ML20125C957

Responds to Urging Acceptance of Il State Energy Alliance 790920 Petition Per 10CFR2.206.Advises That Appropriate Action Will Be Taken in Reasonable Time

ML20125C957
Person / Time
Site:	Dresden
Issue date:	12/20/1979
From:	Vollmer R Office of Nuclear Reactor Regulation
To:	Berick D ENVIRONMENTAL POLICY INSTITUTE
References
NUDOCS 8001110675
Download: ML20125C957 (2)

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Docket No. 50-10 .

Mr. David Berick i Environmental Policy Institute i 317 Pennsylvania Avenue, S. E.

j Washington, D. C. 20003

Dear Mr. Berick:

This is in response to your letter dated November 19, 1979, which urged acceptance of the September 20, 1979 petition from the Illinois Safe Energy Allicrce (* SEA). The ISEA petition requested public hearings i be held on the decontamination of the Dresden Nuclear Power Station, Unit No.1.

Our letter to Ms. Marilyn Shineflug, Co-Chairman of ISAE, dated October 30, 1979, acknowledged receipt of the petition and informed her that the Alliance's petition would be treated under the provisions of Section 2.206 of Title 10 of the Code of Federal Regulations. As required under the provisions of this Section, we will take appropriate action within a reasonable time.

Your letter referred to research carried out by Means, Crerar and Duguid (Science, Vol. 200, 30 June 1978). The referenced paper discusses the disposal of 35 million gallons of liquid waste in burial pits at Oak Ridge National Laboratory between 1951 and 1965. Commonwealth Edison, the licensee for Dresden Unit No.1, has agreed to dispose of the Dresden 1 waste at either Beatty, Nevada or Hanford, Washington commercial low level waste burial sites. These sites differ significantly in their geologic and hydrologic characteristes from the Oak Ridge site where chelant-aided migration of radionuclides was observed by Means, Crerar and Duguid.

Specifically, the Oak Ridge site, where migration occurred, experiences very high precipitation and has a water table so shallow that it i probably intersects the disposal pits and trenches during periods of '

heavy rain fall. In addition, the Oak Ridge topography is hilly with steep slopes underlain by fractured shale material which allows under-ground water and radioactive waste to flow down hill through the fractures until it seeps to the surface within 250 feet of a perennial stream. 1 90022243 8 0 0111g

Mr. David Berick December 20, 1979 Conversely, the commercial waste burial sites at Beatty and Hanford, where no migration of radionuclides has oeen observed, are flat desert areas with very low precipitation, a water table approximately 300 feet below ground level and a distance of 8 to 10 miles to the nearest perennial stream.

In addition to these site characteristics, which prevent the migration of radioactive material from the desert waste burial sites, another significant difference between the proposed waste disposal technique and the now discontinued Oak Ridge methods is that the Dresden waste will be disposed of as a solid. At Oak Ridge over 35 million gallons of liquid radioactive waste was pumped into the disposal trenches. We estimate that approximately 7 million gallons of liquid waste was disposed of in Trench No. 7, wnich you identified as a source of chelated radionuclides. Because of tne differences we have concluded that the Dresd:r. .;;;ts: shculd be disposed of in a dry Durial site.

As you have stated, research at Brookhaven National Laboratory has shown that the decontamination solution causes corrosion of tne waste containers. This f act has been recognizec by both NRC anc Commonwealth Edison from the beginning of tnis review. Because of potential corrosion, Commonwealth Edison initially proposed to solicify the waste to prevent the corrosive liquid from attacking the shipping containers.

I hope this information is responsive to your letter.

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WA RicErd H. Vollmer, Acting Assistant Director for Systematic Evaluation

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0 Environmental Policy Institute 317 Pennsylvania Ave. S.E. Washington D.C. 20003 2Q2/544 8000 O

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November 19, 1979

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Dear Mr. Denton; The Environmental Policy Institute urges you to accept the September 20, 1979 petition of the Illinois Safe Energy Alliance requesting public hearings on the decontamination of the Dresden Nuclear Power Station, Unit 1(44 F.R. 64577, Novem-ber 7, 1979).

As the Institute commented in its response to the Advance Notice of Proposed Rulemaking on 10 CFR Part 61 concerning Management and Disposal of Low-Level Wastes by Shallow land Burial and Alternative Disposal Methods (43 F.R. 49811, October 25, 1978), a number of concerns have been raised about the disposal and migrat1on po- ,

tential of low-level wastes resulting from decontamination operations. Means, l Crerar, and Duguid(Science, Vol. 200, 30 June 1978) identified mobilization of radionuclides from shallow disposal trenches due to organic chelating agents in-corporated in the disposed wastes. We note that NRR's response to such concerns has been to recommend that decontamination wastes be sent to "dr," disposal sites.

This seems to be an unsatisfactory resolution of the problem.

Our concern is heightened by recent work done at Brookhaven National Lab by Dr. Hersh Manaktala on the solldification process and corrosion potential of the Dow Chemical "NS-1" decontamination solution. While the pre 11minary in-  !'

formation made available by Brookhaven indicates a substantial amount of leeway in the actual solidification process, a significant potential for corrosion of steel waste containers exists from the solution itself. Additional data on the leachability of contained radionuclides and chelating agents from the solidified NS-1 waste forms has yet to be released.

We believe that the NS-1 solidification process and durability of the re-sulting waste form (including container)is sufficiently untested and uncertain to warrant the requested hearing. The NS-1 decontamination solution issue is not only pertinent to Dresden but to all solidification and disposal situations where similar chelating agents are used. NRR must address the issue of ultimate disposal of these materials, not simply the on-site application of them.

pectful ,, ,

r f fM Q David Berick g D o O cc:R.E. Browning "n ero S / y 90022245 Pnnted on recycled paper