ML030770819

Wdoh Comments on Draft Safety Analyses Related to Potential Disposal of Two Spent Fuel Rods at a Low-Level Radioactive Waste Facility

ML030770819
Person / Time
Site:	Millstone
Issue date:	02/25/2003
From:	Robertson G State of WA, Dept of Health, Div of Radiation Protection
To:	Chris Mckenney NRC/NMSS/DWM
McKenney C (415-6663)
Shared Package
ML030770830	List: ML030770812 ML030770814 ML030770819 ML030770824
References
Download: ML030770819 (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 25 February 2003 Christepher McKenney System Performance Analyst Environmental and Performance Assessment Branch Office of Nuclear Material Safety and Safeguards Mail Stop T-7J8 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

Dear Mr. McKenney:

This letter is in response to the Nuclear Regulatory Commission's (NRC) request for comments on its Safety Analysis Report (SAR) concerning Long-Term Hazard of Millstone Unit 1 's Missing Spent Fuel Rods Potentially Disposedat the Hanford Commercial Low-Level Radioactive Waste DisposalFacility. This report was published in the January 6, 2003 Federal Register (Volume 68, Number 3, page 588-589).

The SAR states that the rods may have been unintentionally disposed of at the Hanford, Washington commercial low-level radioactive waste (LLRW) disposal facility, but most likely were inadvertently shipped to the Barnwell LLRW site. The NRC's SAR concluded that if the rods were shipped to Hanford, they would not constitute a present or future risk to the public health and safety of the environment.

The Washington State Department of Health staff have considered the source term of the Millstone fuel rods in its dose assessment portion of the Environmental Impact Statement (EIS) being prepared for the US Ecology facility, and have determined that the fuel rods present negligible additional risk. However, we cannot concur with the NRC's conclusions until the Final Environmental Impact Statement is completed and the public has an opportunity to comment. The Final EIS is estimated to be completed by mid-2003.

The department also has the following comments regarding the SAR:

The statement on page 3 "This includes some other spent fuel that was legally disposed in Hanford during the 1970's" should be clarified. It should be made clear that any fuel waste legally disposed during the 1970's was accepted and authorized under the U.S. Nuclear Regulatory Commission's Special Nuclear Materials license. Although the source term tIsý

Christepher McKenney Page 2 of 2 February 25, 2003 from these wastes were included in the state of Washington's dose assessment for the EIS that is being prepared for the facility, it is requested that all fuel waste disposed at the facility under the U.S. NRC license be accounted for and quantified.

On page 3, the EIS source term for Tc-99 is 50 Ci, rather than 60 Ci.

We would like assurance that the presence of both the legally disposed fuel waste and the potential disposal of the Millstone fuel rods at the Hanford facility will not affect the transfer of the facility to the federal government custodian (US DOE) after site closure.

If you have any questions, please feel free to contact me at (360) 236-3210.

Sincerely, Gary Rcbfrtson, Director Divisio6f Radiation Protection cc: Lilia Lopez, Assistant Attorney General Radiation Protection, Richland Larry Goldstein, Department of Ecology Mike Garner, Department of Ecology