ML022480326

Safety Evaluation Report Concerning Missing Spent Fuel Rods

ML022480326
Person / Time
Site:	Millstone
Issue date:	08/23/2002
From:	Robertson G State of WA, Dept of Health, Div of Radiation Protection
To:	Chris Mckenney NRC/NMSS/DWM
References
Download: ML022480326 (2)

Text

STATE OF WASHINGTON DEPARTMENT OF HEALTH DIVISION OF RADIATION PROTECTION 7171 Cleanwater Lane, Bldg. 5

• P.O. Bov 47827 # Olympia, Washington 98504-7827 TDD Relay 1-800-833-6388 August 23, 2002 Chris McKenney Environmental & Performance Assessment Branch

-Division of Waste Management Mail Stop 7J8 U.S. Nuclear Regulatory Commission Washington, DC 20555 RE: SAFETY EVALUATION REPORT CONCERNING MILLSTONE UNIT V'S MISSING SPENT FUEL RODS

Dear Mr:

McKenney:  : *-  :.' ."

This letter is in responsý to !he Nuclear Regulator-y' Cormins'sion's"(NRC) request foi comments on its Safety Evaluation Report'(SER) concerninig "Lofig-terrhHHazard of Mils tone Unit I's Missing Spent Fuel Rods Potentially Disposed at the Hanford Commercial Low-Level Radioactive Waste Disposal Facility."

The SER stated that the'investigative team formed by the licensee concliid&1 that the rods might have been unintentionally disposed of at the Hanford, Washington commniercial low-level radioactive waste (LLRW) disposal facility, but most likely were inadhently shipped to the Bamwell LLRW site. The NRC's SER concluded that if the rods were shipped to Hanford, they would not constitute a present or future risk to the public health and safety or to-the environment.----

Washington State Department of Health (WDOH) staff has considered the source term of the Millstone fuel rods in its dose assessment, and concurs with the conclusions of the NRC's SER, that the rods do not present a long or short-term hazard to the public or to US Ecology workers.

However, wedo have several comments regarding the SER for consideration, along with a policy concern:

1. In Dominion Nuclear Connecticut, Inc.'s Response to'a Re4ilestjo'rAdditional Information Regarding'SafetyAnalysis of Millstone Unit No.'i-Misiing Fuel Ro'dls' (ML021500428), it whs assumed that intrusion wouldlo6cui" 500 yda'rs after the loss of institutional controls. Following NRC guidance, WDOH always assumes intrusion will ocdur-after the institutional control period has lapsed. The decision to use the upper

, Aeckf-- .*.

Chris McKenney Page 2 of 2 8/23/2002 bound time frame for analysis should be substantiated more directly with the inability of the fuel rods to decompose (and thus be accessible) in less than a 500-year time frame.

2. The SER should include a more detailed discussion of the resilience of the metallic/ceramic waste form, as it relates to the Hanford environment.

3. While the SER provided a satisfactory risk assessment for the short and long-term -" -

scenar-ios, it fdils-tO--discffs-s-thd-~g-iilatr-ty-.ltifis-di~ti6nal-ilssues.ý--

If you have any questions regarding this matter, please contact me at (360) 236-3210, or Mikel Elsen at (360) 236-3241.

Sincerely, Gary WRertson, Director Division of Radiation Protection cc: WDOH, Richland Mike Garner - WDOE