energy Alliance (ISEA) asks for a public hearing. We have carefully reviewed the allegations made by these petitioners and have reassessed the environmental impact of the project and have concluded, as we concluded in 1975, that the decontamination will not adversely irpact the environment. Based upon the recent Commission decision requiring that an EIS be prepared for the Surry steam generator replacement action, we have decided to convert our environ-mental appraisal into draf t enviromental stategent.

agms, 2 52 5555 A significant amount of the public's ' interest in~thede~contaminatio'n' has been -

^ focused on the waste shipment and disposal aspects of this activity. We have contracted with Brookhaven National Laboratory through NMSS to evaluate the effect of decontamination chemicals on the integrity of the shipping containers that will be used to transport and bury the Dresden decontamination wastes. The preliminary results of the Brookhaven study support our previous determina-tion that these wastes can be safely shipped off site for burial. NRC has notified the public (43 FR 49811) that an Environmental Impact Statecent supporting our Proposed Rule 10 CFR 61 which will implement a specific This regulatory program for the ranagerent of low-level radioactive waste. statement offers the public an opportunity to. comment on the generic aspects of the disposal of decontamination wastes. 1 e il e n

_m .. ~. ..~.....,... g55l; In light of the proposed changes to Part 51 which will require that we consider 96=J-occupational exposures when determining whether to prepare Environmental lapact Appraisals, we have also evaluated the occupational exposure that will be associated with the decontamination. Connonwealth Edison Conpany (Ceco) submitted a detailed Han-Rem estimate for the project in compliance with the ALARA requirements of 10 CFR 20. In this estfrate Ceco concluded that approx-imately 500 Man-Rem would be received by its employees and contractors. We re-viewed CECO's estimates and concluded that they 'were well based and conserva-tively bounded the expected occupational exposures that would be received. CECO has recently reported that the occupational exposures experienced have been even lower than the earlier estimates because of careful planning. Ceco now projects a total Man-Rem exposure of about 300 Man-Rem for the entire project. From 1973 through 1977 the occupational exposure at Dresden station has averaged 627 Man-Rem per year per reactor. The annual exposures ranged from 313 to 1141 Man-Rem per year per plant. These annual exposures show that the occupational exposures exhibit a range around the average of minus 314 Man-Rem per plant per year to plus 514 Man-Rem per year per plant. It is readily seen that the anticipat~ed occupational exposure of 250 to 500 Man-Rem from the Dresden decon-tamination f alls well within the range of variations that has been historically found at Dresden Station and other operating reactors. Therefore, the occupa-tional exposure anticipated due to the decontamination project does not differ significantly from the normal range of exposures at the station from year to year. Af5IL All aspects of our reassessaent, including preliminary reports from Brookhaven.

ssar support our previous finding that this decontamination does not, adve, sely inpact r

~~ the environment. Because this issue has been the subject of significant public dnquiry, we are also considering holding a public neeting in the Dresden vicinity to explain our action and inform the public of the results of our evaluation. We ret with staff members of the Council on Environmental Quality on February 14, 1980. We provided them with the background and status of this action and dis-cussed our proposed approach to this issue. i i ea 9 +

4 @E? The completion of our review of this action involves not only the decon-temination but also the review of the inspections prior to return to operation. = We will be determining whether or not to igese license limitations or con-ditions on the actual conduct of the decontamination work or in connection with the resumption of operation thereafter. (2) What type of approval did NRC give (license amendment?)? l Commonwealth Edison had originally planried to carry out the decontamination under the provisions of 10 CFR 50.59 which allow the licensee to make changes in the facility if the changes do not involve a change in the Technical Specifications or an unreviewed safety question. TP e+=H. identified neither technical soecif cation changes needed nor unreviewed safety questions. However, because of ACRS ano s ceii concerns reiateo to Ine potenu al ter causing pipe cracks and some pre-vious decontamination project misfortunes, we-informed CECO that we wished to be kept closely informed about the progress of the decontamination program. Because of the 36 million dollar cost associated with the decontamination project CECO agreed to provide NRC with a licensing request for our approval. CECO felt that the request would be a prudent action to assure that the staff have an early opportunity to express any licensing concerns that might inact the viability of the project. On December 9,1975 we issued a letter which conditionally authorized the initi- =- hs!![ ation of the decontamination program at Dresden. The authorization indicated that our review to that point had concluded that the decontamination could be W conducted with reasonable assurance that the health and safety of the public would not be endangered. (3) Did we do a negative declaration or environmental assessment? Our 1975 authorization tn i n4+4 9e t% 6 Heal decontamination 6d not i nvol ve __t iicense amend' int _or other federal action subject to NEPA review. We did assess the environmental i@act of the proposed decontamination and concluded that there would be no adverse environmental igact. Accordingly, we did not prepare a Nega tive Declaration and Environmental Inact Appraisal. Our n.r.wr 9.1975 letter enclosed. only authorized preparation for the crocosed chemical cecon-copy ramination2 0ur environmente ca s es sme nT. of the program was summarizec: in Sectier 1 of the related Safety Evaluation. As stated earlier we are preparing a draft Environmntal Statement for this action and expect to issue'it by the end of May. W e ,,.,__m y g-

Comm:nwrith Edis::n EC. One First National Plata Cheago, minois Accress Reply to: Post Ofhce Box 767 Cnicago. Ilknots 60690 November 1l+,'1979, Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Subj ect : Dresden Station Unit 1 Proposed Amendment to Appendix A, Technical Specification, to Facility Operating License DPR-2. Required to Perform Primary System Chemical Cleaning NRC Docket No. 50-10

Dear Sir:

Pursuant to 10 CFR 50.59, Coernonwealth Edison proposes to amend Appendix A, Technical Specifications, to Facility Operating 1.icense DPR-2 to support the chemical cleaning of the Dresden Unit I primary system. The changes to the Technical Specifications concern (1) deletion of the requirement to maintain primary containment Integrity during the chemical cleaning outage when all fuel is removed from the reactor and containment, anc; (2) exclusion of radioactive liquid storage tanks which are. inside seismically qualifJed structures from the above grade storage curie limitation. ~ / The change to the primary containment Integr ity requirement is necessary to allow the chemical cleaning to be performed at the required temperature of 250er. Special procedures will be implemented to provide for the rapid re eval of the cleaning solution to receiving tanks should a significant leak from the primary system occur. 'This will ensure that any leakage will be small in volume and contained within the sphere. Since the contamination species being removed are. non-volatile and no fuel will be inside the containment, release

• of volatile activities due to a leak would be minimal.

Normal ventilation flow is adequate to ensure that any airborne activity will be conveyed to the stack and monitored. The clarification of the radicactive waste above' grade storage reouirement !s necessary to allos transf er and storage of the scent cleaning solution prior to processirig in the Chemical Cleaning Suilcing storage tankt., which are physically above grade. The current curie limit is based upon postulated rupture of above grade tanks, due to a seismic event, allowing their contents to be released in an uncontrolled manner. Since the tanks in the Chemical Cleaning Builcing are lccated in a seismically qualified structure si:ed to conta in the centents cf all the tanks inside that structure, the curie linit coes not a;:oly. g/ .s /// ,gu && wMech Iuoc.c. %.. ) L n

Commonwealth Ettison NRC Docket No. 50-10 Director of Nuclear Reactor Regulation November 14, 1979 Page 2 Pursuant to 10 CFR 170, Comonwealth Edison has determined the proposed amendment to be Class Ill. As such, we have enclosed a f ee remittance in the amount of $4,000.00. Please address any questions you may have concerning this matter to this office. Three (3) signed originals and thirty-seven (37) copies of this transmittal are provided for your use. Very truly yours, D. L. Peoples Director of Nuclear Licensing RFJ:mae enclosures $UBSCRIBED and SWORP to beforg rne thly d, ay si '/ fe r & s* / & J, 1979, ff. 7 ef,U Ato t. Public S e d 1

.. o ENCLOSURE i Dresden Unit i Revised Technical Soecification Pages Revised Pages 87 91 98 102 New Page Sla / 7911270- .S

g ..] ~ 4.7 StlilVEilLANCE REQUIREllENT

4. / t litt ITrif.~tMilill1011 FOR Opf NATION d.

The test duration shall not be less l tiO!! : turing the out age beginning Novanber,1970, than 24 hours for integrated leak rate to elecontaminate the primary systm. the measurencnts, but shall be extended to requironent of 3.7. A.1 is not applicable a suf ficient period of time to verify, when all fuel is removed frm the reactor by measuring the quantity of air required and the cont aiment. to return to the starting point (or other I methods of equivalent sensitivity), the validity and accuracy of the leak rate i resul ts. i c. Acceptance Criteria for IPCLT (1) The maximtsn allowable Icak rate L shall not exceed 0.4 weight per-cEn,t of the contained air per 24 hours a t a pressure of 20 psig. t (2) The allowable operational Icak rate. L (20). which shall be met prior to. rb9tsnption of power operation following a test (either as measured or following i repairs and retest) shall not exceed 0.75 L.* p CorrectiveAciton~IorIPCLT f. e If leak repairs are nec'essary to meet thb = ' allowable operational leak rate, the inte-grated leak rate test need not be -repeated i provided local leakage measurements are conducted and the. leak rate dif ferences prior to and af ter repairs, when correcs ted to the test pressure and i i l L -.-,--m .-s-.. a s

....~. g. n. ; e L !!!1*S o e e

3. /

i i Primary Containnent - The Integrf ty of 'the D. Primary Containment isolating Valves i A. primary containment and operation of the Isolation valves are provided on lines pene-- emergency core spray system in combination, trating the primary containment and open to limit the ofI-site doses to values less than free space of the containment. Closure of those in 10 Cf R 100 in the event of a break one of the valves in each line would be in the primary syst m piping. Thus, containment sufficient to maintain containmant integrity. I Integrity is smci fied whencver the potential Antmatic initiation is required to minimize,' for violation of the primary reactor systen the potential Icakage paths fran the contain- + integrity exists. Concern about such a ment in the event of a loss of coolant accident. viniation exists whenever the reactor is crit ical and above a tmospheric pressiire. In adilltlon, even durIng perlods-when the reactor is t.lmtdown, prinary contalment integrity is r requirnt to ent.ure fission products would he contained in the event of a refueling accident or large spill of radidactive water fron'the primary sys tm. If no work is being done in i the prbhary containment which has the potential l for release of radioactivity, containnent integrity is not required. o Ulth all fuel rmoved from tk reactor, any l- ^ volatile activities which could be released during the chemical cleaning butage beginning in ilovmber,1970, would he stinimal. ibmal sphere. ventilation flow would ensure that alf-borne activity would be conveyed to the stack, l and the stack gas monitor will be in service. Chnnical cicaning procedures will be established for dioping the c1 caning solution to receiving tanks in case of significant leakage 'fron the l: primary systeri and to ensure that any leakage e of Ilquids to the sphere will be contained within the sphere. 1herefore, based on the above, primary containment integrity is not required for the finvembes, 1978 chemical. cleaning outage when no fubt is in tt containment, a. ,-,,,,,---r-a -s~< ++-,w .- - - - ~, - -n n.n-, a -,-,-ms .w -, -.+ -in - r- ..~.i-,-,.- .---,e m +- -..v.,~..:,

. N.; ~. Ihc primary containment has a design.tmperature and pressure of 325'T and 29.5 psig. respectively. In addition, tlic contoiment was designed for a maximism leakage of 0.5% (by weight) per i itay a t 3/ psi. Ior the latyest break, the l-pa= Imiri conta tivnent pressure is approxima tely 20 psig which is less than design pressure I 8 e anil r.nntainnent Icakage should be less than O.47/ day, which is specified at 20 psig. 1hc allowahic leakage rate at 20 psig is calculated frm the contalment design Icakage rate of 0.51 (by weight) per day at 37 psig by using the following equation: 17 + l.a.( t/pa)l/2 I l 0 t i + 'l = m m m. c ..,n-e y

.s- .t it I hiliIllii i t'.101110fl i OR OPERATION 4.8 StillVCIII Ai!CE RL'0U(HEMENf l 1 hm ir.it.ipenrieni sampics fi*om a tank L The p.:ritm :ince and restri ts of in.lependant si..11 le t. den.init analyzed and 'ha

• amples und valc checks r.htill by Ingged.

valve IIne-up checked prinr in alls-c.harge of Ilquiel ef fluents frcm that tank. 4. If the Ilmits of 3.8.C cannot be met. raillnactive liquid ef fluents shall not lac released. 0. Raillnactive llaste Storagd D. Radioactive Waste Storage lhe maxinien amount of radioactivity in A sample from each of the above-grade liquid liepeld stoiage in all Dresden Stations waste tanks shall be taken analyzed and-alinvc graefe tanksnshall not exceed 90 recorded every 72 hours. If no additions to a cieries. If these conditions cannot' he met tank have been made since the last sample, the the stored liquid shall-be recycled within. tank need not be' sampled untti the next addition. 24 hours -to below grade tanks. All tanks located within tlic scismic portion of the Cheritcal Cleaning Dullding are not considered a bove' g rade storage. E. General ' E. General it is expected that releases of radioactive. Operating procedures shall be developed and 1. natcrial in-ef fluents will be kept at small " used, and equipment yhtch has been installed fractions of the limits specified in Section to maintain control over radioactive nuterials 20.106 of 10 CFR Part 20. At the same time in gaseous and liquid effluents produced the licensee isl permitted the ficxthliity during normal reactor operations including of operation, compa tible with considerations expected operational occurrences, shall be of health and safety, to assure that the maintained and used, to keep -IcVels of. public is' provided a dependahic source of radioactive naterial in ef fluents released t-to unres tricted areas as ' low as.ls reasonably i-power even under unusual operating conditions which may tonporarily result in releases achievable. Tlui environnental monitoring i higher than such small fractions, but stl11 program given in Table 4.8.1 shall be conducted. -i

T e ^ .-..s 3 j-4 y m usurc gg l UNITED STATES OF AMERICA UL 11980> E NUCLEAR REGULATORY COMMISSION k* Of!Ledh W 'It h i / COMMONWEALTH EDFOON ) ) ) Docket No. ) 50-10 Dresden Nuclear Power Station ) Unit 1 ) i PETITION FOR PUBLIC HEARINGS NOW COME Petitioners, CITIZENS FOR A BETTER ENVIRONMENT, PRAIRIE ALLI ANCE, KAY DREY, BRIDGET ROREM, ILLINOIS SAFE ENERGY l ALLIANCE AND MARILYN SHINEFLUG, by their attorney Robert ~ Goldcmith, and hereby petition the United States Nuclear a Regulatory Commis_sion as follows: . n m.- ,n 1. Pursuant to 42 U.S.C. 52239 and 10 C.F.R.,@.206, Petitioners recuest the Nuclear Regulatory Commission (NRC) to hold hearings on the Envtronnental Impact Statement (EIS) related to the decontamination at Dresden Nuclear l'ower Station l Unit 1 (Dresden 1) and on the application for amendment to Commonwealth Edison Company's (CECO) operating license for f Dresden 1, necessary for the ra;d decontamination. 2. Petitioner Citizens for a Better Environment (CBE).is an Illinois not-for-profit corporation with approximately, 3,000 members residing in Illinois and a nationwide me'mbership of approximately 12,000 persons. CBE files this petition on s i \\ ~ CA L / o n '~) 1

~h 4 i p behalf of its members who reside near the Dresden Nuclear Power Station, Unit 1 and whose health, safety and property may be adversely affected by any environmental impact of the chemical 4 decontamination, as well as for its members who reside near nuclear stations w3ich may be decontaminated in the future. 3. Petitioner Prairie Alliance (PA) is an Illinois not-for-profit corporation with approximately 350 members residing in Illinois. PA files this petition on behalf of its members who reside near the Dresden Nuclear Power Station, Unit 1 and whose health, safety and property may be adversely affected by any environmental impact of the chemical decontamination. 4. Petitioner Kay Drey is a citizen of the State of Missouri. Her health, safety and property and that of her family and descendants will be adversely affected by any negative environmental impact resulSin'g [ rom th'e decontamin'at5on '~ "~ ~ at other nuclear stations. T'- 5. Bridget Rorem is a citizen of the State of Illinois and resides in Essex, Illinois, which is within 15 miles of Dresden 1. Her health, safety and property and that of her family and descendants will be adversely affected by any negative environemtnal impact resulting from the decontami-nation of Dresden 1. 6. Illinois Safe Energy Alliance is a coalition of 19 affiliate organizations located in the State of Illinois totaling over 300 members. It files this petition on behalf

of its members who may be adversely affected by any negative environmental impact resulting from the decontamination of Dresden 1. 7. Marilyn Shineflug is a citizen of the State of Illinois. Her health, safety and property and that of her family and descendants will be adversely af fected by any negative environ-mental impact resulting from the decontamination of Dresden 1. 8. Petitioners have a substantial interest in the proposed chemical decontamination at Dresden Unit 1 in that: (a) The Dresden station is located in the State of Illinois and is within 50 miles of several of the state's most populated areas including the Chicago Metropolitan area, Aurora and Joliet, in which a large portion of Petitioners reside. (b) Any mishap or accident occuring-during: the . n r:' =- proposed decontamination releasing radionuclides \\ into the environment will adversely affect Petitioners in the vicinity. (c) The Dresden station is located near the confluence of three major water resources, the Illinois, Kankakee and Desplaines Rivers; any release of radiation con-taminating these waterways will adversely affect Petitioners. (d) The Petitieners desire.to preserve the future environment of the area surrounding the Dresden station for themselves, their families and descendants. (e) The chemical decontamination at Dresden 1 J is a prototype for the development of large scale chemical decontaminations at nuclear stations across the nation. 9. Dated May 1980, the NRC issued a draft EIS related to " Primary Cooling System Chemical Decontamination at Dresden Nuclear Power Station Unit No. 1." 10. Pursuant to 10 C.F.R. 51.52, the NRC has authority 5 to hold public hearings on an EIS. 11. Pursuant to the Council on Environmental Quality Regulations, 40 C.F.R. 15 06. 6 (c) (1), where there is a substantial interest in holding a hearing, the lead' agency shall hold a public hearing. 12. In this case, there are both a substantial interest-. .,ari-- in holding a hearing and a substantial environmental controversy, s to wit, the decontamination of Dresden 1. 13. Pursuant to 10 C.F.R. 50.59 and 50.90, Ceco has requested a license amendment in order to decontaminate Dresden 1. 14. Under 42 U.S.C. 52239(a), the NRC shall nrant a hearing upon request of any person whose interest may be affected by the proceeding. 15. Petitioners' interests will be affected by this proceeding and hence a full hearing, under 42 U.S.C. S2239(a), with Petitioners accorded full party status and given the right to cross examine witnesses and present testimony of their own, should be granted.

+ 16. A proper determin4 tion of "no significant hazard" has not been made in regat?. to the proposed chemical decon-tamination and a proceeding to make such a determination and a hearing are required. 17. Because this decontamination is a prototype for future decontaminations nationwide and because this may be the only opportunity for the public to directly question this program,a public hearing,with full party status to the petitioners, (as oppor,ed to a public meeting without party status) should be granted. WHE REFORE, Petitioners pray that the Nuclear Regulatory Commission institute a proceeding and conduct hearings concerning the proposed chemical decontamination of CECO's Dresden 1. Respectfully submitted, ei /s /g s fn

1. Tb DY: i'.

N Date: w ROBERT GOLDSMITH b'! Attorney for Petitioners Robert Goldsmith 59 E. Van Buren Street Suite 1600 Chicago, Illinois 60605 (312) 939-1530 ~ ' - is' F 1 .6. ** k ISHAM, LINCOLN & BEALE 4 COUNSELORS AT LAW out rimst NatiowaL PLata romtv-s Ecomo FLoom cuecaco,sLuwoes sosoa. ttLtemows sia ase 7soo TcLtat a stoe 4 stao co =tc c tw t.m w. November 14, 1980 ,,,,gtge,s,,,,, non ess ena Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 t Re: Dresden Station Unit 1 Chemical Cleaning of 1 Primary Coolant System i NRC Docket No. 50-10

Dear Mr. Chilk:

These comments are submitted on behalf of Common-wealth Edison Company, which has been informed that a. petition for public hearings has been filed by. Citizens for a Better Environment and various other citizens groups in opposition to the proposed chemical cleaning by Commonwealth Edison of its Dresden Unit 1, reactor located in Morris, Illinois. Apparently the decision whetherJto hold'suchihearings prior to authorizing :the cheniical cleaning has"been referred totthe. u.cc 2 Commission itsel(, rather than to the' Director of smuclear Reactor Regulation pursuant to 10 C.F.R. 52.206.. In light l' of the fact that the NRC Staff has already found, three times, that the proposed action will have no significant and further found at least impact on the human environment, once and perhaps twice that there are no significant hazards considerations, the Con: mission ought to allow the chemical cleaning to go forward without further delay. f Commonwealth Edison and the chemical cleaning project have already suffered due to the postponement caused by the NRC's last-minute decision earlier this year to i prepare an environmental impact statement, notwithstandin See will not cause any adverse environmental impacts." Commonwealth Edison Company (Dresden Nuclear Power Station Director's Decision DD-80-24, 11 NRC 951. Unit No. 1), The Director's decision to prepare an environmental (1980). impact statement was because of the "significant interest and concern" expressed by many of the same members of the The delay associated public who now request public hearings. N FA a~ L. 1 [l

o 3 .- r ..s Secretary of the Commission November 14, 1980 Page Two with preparing the environmental Ompact statement has cost Commonwealth Edison and its customers more than $420,000 as of October 20, 1980, and those costs are continuing to Commonwealth Edison is extremely concerned that accrue. further economic waste and possible prejudice to the project itself will result if the NRC now determines, again at the eleventh hour, that adjudicatory hearings must be held prior to carrying out the chemical cleaning. In Commonwealth Edison's view the goal of public participation in regulatory decision-making has been satisfied by the public meeting held by the NRC in respect of the Draf t Environmental Statement in Morris, Illinois on August 14, 1980. A brief history of the chemical cleaning project seems in order. Dresden Nuclear Station, Unit 1 is the privately built nuclear reactor in the United States. first but since 1978 has been It began operating in August 1960, Over shut down for installation of various safety backfits. the years Dresden Unit 1 was operating, a thin layer (less of corrosion deposits (crud) developed on the than 2 mils) interior surfaces of the primary system, increasing radiation fields which made certain maintenance and inspection activities much harder to perform. The purpose of the chemical cleaning project is to reduce occupational exposure to its employees in keeping with. the AIARA requirements of 10'CFR Part:20>'- -~ and to allow certain inservice" inspection activities-to-be 22:0:2T' carried out as economically as possible. ~ ~ In December 1974 Commonwealth Edison Company On submitted its proposal to.the NRC for its review. December 9, 1975 the NRC authorized Commonwealth Edison to subject to resolution of proceed with the chemical cleaning,that time the NRC found the project three open items. At would have no significant impact on the human environment. In addition the NRC Staff's December 9, 1975 safety evalu-J' ation specifically concluded: "[B)ecause the chemical cleaning does involve a significant increase in the not probability or consequences of accidents previously considered and does not involve a significant decrease in a safety margin, the cleaning project does not involve a significant hazards consideration."

..e Secretary of the Commission November 14, 1980 Page Three In subsequent years, relying on the initial Staff approval, Commonwealth Edison built extensive chemical cleaning facilities and mobilized a large task force of architects, engineers and workers. By early 1980, Common-wealth Edison had satisfied the Staff with respect to the three open items and was ready to carry out the chemical ~ cleaning. It had expended a majority of its $37.5 mil 14gn budget, and incurred 290 man-rem occupational-exposure,F as compared to its original estimate of 250 to 500 man rem for the entire project. To complete the project today would cost only $1.3 million dollars and about 50 man-rem. In 1979 and early 1980 the NRC received a flurry of petitions from interested citizens and groups requesting that an environmental impact statement be prepared, and in one case, requesting public hearings. In May of 1980 Commonwealth Edison announced that it was deferring the restart of Dresden Unit 1 until June 1986 due to existing corporate short term cash flow deficiencies and uncertainty regarding regulatory requirements arising out of the System-atic Evaluation Program and the lessons learned from the Three Mile Island accident. At the same time, Commonwealth Edison stopped work on all major' engineering projects'at the ~"~ f acility, with the exception of the. chemical epleaning project,- -- for which special facilities had been completed, chemicals and personnel trained to a high degree of readiness. purchased, Shortly af ter Commonwealth Edison announced it was deferring restart of the unit, the Director of Nuclear Reactor Regula-tion decided to require preparation of an environmental impact statement "because of significant interest and concern expressed by raembers of the public relating to decontamination of Dresden Unit No. 1," even though the Staff's own reevalua-tion of the project again led them to conclude that it would This decision not significantly affect the human environment. was subsequently formalized as " Director's Decision Under 10 CFR S2.206," DD-80-24, 11 NRC 951 (June 26, 1980).

However, the same time as his decision to prepare an environmental at the Director denied the request for public impact statement, hearings, on the basis that the request was predicated on the lack of assurance that the NRC would inste an environmental 1/

This figure of 290 man-rem includes 84 man-rem incurred for projects not within the original 250-500 man rem estimate. Thus in building the chemical cleaning facility, Commonwealth Edison has done a good job in implementing ALARA.

4 t' Secretary of the Commission November 14, 1980 Page Four impact statement. Therefore, throughout this summer Common-wealth Edison maintained its facilities in readiness for chemical cleaning to take place in the fall. On August 14, 1980, the NRC sponsored a public meeting in Morris, Illinois to discuss the draft environ-Thirteen NRC personnel attended, including mental statement. technical reviewers, consultants and lawyers. management, Most of those who had requested that the NRC prepare an environmental impact statement or who had commented critically The on the draft environmental statement were also there. NRC experts addressed every question asked, and the comments of those who attended the meeting were reflected in the final environmental statement. When the final environmental statement, NUREG-0686, was published on October 17, 1980, it again reaffirmed the Staf f's conclusion that the chemical cleaning will have (Section 6). no significant impact on the human environment And it also concluded that: [T]he decontamination process and -the associated.P. ~ '" " facilities' built ~to solidify theiradioactive' '"~ W ' waste will not be subject to"any' accidentfimoYe ' ~ ~ 2' severe than those previously considered for' the Dresden site and will not result in any hazards not previously considered. This statement closely resembles the defini-(Section 4.3). tion of "No significant hazards consideration" contained in proposed 10 CFR 550.91(b), 45 Fed. Reg. 20491 (March 28, 1980). Commonwealth Edison is concerned to learn that the NRC is now contemplating holding adjudicatory hearings in We are at a loss to respect of the chemical cleaning. understand the basis for such a decision. There is no legal requirement for the NRC to hold ' adjudicatory hearings under the National Environmental Policy Act of 1969. Vermont Yankee Nuclear Power Corp. v. 519, 548 (1978). The NRC has now expressed, NRDC, 435 U.S.its view that there will be no significant three times, environmental impact associated with the chemical cleaning.

e 4 , ;w Secretary of the Commission November 14, 1980 Page Five Under Section 189a of the Atomic Energy Act of 1954, a hearing must be held in respect of any license amendment "upon the request of any person whose interest may However, if the NRC deter-be affected by the proceeding." mines that the license amendment involves "no significant hazards consideration," the NRC can issue the license amend-In such cases, the request for ment, effective immediately. by itself, require the licensing process hearing does not, The NRC has to grind to a halt while hearings are held. recently reaf firmed that this is the law in briefs filed by the Office of the General Counsel in the United States Court The NRC Staff has of Appeals for the District of Columbia. determined twice -- in 1975 and again, apparently, in the final environmental statement -- that no significant hazards Dresden Unit 1 is currently shutdown, and exist. In fact, there is no nuclear fuel in the reactor core or within the The Petition for Public Hearings spherical containment. filed by Citizens for a Better Environment on July 8, 1980 f ails to raise any specific safety issues, and the somewhat more detailed comments filed by CBE and others in respect of the draf t environmental statement have not altered the best judgment of the NRC Staff's own technical reviewers aspublic meeting in 14, 1980 expressed at the Augustthat there are-no serious. unresolved...nvironmental, e Illinoisy Thetonly, conceivable safety issue.with_ _~' or safety concerns. any substance seems to Commonwealth ; Edison to be wheth'er Jthe'. chemical cleaning will harm the reactor primary coolant. ~ Commonwealth Edison's and the Staf f's system boundary. grounds for confidence on that issue, based on the extensive corrosion testing program already carried out and the sur-veillance program which will follow the chemical cleaning, if necessary, in adjudicatory can safely be addressed, hearings after the chemical cleaning, but prior to start-up in 1986. Of course, the Commission has authority to require public hearings when it finds them to be "in the public interest." 10 CFR S2.105. But in Commonwealth Edison's view, the public interest is not well served by devoting substantial Staff and licensee resources to hearings which do not involve significant environmental or safety issues. As Chairman Ahearna stated in criticizing the decision to pre-pare environmental impact statements in this case: 1 1 4

~ r ~ c Secretary of the Commission November 14, 1980 Page Six If the NRC had a surfeit of people and funds and if EIS's did not add any time to the regu-latory process, then perhaps doing EIS's when i i (al-they are not needed might be' acceptable though not a responsible use of taxpayers' funds -- but since neither condition is the case, EIS's should not be done when they are not required. (FES, Appendix A). These remarks are even more compelling when applied to the NRC hearing process. The broader public interest requires that the'NRC weigh the costs of delaying the Dri; den chemical cleaning project pending completion of adjudicatory hearings: 1) An extended delay at this time would cause the loss of key personnel from the project. These people, some of whom have been with the project since its inception in 1973-74, have considerable expertise in the design, engineering, construction and operation of the chemical cleaning system, as well as related research studies;[1These people cannot be expected to put their professional ~ careers "on hold" indefinitely. The loss of these personnel will result in the loss of extensive knowledge and skills necessary for a successful completion of the project. New personnel will be required and it will take them considerable time to review the chemical, cleaning system to obtain a full understanding of its functions and operations. j Additional expense would be incurred to lay up the 2) installed equipment for proper long-term storage. An estimated $50,000 would be necessary to perform the actual chemical cleaning rystem lay-up. Another S25,000 would be required to perform the necessary maintenance and inspections for a one year lay-up period. (Total estimate $75,000) 4 3) A delay would require a complete repetition of preoperational testing of all equipment and I (8) systems taking a total of approximately eight weeks at a cost of $300,000. j

_ _~ n ? o s,. Secretary of the Commission November 14, 1980 Page Seven Additional f actors to be considered in-a delay of the chemical cleaning project due to the granting of a public hearing are as follows: Any delay in the chemical cleaning will require 4) personnel, as they perform routine activities, to The following receive additional radiation dosage. lists activities as a minimum that will be performed: Dosage Activity 1 man-rem a) Re-hydro test of the reactor pressure vessel system. b) Retraining of new personnel. 15 man-rem c) Detensioning of RPV head and 6 man-rem later retensioning, 1 man-rem d) Leak detection system maintenance. Total additional dosage not pre-viously~ estimated 23 man-rem This total of 23 man-rem does not include dosage which would be incurred as a result of any in service inspections required during the lay-up period. Activities related to the Dresden 1 lay-up could increase this number significantly. A delay in the chemical cleaning could possibly prohibit potential lay-up alternatives from being performed, due to excessive dosage. Any delay in the chemical cleaning reduces or 5) eliminates the company's flexibility to adjust the unit's return to service if load demand or The chemical financial considerations change. cleaning must be completed before many of the Early required plant modifications are made. completion of the cleaning allows efficient use of manpower and financial resources.

,o l n l = Secretary of the Commission Nove:nber 14, 1980 Page Eight In the absence of any significant new information calling into question the safety or environmental impact of the proposed chemical cleaning, Commonwealth Edison respect-fully requests that the Commission allow it to : proceed. Here controversy, without technical foundation, does not While we appre-justify paralysis of the licensing process. ciate the many other demands upon the Commission's time, we hope that the Commission, having accepted referral of this matter from the Director of Nuclear Reactor' Regulation, will make its decision promptly. In our view, the decision of whether or not to hold a hearing is clearly not an appro-priste subject for further delegation or delay. Very truly youpr,-] ^ / J j L /4l'/W One' of the Mtorneys fpr/ ~ m Commonwealtit/ Edison Company ~~ PPS/kb CC: NRC Commissioners Messrs. Bickwit Denton Trubach Goddard O'Connor Goldsmith (CBE) s .}}