ML14107A006
| ML14107A006 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 04/11/2014 |
| From: | Drey K Beyond Nuclear |
| To: | Bladey C K Rules, Announcements, and Directives Branch |
| References | |
| 79FR10200 00011, NRC-2012-0001, NUREG-1437 | |
| Download: ML14107A006 (14) | |
Text
Mendiola, Doris
Subject:
Attachments:
FW: Docket ID NRC-2012-0001 Callaway -- NRC Draft for Comment -- NUREG-1437
-- Supp. 51 ..... doc From: Kay Drey [mailto:tritium3@sbcglobal.
net]Sent: Friday, April 11, 2014 12:02 AM To: Bladey, Cindy
Subject:
Docket ID NRC-2012-0001
Dear Ms. Bladey:
Attached are my comments.77/'F -Thanks, Kay Drey-1U rnD CID SUNSI Review Complete Template = ADM -013 E-RIDS= ADM-03 Add= &.C~lý1 Comments on NUREG 1437 -Supplement 51: the Draft Supplemental EIS re Ameren/UE's application to extend the Operating License for the CALLAWAY Nuclear Power Plant for an additional 20 Years.The Draft SEIS was published in Feb. 2014 by the U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation.
These comments are being submitted via the federal rulemakings website at www.regulations.gov on April 10, 2014. They will also be mailed to Cindy Bladey, Chief -- Rules, Announcements, and Directives Branch -- Office of Administration.
Nuclear Regulatory Commission.
Docket ID NRC-2012-0001.(April 10 was the date originally announced by the NRC, and is the date toward which I was working.)From: Kay Drey Board member -- Beyond Nuclear 515 West Point Ave. St. Louis, MO 63130. tritium3@sbcglobal.net I told my 97-year-old husband that I was preparing comments to submit to the Nuclear Regulatory Commission about our electric utility's efforts to extend its Callaway nuclear power plant operating license for another 20 years. Leo responded:
Wouldn't it be dangerous if they operated the Callaway plant for another 20 years?I answered yes.The following comments will focus on some of the many reasons for my "yes" response.Daniel F. Ford, in his book Three Mile Island, 1982, p.29, included a disturbing list of common problems at nuclear power plants. "All nuclear-power-plant systems, structures, components, procedures, and personnel are potential sources of failures and malfunctions.
Problems can arise from defects in design, manufacturing, installation, and construction; from testing, operational, and maintenance errors; from explosions and fires;from excessive corrosion, vibration, stress, heating, cooling, radiation damage, and other physical phenomena; from deterioration due to component aging, and from externally initiated events such as floods, earthquakes, tornadoes, and sabotage." (1) Known fuel rod hazards -- and unknowns: Extended storage for irradiated fuel rods is inevitable at Callaway because the spent fuel pool is already dangerously overcrowded and because no safe, permanent, politically acceptable location has been found in the United States, and may never be found, for the nation's irradiated fuel rods --- for the rods already accumulated and for those that would accumulate in the future if the Callaway operating license were to be extended.When the Callaway plant was designed, Union Electric expected to use fuel rods containing 3.5% fissionable uranium-235.
Currently, high-burnup fuel is posing major concerns --- that is, reactor fuel that is enriched to a higher level of uranium-235, and that is left in the fuel storage pool under water for a much longer duration.In 2012, the official publication of the National Academy of Engineering of the National Academy of Sciences raised concerns about the viability of high-burnup fuel by noting: "the technical basis for the spent fuel currently being discharged (high utilization, burnup fuels) is not well established
.... the NRC has not yet 1 granted a license for the transport of the higher burnup fuels that are now commonly discharged from reactors.
In addition, spent fuel that may have degraded after extended storage may present new obstacles to safe transport." [ National Academy of Engineering:
Managing Nuclear Waste. Summer 2012 -pp. 21, 31.Emphasis added. http://www.nae.edu/File.aspx?id=60739
]In 2012 the Nuclear Regulatory Commission indicated that spent nuclear fuel in surface storage may extend to 100 years. In 2011 the U.S. Energy Department indicated that consideration is being given for a 300-year period before geologic disposal.The United States Nuclear Waste Technical Review Board, created under the 1982 Nuclear Waste Policy Act, issued the following key finding: "Insufficient information is available yet on high-burnup fuels to allow reliable predictions of degradation processes during extended dry storage, and no information was found on inspections conducted on high-burnup fuels to confirm the predictions that have been made." [ Evaluation of the Technical Basis for Extended Dry Storage and Transportation of Used Nuclear Fuel. December 10, 2010.]Of great concern, then, is that the fuel rods are becoming more and more dangerous because of their content (that is, the more highly-enriched uranium), and because of the many unknowns about the condition of the cladding and of the highly radioactive fuel --- during operation, storage, and transport to some hypothetical disposal location in the unforeseeable future.Some questions about the Callaway fuel that merit consideration:
(1) What is the radioactive inventory of the spent nuclear fuel in the Callaway fuel pool, and what are the burnup characteristics of the cores?(2) Has the NRC evaluated the period at which the Callaway power plant is expected to run out of wet storage space --- that is, in the spent fuel pool?(3) Does Ameren/UE have plans to install dry-cask storage? And if so, starting when, for what volume, and over what period of time?(2) Highly radioactive corrosion products throughout the power plant: Concerns linger about the buildup of highly radioactive corrosion products that accumulate on and inside safety-significant equipment within nuclear power plants. Please see the attached set of facts and questions about the pervasive, long-lived "crud" [Chalk River Unidentified Deposits].
I submitted those comments to the NRC thirty-four years ago --- about the health and environmental hazards of the high gamma-emitting rust and about the chelating agents that had been intended to resolve the crud problem, but instead exacerbated it.(3) Routine radioactive releases to the environment:
Extending Callaway's operating license would burden living creatures and the environment with twenty additional years of emissions of certain radioactive liquid, solid and gaseous materials generated at the plant for which no adequate filtering technologies exist. And no accurate monitoring equipment.
That includes radioactive hydrogen (tritium), and dissolved and entrained noble gases (krypton that becomes rubidium and then strontium, and xenon that becomes cesium) that would be released to the air and then land, and to the Missouri River and the groundwater
--- during the routine operation of the plant. It doesn't take an accident.(4) The increased exposure of Callaway plant workers: 2 Exposure to ionizing radiation increases the risk of damage to cells, tissues, and DNA, potentially causing mutations, cancer, birth defects, and reproductive, immune, cardiovascular and endocrine disorders.
Any exposure to radiation increases a person's risk. The longer a nuclear plant operates, the greater is the accumulation of radioactive contaminants and potential occupational risk.Conclusion:
In November 1974 I first learned that Union Electric (now Ameren) was proposing to build a nuclear power plant here in Missouri on a limestone plateau, and that an accident could cause the hot, highly radioactive fuel to melt through the limestone (known universally for its holes), and reach the groundwater.
I was told there could be a radioactive explosion.
Just two days later, on November 13, I made my first public statement against nuclear power, at a Missouri Senate committee hearing --- and have continued to study and worry about nuclear power and radioactive waste ever since.The above comments are being submitted with the hope that the Nuclear Regulatory Commission will deny Ameren/UE's application to extend its Callaway Nuclear Power Plant operating license for twenty years beyond its original forty-year operational tenure.Sincerely, Kay Drey
Attachment:
comments on crud at Dresden One.Submitted to the U.S. Nuclear Regulatory Commission.
7/16/80.3 0 re crLj_515 West Point Avenue Univorsity City, MO 63130 July 16, 1980 Director, Division of Licensing U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Dear Sirs Thank you for giving citizens the opportunity to comment on the proposed NRC/DOE/Dow/
Commonwealth Edison chemical decontamination demonstration project at Dresden Unit One, as described in the Draft Environmental Statement (Draft EIS), NIUREG-0686, issued in May 1980. However, I must protest once again that the public is being asked to forego answers to questions affecting health and safety because of Dow's proprietary rights. The only scientists who know the ingredients of Dow's Nuclear Solvent-i are those employed by Dow Chemical, Commonwealth Edison, DOE or the NRC -- and these are the very scientists who have been committed to the Dresden project and NS-I for at least several years. I continue to believe that scientists without a financial or emotional commitment to this project should be given access to the data necessary to evaluate its potential impact.My concerns about the Draft EIS and the proposed decontamination center around both facts that are known and those that are not.A. How can anyone be sure an accident will not occur during the decontamination?
We know that, contrary to basic design and operating guidelines for nuclear power plants, some areas of the Dresden reactor coolant pressure boundary have not been in-spected for seven years. Because of extremely.
high radiation fields at Dresden One, caused by the acoumubtion of crud, Commonwealth Edison "repuested and was granted relief from some inservi~e inspection requirements in 1973. (Draft EIS, p. 2-5)That is, for five years prior to the shutdown in November 1978 for the proposed de-contamination and NRC-mandated retrofitting, the NRC had "waive(d) inspection require-ments for safety-related components in plant locations where significant radiation exposures could occur." ("Identification of Unresolved Safety Issues Relating to Nu-clear Power Plants," NUREG-0610, January 1979, p. 44). As a result, critical nozzles, an estimated 40 to 50 primary coolant pipe welds, beltline welds on the reactor pressure vessel itself, and no doubt other safety-significant components have not been inspected for several years. (Draft EIS, pp. 4-1 and 5-2).How, then, can anyone accurately predict the potential volume or locations of leakage during the proposed 100-hour fluahing?
Who knows what will happen when five or ten.top& or more of a caustic, ohelate-based solvent come in contact with an embrittled twenty-year-old vessel, corroded heat exchangers and pumps, five miles of convoluted piping, etc. -- with vilves, welds and components fabricated out of literally countless different metals and alloys?If this system-wide demonstration project is not an experiment, as the NRC claims on the first-page-four of the Appendix, why is the federal government helping to fund it? If it is not an experiment, why are there so many unknowns?As "decontamination of reactors" was described by the NRC's Advisory Committee on Reactor Safeguards in its March 21, 1979, list of unresolved generic items of safety significance: "At this time the information on full scale decontamination (of primary reactor systems) is limited. Examples of potential problems include such items as handlino decontamiation solutions, potential hideout of radioactive products, enhanced corrosion and crud formation following decontamination, and the possible incompatibility of the different alloys in the pressure boundary with the decontamination solutions." B. In the event of an accident during the decontamination, what will be the effect upon NUREG-0686: the workers and the public nearby?Apparently no one has studied the synergistic effects of industrial solvents mixed with radiationm.
Although chelates are administered to workers mho have ac-cidentally swallowed plutonium or mercury, etc., essential trace elements normally found in biological tissues or cells are subsequently provided to replace those materials inadvertently removed. And the quantities involved in the therapeutic use of ohelates are of course miniscule compared to this project.No one has denied there will be leakage within the plant -- there always has been.Workers will therefore be exposed to unknown health risks, not only during the flushing, but during the evaporation, solidification, and shipment of the wastes, as well. Furthermore, if the chelates are broken down, as they should be to protect the public, this additional step will also increase the workers' risks. At this point I am absolutely unwilling to participate in the benefit/risk game. I firmly believe that neither the workers nor the public should be placed at risk: C. What radioactive wastes and other toxic chemicals are apt to be released to the at-mosphere during the evaporation, and in what quantities?
There seems to have been some debate among scientists at the EPA, NRC and ERDA about whether the presence of radionuclides in unexpected places at the Maxey Flats, Ken-tucky, radioactive waste burial site could be blamed on the ability of nuclides to migrate at subsurface levels (perhaps, it was hypothesized, because of the presence of chelates) or whether the evaporator plume from the solidification process was responsible for the dispersion. (EPA/0RP 520/3-75-021 and EPA-520/5-76/020)
D. Does anyone really know what it is inside the primary cooling system that you want to let out? Is this perhaps the ultimate Pandora's box? What is the composition of the--> crud?Answers to these questions are important because they affect the reliability of the NRC's prediction that "the longest lived significant isotope that will be solidified after the decontamination is Co-60 with half-life of 5.2 years. Tests have been per-formed to demonstrate that the stability of the solid polymer will not substantially alter for over 50 years, corresponding to 10 half-lives of Co-60." (Appendix, second-page-five).
1.. Fission productst Although a few fission products are listed on page 2-2 among the radionuclides expected to be present in the Dresden crud -- namely, oerium-141 (half-lifo of 32 days), cerium-144 and protactinium-144 (290 days), and rubidium-103 (41 days), plus three additional curies of "MFP" or mixed fission products -- is it not highly_ probable that a far greater variety of isotopes is present, and a great deal more radioactivity?
And is it not possible that some of the corrosion products, fission products, and actinides in the crud may have half-lives longer than cobalt-60's?
- a. Assuming the amount of fission products deposited along the ininr surfaces of the Dresden piping is dependent in large part upon the am1fuLeQLNel rod cladding failures, the prognosis for Dresden's crud is not good. In several publications cladding failures at Dresden One are specifically mentioned.
(1) In the first place, stainless steel cladding, used at least in the initial years at Dresden, is virtually obsolete.
The only boiling water reactor still using stainless steel clad fuel is the tiny 47 Mffe reactor at LaCrosse, Wisconsin."Stainless steel is no longer the preferred cladding material for most light water reactors because it absorbs more neutrons than does Zirca-loy. ... In boiling water reactors, stress corrosion cracking of stainless steel during normal operation is an additional incentive to use Zircaloy which is not susceptible to this problem." (from a letter to me from Harold Denton, Director, Office of Nuclear Reactor Regulation, dated July 30, 1979; signed by Edson Case.)(2) In an analysis in a GE report of iodine leakage rates at BWRs, the stainless-steel-clad fuel at Dresden One was cited as having experi-enced "severe" defects" in March 1965. (J. M. Skarpelos and R. S.Gilbert, "Technical Derivation of MER 1971 Design Basis Radioactive Material Source Terms," NEDO-I0871, General Electric, March 1973, p. 4-1)I do not know in what year the switch to Zircaloy cladding occurred, nor do I know what percent of the cladding has failed each year since.(3) Dresden One is not unique in having cladding problems, of course. But why is this history of cladding failure and leakage not reflected in the NRC's projections of the composition of the orud?As explained by B.C.J. Neil of Ontario Hydro at a conference on radia-tion shielding several years ago: "Volatile and gaseous fission prod-ucts such as radioiodines will diffuse to and escape from the minutest holes and aragc__ in a fuel sheath (cladding).
Water soluble fission products will dissolve in any water which enters the fuel sheath through a hole or crack especially when the fuel is temperature cycled (i.e., at power changes, shutdowns, or startups)." (from "The Contribution of Fission Products to Radiation Fields in a Pressurized Heavy Water Reactor," pp. 402-3. Although the title refers to a heavy water reactor, much of the paper deals with problems common to all water-cooled reactors.)
While much of the escaped fission products, as well as byproducts of tramp uranium, solid daughters of noble eases, etc., will stay suspended in the cooling water and will be filjterecd ot for burial or will be re-leased to the environment, same will settle out and become deposited as a part of the crud. According to Neil, at one plant which had experi-enced fuel rod cladding failures, the radiation fields during shutdown were increased in some parts of the reactor more because of the presence of fission products (such as zirconium-95 and its daughter, niobium-95, and Lanthanum-140, daughter of barium-140) than because of corrosion products (4) Cladding failures during the first decade of operation at Dresden are also described in a Bureau of Radiological Health study: "At Dresden, much of the fission product activity in primary coolant water is attributed to uranium that had entered the primary coolant several years previously from failed fuel elements." (B. Kahn, et al., "Radiological Surveillance Studies at a Boiling Water Nuclear Power Reactor," EPAs BRH/DER 70-1, March 1970, p. 6)b. Just as there are hundreds of isotopes within a fissioning uranium core at any one time, so may a great variety of these have escaped during the operating life of a reactor to seek refuge in the crud. And they are of all ages. come examples: (1) Cesium: According to a private communication sent in June 1975 to the authors of an EPRI study on the buildup of radioactivity, about 10 of the radioac-tivity released from a specimen of nickel-iron spinel deposited in the stainless steel clean-up piping at Dresden One (found during a decontami-nation of the clean-up loop) was attributed to cesium-34 (with a half-life of 2 years) and cesium-137 (30 vears). The major portion of the radioac-NUREG-0686 tivity came from cobalt-60. (S. G. Sawochka, et al., "Primary System Shutdown Radiation Levels at Nuclear Power Generating Stations," EPRI v 404-2, p. 18.4, based on communication from J. S. Scott.. Dec., 1975).While attempting to extrapolate any meaningful projections from just one small specimen of crud at Dresden may seem grossly unscientific, appar-ently the few isotopic analyses available to the nuclear industry are not much more inclusive.
One of the few primary loop crud deposits ana-lyzed for isotopic information for the above EPRI study, for example, was retrieved from Indian Point One, and seems to be no larger than 4.5 square centimeters.
By the way, the gamma dose rate of this small collection of mostly cobalt-60 measured one rem an hour! (EPRI # 404-2, p. 9.7)Perhaps this paucity of data explains same of the EPRI authors' pessi-rmism: "In summary, accurate prediction of radiation levels on out-of-core surfaces or assessment of the effects on shutdown radiation levels of plant operating practices or minor design variations in current gener-ation BWRs and PVRs are not considered possible within the state-of-the-(art." (op. cit., p. 58)(2) Iodine: In an enclosure to an NRC memorandum from G. Knighton, Chief, Environ-mental Branch, to D. Ziemann, Chief, Operating Reactors Branch #2, dated February 13, 1979, the manre r in which fission products may have become an integral part of the Dresden crud is described as follows: "lodines and other volatile fission products which may have plated out on the primary system surfaces will have decayed to insignificant levels before the cleaning begins so that these isotopes are generally not present." (p. 7)On page 4-7 of the Draft EIS a similar statement appears: "All radioac-tive iodine isotopes have been decayed to insignificant levels." What about iodine-129 which has a half-life of 17 million years?(3) Zirconium:
W',hile I have seen zirconium isotopes in lists of both corrosion products and fission products, zirconium clearly plays a role in helping to clog up a reactor, regardless of how it's labeled. And while I have not read specifically of Zircaloy cladding failures at Dresden One, there is no reason to think this reactor alone would have been spared.Since zirconium-95 is listed as one of the isotopes expected to be present in the crud at Dresden, is it possible that zirconium-93 may be present, too? Zirconium-95 has a half-life of 63 days; zirconium-U has a half-life of 900,000 years. Do you expect the radioactive zirconium to be present as the result of particles sloughed off of failed Zircaloy cladding, or as a fission product, or both?(4) Transuranics:
While not technically fission products, transuranics are byproducts of.he fissioning of uranium. (I am not meant to understand that sentence.)
The Bureau of Radiological Health's environmental surveillance report on Dresden One includes an especially important observation:
Although the alpha-particle spectrometer used to study the Dresden primary coolant in 1968 was apparently only sophisticated enough to be able to identify one NUREG-0686 group of transuranics in the primary coolant, the presence of one probably means others would have escaped into the coolant, too. Would this not also mean that transuranics could be in the crud as well?The BRH scientists attributed the group of alpha particles to curiui-242.(BRH/DER 70-1, p. 7) Curium-242 has a half-life of 163 days, but many other transuranics will be around for a lot longer. Such as plutonium.
(.. Corrosion products: a. Should there not have been a long list of co02osion products amid the pre-dominant radionuclides expected to be present in the oxide layer at Dresden, on page 2-2, Table I, of the Draft EIS?A list of the corrosion products activated (irradiated) by stray neutron bom-bardment within most nuclear reactors reads almost like the periodic table of elements.
There's not much missing. In the Draft EIS, however, the only corrosion products listed are cobalt-57, 58 and 60; zirconium-95; and manga-nese-54. Perhaps because Dresden One has been shut down for a year and a half, some of the most common, shorter-lived corrosion products may have been expected to have decayed to insignificant levels -- though cobalt-58 is listed and it has a half-life of only 22 days.If there is to be a thorough assessment of the risks of dissolving crud from the interior of a reactor, and bringing it out into the human (as supposedly distinct from the worker) environment, should it not include a far wider range of corrosion products?(1) The following corrosion products have been specifically identified in various reports about Prezden On -- that is, over and above the few mentioned in the Draft EIS: iron-59 (half-life of 45 days), iron-55 (2.7 years), chromium-51 (28 days), copper-64 (13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />), Manganese-56 (2.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />), nickel-65 (244 days), zino-69 (13.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />), zinc-65 (2.55 hours6.365741e-4 days <br />0.0153 hours <br />9.093915e-5 weeks <br />2.09275e-5 months <br />; a corrosion product of Admiralty for example, with which the Dresden One condenser was tubed until 19695, sodium-24 (15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />), phosphorus-32 (14 days), silver-llOm (253 days), cobalt-57 (271 days), tantalum-182 (115 days).(a compilation from EPRI # 404-2, December 1976; BRH/DER 70-1, March 1970;and General Electric # NEDO-10871, March 1973. Not included in these studies are coolant activation products, such as nitrogen-13, 16, and 17, oxgen-19, and fluorine-18.)
(2) In addition, the following elements were listed by the Atomic Energy Commis-sion in WASH-1258 among "corrosion products released to the primary coolant" in boiling water reactors:
silicon, carbon, vanadium, titanium, sulfur, lithium, tin, tungsten, and molybdenum.
("Final Environmental Statement Concerning Proposed Rule Making Action: Numerical Guides for ... the Criterion
'As Low As Practicable'
... in ... Effluents," July 1973, Volume 2, p. A-4)b. And aren't many corrosion products long-lived?
For example: (1) Carbon-14:
Is it not possible that long-lived isotopes of some of the elements men-tioned above would be found in the Dresden crud if it were isotopically analyzed, specifically testing for those components?
Once again, my comments about the composition of the crud are aimed at two basic questions addressed in the Draft EIS: the amount of radioactivity in the crud, and the potential persistence of its hazard in the human environment.
Apparently cobalt-60 is so prevalent becausd it is the most common activa-tion product of the natural cobalt that occurs to some extent in almost all iron and nickel alloys, as well as in stainless and carbon steels. Is NUREG-0686 it possible that carbon-14 may be an activation product of carbon steel, a material no doubt present at Dresden, such as in the con-denser? If so, might some of the carbon-14 have ended up in the oxide layer?(2) Nickel-63:
Aocording to the EPRI report mentioned above on the buildup of radioac-tivity, approximately 200 pounds per year of nickel is released into the Dresden One reactor as the result of the corrosion of Dresden's copper-nickel and Monel feedwater heaters, an amount "at least an order of magnitude greater than that at current generation BWRs with staibless steel feedwater heaters."' (EPRI ` 404-2, p. 18-4) The report explains that this causes the production of more cobalt-58 and 60.Does it not also mean that nickel-63 may be produced, too? Nickel-63 has a half-life of 92 years. I first read of nickel-63 in lecture notes of health physicist Karl Z. Morgan. He listed cobalt-60, niokel-63 and iron-59 as the most common corrosion products.
Apparently at least some NRC staff members expect niokel-63 to be present in the Dresden crud also.In the NRC memorandum mentioned above, dated February 13, 1979, George Knighton reports as follows: "By letter dated December 27, 1978, the licensee (Oommonwealth Edi-son) has committed to analyzing the spent decontamination solvent to determine the transuranic nuclide content of the solidified waste.The licensee also committed to sampling the demineralizer discharge product for Fe-55 and Ni-63 at the beginning and end of the waste processing cycle to ensure that no Fe-55 or Ni-63 is transferred to Dresden 1 radwaste or Dresden Units 2 or 3." While the processes involved in analyzing, ferreting out and keeping the transuranics, iron and nickel isolated are not at all clear, the fact that they may indeed be present surely is.3.1 According to page 15 of the Appendix to the Draft EIS, the Electtic Power Research Institute is presently sponsoring research by Battelle Northwest to develop "a weaker but more frequent decontamination process on line." (emphasis added). I 4 would certainly hope that neither the NRC nor DOE would allow its licensees to use non-biodegradable chelates while a plant is on line -- or even during a routine refueling or maintenance shutdown -- unless the uranium core is removed in advance (though cores, too, become crud encrusted), and unless the decontami-nation effluent is kept isolated from the rest of the plant's liquid radwastes sq.ý%the chelates can be broken down before shipment and burial.of the corro-sion/fission ptoduots.E. Is it really a good idea to bond chelates to the Dresden orud -- even if the pipe interiors get cleaner?Scientists already know that chelating agents, such as those included in Dow's NS-l, can cause the acceleraeAed nijration of radionuclides through the environment.
The J NRC staff says does not have "field or laboratory tests which quantify the migra-tion potential of radionuclides associated with Dow solvent...." (Draft EIS, Appendix, first-page-two).
On the contrary, field data do exist which demonstrate that radio-nuclides bonded to EDTA, an ingredient of NS-l, have migrated through the environment at a rate far faster than that expected if the chelates were not present. The very q ualities which make chelates effective as solvents --.irtabl to form clawlike multiple bonds with a metal ion, enabling them to dissolve normally insoluble metal Sand to keep them in solution -- are the same qualities that make them a persistent threat in the environment.
To quote from the abstract of a study by Means, Kucak and Crerar recently published 0 NUREG-0686 in England: "Multidentate chelating agents such as NTA, EDTA and DTPA are receiving widespread use in a variety of industrial applications and are entering natural water systems. The presence of these chelates in the environment cam be undesirable because they solubilise toxic heavy metals. We have analysed the relative biodegradabilities of NTA, EDTA and DTPA in several different chemical environments.
The objective was to determine whether any particular chelate is significantly more biodegradable than the others and therefore more desirable from an environmental point of view ...gradation rates of all three chelates are not rapid enough, even under ideal laboratory conditions, to preclude concern about their release to the environment." (J. L. Means, et al., "Relative Degradation Rates of NTA, EDTA and DTPA and Environmental Implications," Environmental Pollu-tion (Series B), Vol. 1 (1980), pp. 45-60)In the body of the paper a compendium of the primary hazards involved in the use of chelates includes the following: "While chelates are used because of their powerful metal-binding proper-ties, it is this same characteristic which may have undesirable environ-mental consequences.
For example, EDTA, which is used in nuclear decontam-ination operations, is causing the migration of ""Co from intermediate-level waste disposal pits and trenches in the Oak Ridge National Laboratory (ORNL)burial grounds. Because it forms extremely strong complexes with rare earths and actinides, EDTA and similar chelates may also be contributing to the mo-bilisation of these radionuclides from various terrestrial radioactive waste disposal sites in the USA. ... Indeed, the presence of significant concentra-tions of EDTA in 12- to 15-year old radioactive waste at ORNL attests to its persistence.
Therefore, wherever EDTA and similar compounds have been intro-duced into the natural environment, the aqueous transport of transition met-als, rare earths and transuranics, which characteristicflly form the most stable complexes with chelates, will be expected to occur."Also, chelates may degrade into compounds which still possesstal-binding properties, although probably weaker than e original complexing agent. ..."In addition to increasing the solubility of heavy metals, chelates can fur-ther increase the uptake of these metals by plants and consequently increase their ecological recycling rates and the possibility of their entering human Lfood chains. If chelates are present in domestic wastes, they may dissolve copper, lead and iron from plumbing systems and sewage effluents and/or adversely affect sewage plant efficiency." That last sentence might make one wonder about the wisdom of putting Dresden One back on line after the cleaning, though I have heard that Commonwealth Edison may not in--tend to take that action at any rate, decontamination or not. Apparently the cost of retrofitting much of the obsolete equipment to bring it into compliance with NRC requirements may be economically unjustifiable.
Although the full range of components of Dow's NS-l is not available to the public, in a letter dated April 18, 1980, to U.S. Senator Howard.Cannon from Nevada, the DOE in Washington, D9.C. made the following statement, based on information provided from the DOE's Idaho Operations Office: "The decontamination solvent and first water rinses will be collected and processed by evaporation.
The resulting liquid waste is estimated to be 60,000 gallons, containing approximately 15 percent etheylenediaminetetra-I NIUREG-0686 acetic acid (EDTA). This liquid waste will be solidified using a proprietary Dow process using polyester resins." Whether that means 151 of the 60,000 gallon sludge (the Draft EIS estimates 20,000 gallons on page 4-6) or 15Y of the Dow solvent, I do not know. Neverthelessp the remainder of the letter to Senator Cannon reveals many other important facts and opinionst In general, concerns about the disposal of decontaminating agents like EDTA by shallow land burial are appropriate and shared by the Department of Energy.The Department is currently sponsoring the following related research programs: 1. The quantitative effect of agents such as EDTA upon the mobility of radio-nuclides in the soil is being determined.
- 2. Techniques are being developed to stabilize old burial trenches.3. Techniques are being developed to destroy organio compounds such as EDTA.One such method would result in a final product encased in &lass.Disposing of the waste from the decontamination of Dresden I at the Beatty site, however, should not pose a significant hazard. The Dow resin is water re-pellent, and the lack of water at the Beatty site will severely limit any migra-tion of radioactive waste. In addition, the predominate nuclide is cobalt-60, which has a 5.2 year half-life.
The Dresden I decontamination process will probably not be used to decontaminate other reactors.
The process is applicable only to bailing water reactors, and the proposed process is not economical.
The sponsoring utility, Commonwealth Edison, is in fact considering a different process for Dresden I1." (from Sheldon Meyers, Deputy Assistant Secretary for Nuclear Waste Management, DOE.Original signed by R. G. Romatowski)
Even just one or two of the above statements alone should provide reason enough for the Dresden One project to be postponed.
Data unearthed (1) by the Department of Energy after the crud has been bonded to the chelates and brought into the environ-ment may be too late.F. Does anyone know for how long Dow's s, if i plastic resins will be able to keep chelated radioactive wastes solidified
?I don't know how to comment on the reports of laboratory tests performed by Dow of its own solidification agent other than cynically.
Nevertheless, even without being able to unscramble which Dow and Brookhaven tests were which in the Draft EIS, it seems clear that some cobalt-60 can and did begin leaching out of the radioactive waste/Dow NS-l/Dow polymer matrix when immersed in pure distilled water in only one weekl Although none of the solidification tests was trying to simulate burial ground conditions, do they not all indicate that the Dow matrix is indeed porous and that chelated oobalt-60 remains highly mobile?If one adds to those laboratory studies the field data from Oak Ridge, Tennessee (Means et al., Science, Vol. 200, pp. 1477-1481), Maxey Flats, Kentucky (research in progress at the U. S. Geological Survey in Denver, Battelle -Columbus Laboratories, and Brookhaven National Laboratory), and West Valley, New York (research in progress at BNL), can anyone still be wondering whether it is wise to experiment in nature with huge quantities of Dow's plastic resins to see if they can really keep huge quantities of chelates from keeping huge quantities of radionuclides in solution -- as the chelates apparently are wont to do?What is the expected lifetime of the Dow vinyl-ester-styrene itself NUREG-0686 under burial conditions, and when subjected to radiation and chelates?
As studies in California, South Dakota and Illinois have shown, data collected in Oklahoma also indicate that "low levels of many potentially undesirable organic compounds were being contributed to groundwater within and immediatel , under the Norman (Oklahoma) landfill by solid waste deposited in this landfill." (W. J. Dunlap et al., fram a symposium on "Gas and Leachate from Landfills," EPA-600/9-76-004, March 1976, p. 105.Emphasis added.) As the Dow solidification agent breaks down, could it, too, release components that in themselves may bond onto the Dresden radionuclides and other wastes already at Hanford and Beatty, adding to the migration problem?G. Can anyone be sure the Washington and Nevada sites will remain dr ?A U.S. General Accounting Office report lists characteristics identified by earth scientists about America's low-level waste dumps for which inadequate data have been collected, and "about which not enough is known to reasonably predict the migration direction and rate (of radioactivity movement) or to determine whether reasonable pre-dictions can be made." Major information lacking about the Hatnford site includes: "rate of infiltration (the amount of water that is not evaporated or transpired and is free to move downward), rate and direction of ground water movement, and intercon-nection between shallow and deep aquifers." The data needed for the Beatty site includes "rate of infiltration, and direction and rate of ground water movement." ("Improvements Needed in the Land Disposal of Radioactive Wastes -- A Problem of Centuries," RED-76-54.
January 12, 1976; pp. 13 and 45-46.)The same report describes the following: "Through 1974 over 140 billion gallons of licuid waste containing about 5 million curies have been discharged into the ground at Savannah River, Idaho, and Hanford with the intention that the radioactivity would be trapped as it mand through the soil beyond the point of release and that the ex-tent of migration would be limited by removing the driving force of further liquid releases.
As soon as technically and economically practical, ERDA (DOE) plans to discontinue such practices." (Op. cit., pp. 5, 6)Where are those Hanford liquid wastes now?Because of the possibility that long-lived transuranics and fission products may be present in the crud at Dresden, as well as long-lived corrosion products; and because chelates in the proposed Nuclear Solvent-i are known to cause the migration of radionu-clides through the environment; and because neither the proposed polymer matrix nor the mild steel drums is capable of serving as a permanent barrier to keep the Dresden wastes segregated from other known and unknown, liquid and solid wastes already present at the Hanford and Beatty sites or apt to arrive in the future; and because Mother Nature --who is in charge of 500-year rainfalls, the Columbia River and the Amargosa, groundwater and aquifers, the Cascade Mountains, earthquakes and climates -- refuses to be held accountable, I urge the Nuclear Regulatory Commission to withhold its permission for Commonwealth Edison to use chelates to flush its crud out into the human environment.
Sincerely, Mrs. Leo Drey (Kay)
-~Decontamination 4m' eudd e,#dn, [nof SiKrnia*i7 In describing the measure of how radioactively hot an area is in which a worker may have to perform inspection, w a or repair tasks, the nuclear industry speaks of the "radiation field." As the plants in the country have gotten larger in electric owtput, particularly larger, for example, than a submarine reactor, the radiation fields have gotten hotter -which means, among other things, the* an individual worker gets burned out -or gets his full quarter-year's annual dose -in a much shorter time. In some areas of some plants, for example, a worker or inspector may only be able to stay in a given area for a minute or a minute and a half. This makes repairs at nuclear plants expensive, of course. At Indian Point One, about 26 miles from Central Park in New York, it took 700 men 8 months to repair a thermal sleeve because everything was so radioactively hot. The same repair job at a coal-fired plant would have taken "about two weeks using 25 men." (Bernard Verna, Nuclear News, November 1975, p. 52). The high radiation fields also make things dangerous.
At Dresden One near Joliet, Illinois, the radiation fields were so hot near the reector, for example, that inspectors had not been able to examine some of the most critical welds in the plant for seven years -the welds could not even be inspected, let alone be repaired if need be. These were welds at the reactor coolant pressure boundary.Even the NRC finally realized, apparently, that continuing to let Commonwealth Edison deviate from its technical specifications could prove disastrous.
It had been discovered that one of the primary reasons that the radiation fields were so hot in certain places at Dresden One and at other plants was the buildup of radioactive corrosion products -in the primary cooling loop they call these products "crud"; in the secondary loop, they're called "the green grunge." Just as other pipes tend to corrode or rust over time -or accumulate petal oxides -those at nuclear plants do, too. A major difference, however, is thatIa nuclear power plant the corrosion products themselves become radioactive as they're bombarded by neutrons -and the major component of the crud, it turns out, is cobalt-60
... one of two isotopes most commonly used at hospitals in a sealed source for radiation therapy. A patient normally has his or her cancer cells exposed to the cobalt-60 or cesium-137 source for a matter of seconds to try to kill the cancer cells. Nearby healthy cells may also be destroyed, but there is no alternative.
Well, to repeat this same cobalt-60 is the primary component of the crud in nuclear power plants. And since cobalt-60 gives off powerful, penetrating gamma rays that are readily registered on a worker's film badge, or other monitoring equipment, an area with a heavy accumulation of crud is going to be undeniably hot.They speak of crud traps, places where a pipe may turn a corner, for example -where the crud or cobalt-60 and related corrosion products build up. To give you an example of how hot cobalt-60 can be: At Indian Point, one piece of crud measuring just +Y2,w;,ta or about 2 inches square, gave off one rem an hour -- that's the equivalent87,600 times the amount of background radiation we are exposed to in one year. That was a 2" square and yet Dresden One, one-fifth the size of Callaway has 5 miles of piping.(Callaway will have 100 miles of piping !) This accumulation of crud, by the way, not only increases the radiation field for the workers, but it causes the pipes and other parts to clog up and become less efficient or even inoperable.
The solution the nuclear industry has been proposing for years -- and which has been used at least to some extent at all commercial and military reactors -- is to use chemical decontaminants, or solvents, to dissolve the crud from within the pipes, and off of various parts that need to be repaired or replaced.
It turns out, though, that three scientists at Princeton and Oak Ridge discovered that the very chemicals that have been used for decontamination and were to have been used for the first total-plant decontamination experiment at Dresden One back in 1978, are the ones that have caused radioactive wastes to migrate out of burial trenches.
They're called chelating agents.They bond onto and dissolve the corrosion products off of the pipes and parts so that the corrosion oroducts can then be flushed away. The problem is that they stay bound, ano keeo the radioactive metal products in solution so that after burial they're able to miorate throuch th environment.
It's been described as burvino radioactive waste with foiler skates on.