ML19330A536
| ML19330A536 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/18/1980 |
| From: | Ginsburg R, Goldsmith R CITIZENS FOR A BETTER ENVIRONMENT |
| To: | NRC COMMISSION (OCM) |
| References | |
| CBE-80-141, NUDOCS 8007280537 | |
| Download: ML19330A536 (24) | |
Text
. _ _ _ -
CBE 80-141 Tills DOCUMENT CONTAINS P00R QUAUTY PAGES s,
J COMMENTS ON THE DRAFT ENVIRONMENTAL STATEMENT RELATED TO THE CHEMICAL DECONTAMINATION AT DRESDEN UNIT 1 BEFORE THE UNI TED STATES ilUCLEAR llECULATORY CO.'"ilSc. I0d SUBMITTED ON 3EHALF OF CITIZENS FOR A BETTER Li4VIRONMENT BY ROBERT GoL: SMITH, Esa.
AND COO)
ROBERT GINsBuRe, Ps.D.
5 JULY 18, 1983 O//
- I 8007280537 e
ECEECT CWT INTRODUCTION The following are comments of Citizens for a Better Environment (CBE) concerning the Draf t Environmental Statement (Draf t EIS) related to
" Primary Cooling System Chemical Decontamination at Dresden Nuclear Power Station Unit No.1," Connonaealth Edison Comoany (CECO), May 1980, written by the U.S. Nuclear Regulatory Commissien (NRC).
CBE is a not-for-profit corporation speciclizing in environmental research and liti-ga tion.
CBE has approximately 3500 members in Illinois ana over 10,000 members naticn. vide.
Many of CSE's rembers ;ive near nuclear power plants and are seriously concerred about the onvironr.eht3l iigaCt of these plants.
CBE applauds the NRC decision to do an E!3 ccccernin<; tne decontamination of Cresden 1.
Hcv.e v e r, as.hese cc ren*.: indicate, SE b lie,es the Draf t EIS is technically deficient and superficial in its analysis.
What is more, CBE has requested by petition a full pubiic nearing on this EIS.
Because the decontamination of Dres ien 1 will serve as a model for future decontaminations, CBE believes that this EIS should consider the envircn-mental impact of future, similar decantaminations.
It is CSE's position that a progrannatic EIS nust be done for the decontaminations whicn are sure to folicw that of Dresden 1.
Thus tne Graf t EIS under consideration is not only inadequate insofar as tne Dresden 1 decentamination goes, cut it is also deficient in that it fails to consider the disposal and trans-portation of all the.43ste generatec in like decontaminations as well as
. e:.CEE R & :1:::.7 other generic issues raised in these comments.
Hence, to fulfill the
- ndatebof the National Environmental Policy tct (NEPA) the flRC must
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prepare and circulate an EIS related to the chemical decontaminations i
1
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Jof light water, commarcial power, nuclear plants.
GENERAL ORGANIZATION AND ANALYSIS i
-The overall organization and analysis of this Draft 215 are deplorable.
Many pages are not even numcered. Several tables and charts are direct transfers from other documents.
Much of the text is verbatim from pre-f vious ceForanca or submittals. All of which evinces a failure to under-take a sericus, independent, systematic analysis of the proposed decon-tanina tion.
This certainly violates the spirit of NEPA and in many j
instances the !etter.
Eeginning with Table 1, p.
- -2, the EIS directly lif ts this table from CECO's submittal of April 14, 1975.
These data are crucial because they are relied upon to determine how radioactive the resultant waste will be.
.Hence CECO's own data, not the NRC's, form the foundation upon which many steps and decisions are built. The EIS does not mention any con-firmat;ry testing done by NRC or any other federal agency.
This abdica-1
-tion of an essential piece of analysis negates the role of federal assess: rent cf _ the envirunnental impact of the project.
1.
Section 102 of fiEPA requires compliance "to the fullest extent possible."
.2.
See. sections 102(2)(A) which requires a " systematic, interdisciplinary approach" and 102(2)(C) which requires a " detailed statement."
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.. EQEDO MMC Tables 3,;i and 5 and figure 2 in the Draf t EIS are all identical to Table I, pages 5-9, and Figure II, p.15, found in CECO's "Dresden 1 Chemical Cleaning Licensing Submittal," dated Decemoer 16, 1974. This direct transfer from CECO's submittal to the EIS again reflects the utter dearth.of independent agency analysis. All the alternatives short of shutting the reactor down (see infra) are thus lef t up to the inter-ested industry.
In no sense of the term can the NRC in this Draft EIS be said to have taken a "hard look" at. the environn. ental conse-quences.
If anything, the uncritical adoption of an industry study submitted nearly six years ago demonstrates the NRC's desire to jus-
- tify a decision already made and thus directly contravenes the Council i
on Environmental Quality (CEQ) regulations implementing NEPA, 40 CFR
~
1502.2(g) and 1502.13 The analysis of Radioactive Waste, section 4.2.2, p. 4-6 et seq., is derived virtually uced for word from Attachment 1 to a memorandum from I
G.U. Knighten to D. Ziemann, dated June 21, 1979.
Even the conclusion on p. 2 of Attacncent 1 is identical to tne conclusion at the end of section 4.2.2 of the Draft EIS, except to the extent that the Draf t EIS t
cites different regulations and statutes. On the face of it, tnis is l-i not necessarily illegal since the NRC oid perform some of its own anal-ysis.
However, it should be noted that Attachment 1 is based in part 4
. upon-an earlier -evaluation of December 9,1975 along with information 7
. added since 1975.
The EIS, on the other hand, adds nothing to the anal-ysis of June 1979 and thus we' wonder whether the NRC has overlooked any g
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new developments and information since that time. Again this betrays
'NRC's cavalier attitude toward this EIS.
To a lesser extent ~the section on Occupational Radiation Exposure, 4.2.1, pp 4-1-4-6, is derived from a memorandum from G. Knighton to D.
- iemann, dated February 13, 1979.
This section, in addition to the previous sections derived elsewhere, leaves only four to five pages of text which were done for the sake of this EIS.
It is clear that this EISt is a " cut-and-paste" job and by no stretch of the intgination ful-fills the requirements of MEPA.
AMALYSIS AND MATURE OF THE PADI0 ACTIVE " CRUD"
- The initial step in analvrina the oroblen of radioactive deoosits on reactor cooling pipes is to accurately identify the nature of the deposits.
The NRC has aoparently failed to accor.olish this task. The value for the total amount of radiation, as reported by the NRC to Prof.
Banaszak on 9/7/79, has a very large error ( 3000 ! 1000 curies ).
The total a~ount of' radiation to be removed has an impact on several areas of the project, escecially radiation exposure and waste discosal.
Without an accurate assesment of the amount of radiation in the pipes there cannot be effective plannina.
The Draft EIS also does not indicate. hew 'the sampling was done, where the samples came from, how long 'they had been _ removed from excosure to radiaticn ( in order to determine the presence of shorter lived _ isotopes ), and the source of the large error.
The second' critical cuestion af ter the determinatien of the total 1l amouiitlof radiation to be renoved is an analysis of the scecific j
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- radionuclides present in the crud.
There are t'..o aspects to this question.
I First the oossible_ presence of fission oroducts _ and transuranics and' second the cresence of other radioisotoces cenerated from the materials in the coolino systen.
It is surprisina to us that Table 1 does not contain any isotopes of materials found in the coolina system such as Fe, Cr, Ni or Cu isotooes. - It is odd that the components of stainless steel
-( which was most likely used for at least part of the cooling.
. system ) wot.:d not contribute to the radionuclides in the crud.
Furtherncre a study by_ EPRI (see Aapendix A) in December 1975 indicated
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that 'in 1968 large cuantities of Cu-64 were founc in the reactor water.
Since Table 1 sas constructed by CECO in a report prior to the shutdcwn of Drescen 1 in Odtober 1973 it is surprising that Cu-6a is not included i
in the table.
The presence of fission products in the crud is of even greater concern
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given their longer half lives.
The sane EPRI recort, mentioned above, l
indicated that Cs-134 and Cs-137 had been in scne deoosit3 in the stainless
. steel clean-up piping at Dresden 1.during a decontamination of the clean-uo loop. Both Cesium isotooes are fission products with half-lives of 2.1 and 30.1 years respectively.
Furthermore the Draft EIS mentions in section a.2.2 ~ that radioactive Iodine levels will have decayed to insignificant
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levels.
If I-129 or I-131 are present,then other long lived fission -
products should )lso be present.
If the NRC concludes they are not, a detailed explanatinn of-that conclusion is necessary. As mentioned t
Epreviously, paragraph d.2.2 in the EIS was cocied nearly. verbatim fron an earlier Ceco report. Only' the sentence on the radioactive iodine d
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was added. Daviously the NRC thnuynt it important enouqh to mention the possible problem from lodine isotopes ( and by implication the presence of other fission products ) in the crud but not important enough to of fer any reasons or e> planations. The absence of any of these radioisotopes from Table 1 or any explanation of their absence raises serious cuestions abcut the 6dequacy of the analyses performed by Ceco and Dow and their subsequent evaluation by the NRC.
CORROSION One of the primary concerns of the NRC should be some assurance that the decontanination does not degrade the integrity of the primary coolant system boundary. Unfortunately the Craf t EIS aadresses this problem mcst perfunctorily.
One of the bases of public concern over the decon'. amination has been the possibility of damaging the reactor ano tnus preci; i ta ting a majcr acci fen'. in the f iture.
?.e NRC has ignored the ccr.cerns of the public as well as of gosernment scientists.
In particular, a memo from John 'Aeeks (4/16/79) at Brocknaven National Latorataries (BNL) expressed concern trat significant amounts of MS-1 sci zent might be trapped in creviced are u around bolt; or in creviced pockets formed by galvanic corresion near defects of the vessel clad.
Tre water rinse cycles could easily fail tc remove such trapped solvents.
The longer the solvert remains, :ne more corrosion becores significant These concerns were initially raised by studies done by Ocw ano GE cn various steel types found in the reastor.
Those studies reported that type 410 steel which is used in a nuncer of bolts and valves in tne core support systen is susceptib'.e ta corrosion an'Jer certain conditions.
The SNL remo said that such conditions could readily exist in the reactor
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especially if there is an extended period between the decontamination.
and start up.
It is likely there will be such an extended period since Dresden 1 will not be on line again until 1986.
1 At page 14, Appendix A of the Draft EIS, the NRC states that the chelating
~
agent decomposes at 300 deg. F.
ilithout knowledge of the formula for'NS-1 it is impossible for commenters to confirm whether those decomposition products will indeed be innocuous.
It is likely that the decomposition.
-products will include other complexing agents or remain corrosive in scme other fashion.
Thus even the start up of the reactor would not alleviate the problem of trapped solvent.
REMOVAL AND CCOTA!T'ENT OF USED SCLVENT Since :ne dccontamination solvent is not described in detail because of proprietary rignts, several questions arise concerning the nature of the t
radicnuclide-chelate complex. Since such complexes and the uncomplexed chelates are known to be highly mobile in the environment ( see Crerar et.al.
article referred to in Appendix A of the Draf t EIS ) and the food chain, there is great concern over any possible release of these materials.
4 After the decontamination, CECO plans to concentrate the decontamination solvent. and the first rinse in an evaporator and further purify the distillate by passing it through a demineralizer. Other rinses, if
- necessary, will be purified similarly.
If the complexes are ncn-ionic,
-significant; quantities of radioactivity may distill over into the
' distillate along with.some uncomplexed _ chelate. Moreover, any non-ionic
-species will be less efficiently removed from the oistillate or later
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rinses than will ionic species. Such a situation could lead to increased time and-costs in purifying the waste water and storage of the wastes. The Draft EIS also-does not address the fate.( i.e. eventual disposal ) of these demineralizers and evaporators. They could be highly contaminated with radioactivity.
Also, if any chelate ( whether complexed or not ) were trapped in the pipes and only slowly leached out o.er time, it could eventually be flushed into the Illinois River.
The release could cause radionuclides emitted in past years and now trapped in river secitrents to ce resuspended or redissolved and thus reenter the facd cnain.
This would pose a long term problem even if only small quantities of chelate were involved.
Even 0.01. of the original 200,000 gallons from the deconta lination ar.d first rinse could provoke :erious envirancental consequences. The Draft EIS does not ad;quately discuss these points, if address them at all.
PACKAGIflG AND DISPOSAL OF THE C0!!CErlTRATED WASTE The Draf t EIS states that the concentrated waste will be solidified with a vinyl ester-styrene polymer in 55 gallon steel drums.
In the process of describing the procedure ( Draf t EIS, section J.2.3 ) the f2C shrugs off concerns about (1) the l_i;~etime of. tne steel drums and whether they will remain intact iong enougn to be buried, (2) that the polymer matrix and steel drums will not prevent significant leaching,-
even at the " drier" disocsal sites and (3) what will happen if the waste has radiation _ levels greater than 10 naccuries/ gram and cannot ce
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disposed of in a low level waste depository.
As to the durm's lifetime, experimental results from BNL ( H. K.
Jtanaktala cemo, 10/31/79 ) indicate that pockets of liquid would be very corrosive to corc.aercial grade mild steel used in the drums.
Such pockets of liquid could form for several reasons, including mixing errors and variations in the composition.cf the solidified waste.
The data showed that formation of pin holes.as easily possible I
in 1 to 3 mon;hs. 'It is likely, given the extent of 'the project, that the barrels will not be delivered tc the disposal site fcr several wee'.s af ter they are filled.
In tnat time period it is reasonable to assune that sore of the dru":s could develop small leaks.
In 'the face of the SNL conclusions, the Draf t E*.3 ( section 4.2.3 )
concluded ctnerwise, i-j The Draft EIS almost completely ignores the problems of chelates l
j leaching into tne environment by saying that the chelate complexes will be trapped _in the polymer matrix and surrounded by a " dry l
environment". However even in a dry environment a concentrated plume of chelate bourd radionuclides could slowly leach out of the barrels 4
and eventually the site.
The solidificatio1 is cnly for_ ease of transportation and to sicw down leaching - rot eliminate it.
Ir. thi s.
L case minration could be easily aided by the NRC's proposed burial
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policies.
In particular, the NRC proposes to segregate the waste-from everythinc but organic materials'like toluene and xylene.
In our. experience such materials could probably dissolve the polymer
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. C2ME : i 1' ' i tatrix freeing tne radionuclide-chelate complexes.
In such a situation a highly dangerous form of radioactivity whose chysical and chemical charcrtorisitics are unknown would be rel' M d.
It is frijntening to see tne NRC recornend a prncedure whicq could have wch consequences and runs counter to their own stated g als.
The problems raisc f in the first section of these *ec,r ical coinents ccncerning tne an7unt of radioactivity and tne nature of tne radionuclides has further significance for the ur.te disposal prcMem.
Tne presence et significant quantities af long-lived ridi auclide; ind/or transuranics rnat in:re.ises the level of radinactivity over the limit for low level disposal..ould pose i very real discosal prenlem for the project.
In that case tre 13ste would have to be stored at Jrescen until a
" w sitcr. mera:ed by :he 's. ; mernm en t,a,ica i, mtnar:cm1 to dispost af transuranic waste' is crejtei ( 3raf t E:5. 'rpencix A ).
That ray take long time. Alterr.atively if the waste is still "los le.e!
but with icnger lived isotopes than Co-60, leakage frcm the waste u.sposal site and contx:;ination of water an : the food enain could be very significant and hazardous, in ei ther case, the assurances by the 'sRC in section 4.2.3 that the waste can be isolated from tne human environment for a long enougn perice of time are not satis *ving or even barely adequate given these uncertainties and tne ananswered questions in the Draf t EIS regarding the arcunt and type of radioactivity.
TRAN3PORTATI0" AMD ~'ERL_NCY PRO:EDURES The Draf t EIS does act F.ention or even apcear to have thca;ht acout
_11 SCEE ':!r : r about the problem of transporting the waste from filinois to Washington State. We have already described the possibility of pin hole leaks developing in the drums. There is also a real possibility of a nighway accident and resulting spills.The latter is even more serious since the NRC estimates from 10 to 100 trucks for transporting these wastes which must be multiplied for future decontaminations the NRC is planning. A spill from one of these trucks could cause severe long term harm.
There is no mention in the Draft EIS of special precautiors that will be necessary in the case of an accidental spill.
The Draf t EIS downplays the possibility of anything going wrong with their plans.
There are no contingency plans to inspect inaccessible welds, bol ts etc.
if accessible,. elds and bolts show signs of damage from the decontaminaticn.
There are few, if any, details on the post decontar. nation inspection procecures and criteria. There are no stated contingency plans to deal with any other potential problems at the reactor curing or af ter the decontamination.
Given the danger from the chelated forms of radiation in terms of human expcsure as well as incorporation into the food chain the NRC should have paid more attention to precautions, plans and criteria in case of an accident.
i
12-iNFfEMC7 SHUT THE REACTOR DOWN PERMANENTLY The alternative of shutting the reactor down permanently is given short i
shrift.
Three short paragraphs are d :ted to the topic and no "Jetail or supporting data are given. The conclusion that $300 million could be saved over 15 years is unsupported. A 60% " availability factor" is as-sumed and yet a capacity factor is required to determine the accuracy of the $300 million. No cost per kilowatthour (kwh) for the replacement power nor for Dresden 1 to operate for the next 15 years are given, elim-f insting the possibility of auditing the $300 million. The analysis is i
thus made up of conclusory statements and violates section 102(2)(C)(iii) of NEPA as well as CEQ regulatinn,10 CFR 1502.14 Even without the supporting data, a $100.000 per day replacement cost is unduly high. Althougn $100,000 per day may fai. ly represent the cost of purchasing the replacement power from other utilities, it is not a real-istic figure. For exaaiple, during periods where there is little or no
-seasonal demand above the base load, such as spring or fall, CECO could very well replace Dresden 1 sith its own base load generating plants.3 Adding to the unreality of the 3100,000 per day figure is the fact that
- 3.. Excluding. Oresden 1. Ceco owns over 12,000 megawatts of coal or nu-clear plants.
(Annual Report of CECO for the year 1979 to the Illi-nois Commerce Commission (ICC)) CECO's estimated base load for 1978 j
was 8,727 megawatts (see Exhibit VI-3-b in the rebuttal testimony of j
G.F. Rifakes submitted by CECO in ICC Docket.4 79-0214.) Even.if the the base load grows at 43 a year, CECO will own an ample enough margin to use its own base load plants to replace Dresden 1 for much of the
. year, and in a few years new base load plants will be on line.
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CECO does not plan to return'Dresden 1 to service until June, 1986.
(CECO's Load and Capacity Statement, May 28,1980) At $100,000/ day, this amounts to approximately $219 :nillion. ($100,000/ day X 365 X 6 years)
It is therefore apparent that neither the $100,000 per day nor the
$300 million. for 15 years are meaningful figures.
The ultimate comparison of $300 million with the decontamination cost of $39.5 million is misleading and improper.
To begin with $300 million is not properly comparable to the estimated $39.5 million cost of decon-tamination bi:ause the $39.5 million does not include the additional cost of generating electricity at Dresden 1 for the 15 year period. To properly compare the $300 million to the cost of decontamination, the i
cost of operating Dresden 1 for the 15 year period must be added to the
$39.5 million.
According to CECO's Annual Report to :he ICC for 1979, the cost of running the Dresden station was 3.47 mills /kwh.
Assuming a 45.; capacity factor, the daily operating cost of Dresden 1 would be approxima tely 513,300.
(200 megawatts X.45 X.00347 X 24) Over the 15 year period (actually only 9 years of operation, considering the 600 availability. factor) this would amount to about 560.1 million.
Add this to the $39.5 million, and $99.6 million is the proper starting point _ of comparison.
4.
This figure does not actually include Dresden 1 because it did not operate in 1979. However, it is unlikely the oldest, smallest plant of the three would decrease this average cost.
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As has been noted, the.5300 million is unduly high since CECO could replace much of the electricity from Dresden 1 with its own base load, thus narrowing the gap between $99.o million and $300 million even more.
Moreover, it is pro')ble the a 60: capacity factor was assumed in arri-ving at the $300 million calculation.
If this is the case, then the t
l capacity factor assumption is significantly erroneous and hence biases f.
the $100,000/ day figure upward.
For Dresden l's actual capacity factor
' s around 45", cumulative.6 The actual experience, a 453 capacity fac-i tor, would substantially reduce the $300 million replacement cost, 4
thus narrowing the differential even more.
4 5.
This is quite likely since a 200.,.egawatt plant with a 60; capacity factor would require 2,E30.000 kilowatthours of replacement power each day.
CECO currently purchases economy pcwor at the suggested price of 3.5: ;nn- (wh. (CECO Exhibit 2.003, accond revision, suo-
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nitted with R. Heumann's testimony in ICC Docket 579-0214.)
$100,000/ day with a 603 capacity f actor at a 200 megawatt plant t
means the purchased power costs between 3.4c-and 3.5c per kwh.
6.
See NUREG-061a, Nuclear Power Plant Operating Experience 1978-where the 1973 Dresden 1 capacity factor was 44' and operations were considered routine during the year. (p. B-80) 2 See also, NUREG 0200, Operating Units Status Report, Marcn 1930, 4
where Dresden 'I's cumulative lifetime capacity factor (DER Net) is 45.43. (p. D-5) 7.
The purchased power replacement cost would then be about $73,900 a-day, or-about $242.8 mi' lion for the 15 year period.
This is still an. inflated figure because it fails to account for Ceco's own. generating capabilities.
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.Hence the comparison of $300 million to $39.5 million is a meaningless i
exercise. The incorrect, implicit capacity factor, the assumption of only purchased power at he replacement power and the failure to account for Dresden l's operating cost thus totally invalidate the analysis which eliminates the alternative of shutting the reactor down.
From our analysis the cost differential between shutting the reactor down i
and decontamination plus resumed operation is not so significant as to outweigh the risk of environmental degradation from the entire project.
Therefore, we believe NRC must perform a more thorough and supportable analysis before this alternative can be honestly discarded.
REQUEST KR_A FROG _RAlqMTIC_EJS, f
CECO's proposed decontamination of Dresden I will ce the first, large-scale commercial reactor system decontamination in the United States.8 9
This decontamination experiment is expected to provide experience and t
i 8.
See letter of Harold Denton to Mrs. David Deutsch, dated September 14,197P in which Mr. Denton calls the Dresden 1 decontaminatiGn
...the first full-scale application of Dow Chemical's solvent f45-1
- for the decontamination action of a complete primary coolant system."
-(at p. 2) i
- 9. - See letter from Ruth C. Clusen, Assistant Secretary for Environment, Department of Energy, to Mrs. Leo A. Drey, dated August 2,1979, in which Ms. Clusen states: "Thus, no NRC license was issued specifi-
. cally for the decontamination experiment."
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10 background for future decontaminations at other nuclear reactors unJer NRC' regulation.
The NRC should not consider the Dresden 1 decontamination in a vacuum.
Instead, it must assess the environmental impact of subsequent decen-taminations.
The waste generated during the Dresden decontamination may not present a significant transportation or disposal problem, assu-ming our other concerns are not realized. Nonetheless, the decontami-nation of 20 or more reactors may change the dimension of the problem.
Hence the scope of this EIS is too narrow.
Under CEQ regulations im-pl_...enting HEPA, connected actions which are closely related must be discussed in the same impact statement. 40 CFR 1503.25(a)(1). Cumula-tive and similar actions, as well, cerit a programmatic approach under the CEQ's regulations. 20 CFR 1503.25(2) and (3).
The.vaste it:el' will obviously be accumulated af ter several decontaminatiens.
CBE, therc
- ore, formally requests that a programmatic EIS be written re-lating to future chemical decontaminations of co1=ercial nuclear reactors.
10.
The NRC in a response, dated May 21, 1979, to questions from the Illinois Attorney General's office, (at p. 6) stated: "However, it is very likely~ that the Dresden decontamination program will provide valuable confirmatory experience and background in large i
scale reactor system. decontamination that.will be useful in any Three Mile Island decontamination." See also, a letter to Mrs.
Kay Drey, dated November 21, 1977, from Paul Pettit, Division of Nuclear Power Development, Department of Energy, in which he states: "The Commonwealth Edison Company is under contract to the Department of Energy to develop, demonstrate and document methods to chemically clean reactor equipment in nuclear power
.-plants." sat p. 1)
(emphasis added.)
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- 15. supplementary Notes
- 16. Abetracts This recort docu ents the results o' I survey of 01eratino nuclear stations j to cetemine the extent and seriousness of radicactivity buildun in nuclear olants; to access tne value of the available data case for extracolatino observations to lonner coeratino times; to define corrective antiens and associated R'D nronra s; and to de fine additional in'or-ation qatherinn nronev's wnere needed.
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- 19. 5cc arit y U.s s (This
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- 10. A esilao. hey 5 asement 8
Repoeti CNrL* "!F'FO 1ELEASE tmLI"ITE0
- n. s u,i.,.... n o n.
l Pw a n r o om...... a s,.. s... t.swma e, aw me.u t.e.s o.
isi>ronu av nr.dr.rwoutc;u e r - o--. s c. a s s. - >.
1 y-
)
h pagn 2 of 8
/ : t h.:...,
!/
ag Oreseen i Cescrioticn Drescon I (01) is a cuai cycle Se rated at 700 w t anc 2:0 We (200 r've net).
The core centains 464 taei elemen ts, eacn ccro: sed of !6 2i r:31ov-_2 clad fuel rods in a 6x6 array. $ *eam generated i n the s 'ai a r ass s *aal cf M proon s_?e_l_
e is deIisered as 3 steam--ater mix ture !a ine primary steam drum pressure vesseI 6
.here separation cccurs.
rimarf steam t icw is Soproximately 1.5x10 lbs/h at o
1000 psis. Seconda y steam is arCduced i n f cur s ta i n 'ess s teel tucec itsam gen-n.a.to.rs at 500 psig. Peactor.arer cleanup at sporeximately 270 gpm is handiec by a system ConJISting of 4 Fegverati ve and I non-regenerati ve s tain less s'e6I U;ac heat excnangers and 2.deea ted cemi ne ra t i :ers. Full ftcw ( ev 3000 ;pm)
,densate treatment is handlec in the primir/ system by 2 cee: bed demineral-7ne 2 Icw c esssure Primary fec ;.a rer i s ret ;rned to the s team cru n.
2p.
and t hi,n eroe v e ta %, tor o.arars in the ;rimarf sys tem'3r0 tuced w i th 70 ~0 ' # ?-
(
c:coer-air'<ai andyeael, respecti ve l y.
Pri. mary sys tem ci pi ng i s s tain less steel.
3 The ccncenser, criginal.y
- abed.i th Acmi ral ty, was ra ucec with stainless itsel N m ?n '.5,>up.IS3h If*
. d :q7.u i},. a i )
I*
{
g., J[ 1 3
- te suremer.? 'r cram Or i mary Cen t a i nman ? Ladia* ion sevel
- a
)
u...,.
b
..-f.
f 3
I n mi d-19 74, a snutccan radiation level review.c3 ;ertermed cy Ccmmonweal th Edison personne6. The f oi lewing is an excerp t f r:m tr. it s tudy.
"A.
01 "A" and "C" secencary 3 teen Cenera ta 3 to f es 3,,,,,,,,
V, Ccse r ate bui i ;-aa sar,eys.ere perter +ed :n co-n "A" anc "C" 3ecencary Steam Cener s ce Rece.s curing major cu 2ges tecm 1960-1966.
s J
(
Acproximateif se.en sets et acse rate measurements. ore corained ar each at 36 s?eCi'ied IcC.3?ic'3 in these rccms.
j u rvey -3
- rCat Nov and Cec !)73.ere re.iewea ter measuremen ts a t
.ese so e locatters in crcer to extond inis otucy to the present. Represan tati ve resulis were
\\
ncema li.:ec to the Ncv 1060 data and are presentec in Figure i8.l.
- t /I 7)
,4 Al2. E33 1.et te r 4 46 7-71 to F.
- '. calmer,
- P.
craen, W.
I. Ki e 03S ; /
I it. A. P3vli;k, July 12, 19 74 I
!$.i i
e.
page 3 of 3 includec in inis program. Avai lat te Jcse rates it survey poin ts in s team generater roce.s B, C & D are gi ven in 7ab le 18. 3.
Water Chemistre t
General: Ouring ncrma t operation, reactor.arer pH and ccncuctivi ty f alls ai tnin 5.5 to 3.5 and 5 0.5 pr.r.cs/cm, respecti vel y.
4 The average sclue le ni cke t concantratir.ns tren in63-1963 (1.1-4.5 EFPY) in the condensare dam _inor3 p er e.fh % and f q'*4aater aere 6 ppb and 20 p::o,
respect.svely. 13 As a result of ccrresicn of the vonei,nd -^arer-nickel m
feedaater hos'a-5, inis_ nickel. input to the reactor,
~00 t es/y, is at leas t an ceder c f magni tude grea ter fnan tha t at current generation SWRs wi th s'ain less s teel f eec4a te r he i te rs. As such, it is cupectec to s trcngly inf luence corr:sien produc t cescsi t on the sel an: to teac to f orcer Mian
' g ana g ] predoction.
averare rates cf Corrosien P cjuct Paci ecnemi s t ev :
Av ai t a 'e rarm (sciu ;e 2nd i ns o s..e l o )
- 3:s Id.4,Al
,A l5 raccrgr.a te r i scrcpi c cara are gi von in a
g;c, c_nc,,,73_
t i ens
- n.. y.,.: _. n,1 ? -M are inci cari se o f w g er anc ti g i inout, p
respectieely recm the feedaaier t eaters.
Raciochemical analysis of a nickel-iren sninel ceposit, found in the st<'in-tess clean-up piping gyrinq q q9cpntamir3;ien of tne clean-up ! cop, indicated 10% due to Cs-134 anc Cs-137. l6 A
1 tha t the major activi ty was Co-60 wi th aoout f
4,;. a tm <
- 2. y ars 3a7 L,U'"
i
\\
1 Al3.
A. B. Sissen, " Water Chemistry at Drescen fluclear ?c er Station",
j P3per aclished at the Houston flational Associaticn of Corr 0sion Engin-aers Meeting, Apri l 1969.
Af4 J. M. Saarpe los anc R. S. Gi lbert, "Techn':al :erivation of EWR 1971 Cesi gn Basi s Radi cacti.e *-tateri a l Source Terms", l4ECC-l0871, General Elec tri c Company, March 1973.
- Ars, B. Kann,er al., "Radioicgical Surveillanca Studies at a Colling Water
'hac t e ar P:aer Peactor", U. S. Departmen t of Heal th, Education, and
.5e i tare, Pub l ; c -ea l th Sersice, 1969.
SID.
J.
J.3 cot ?,
Pe t va *e CCergn I CaTtQn, J ta rA
'3 I5.
18.0
--e.-
page 4 of 8 TABLE 18.1
[
CRESCE;l 1 "-ECONCA23 STE NGE'4E3A~#P PADI AT:CN I
SL. 'eY !N CC705ER-DECE8E9 1973 t.
t 3
( ~ 7. I IFPY )
4 5 :e y. ~.y e e v n e t-nts av 2")
L
]
A 3
C 0
Tescric tien/Ler.ation of S'eesurement L'
22 3C0 1600 300 1.
riandnote cover (rignt)
(
!!3 00 0 3C0 100 I
2.
Hanchole cover (lef;}
{
3900 3500 2500- %00 3000 l
3.
Ecttori drain (rignt) 1 20C0 3500 2500-3000 15C0 4
Scrtca drain (left) 12CC 3C0 1300 2000
/
5.
Primary sice vent tr:gn )
6.
Primary si ca ven t (6ett:
16C0 550 11C0 3000 t
7 Tc ler t et crima y sice.en*,
1" gi;:e
- R
- NR*
NR*
500 wooec etf (seconcarv sice crain) 20 250 SCO 600 8.
Pump tco of <ent
..R '
150 300 300 9.
valve to rignt et pump too at vent SCO NR*
650 400
. iO. Cecon fIange NR' NR*
NR*
600 I
11 Suction sice, cecon ftengo l
NR*
1200 NR*
NR*
12.
Primary leac crain 1ine NR' E00 NR*
NR*
13.
Secondary sice drain I
L l
Ik 1
- NR - not Repor+ed a
P
< l 1
i
tiuclide
.x.k' Cr-51 500
.v '
500
'?
4
- .tn-5 4 Tid. *
. '.1 *
- g
.S, Fe-59 50
- R*
nR+
..a v.
I 7CO i<
< - 58 5000 -
- 2000
~:
to-60 500
- C0 260
('j
/.f, #
..q l 4 -- Cu-6 4 6CC00.
iC;00 2:00
- '.8
.s :
tii-65 300
.a
- NR+
.t..
Zr.-65 2
.u + +
4
, ;o Cs-134
'R*
23 h
e.
e 6
e..
- *$ - N0 ' 000Cr'e:
- *NM
.;o 7 '.'eas ;re a i
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l
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4 l
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