ML031690619

South Carolina'S Department of Health and Environmental Control'S Comments on Draft Safety Analysis Related to Potential Disposal of Two Spent Fuel Rods at a Low-Level Radioactive Waste Facility

ML031690619
Person / Time
Site:	Millstone
Issue date:	06/03/2003
From:	Porter H State of SC, Dept of Health & Environmental Control
To:	Chris Mckenney NRC/NMSS/DWM/EPAB
McKenney C (415-6663)
References
Download: ML031690619 (2)

Text

H E C PROMOT PROTECT PROSPER 2600 Bull Street Columbia, SC 29201-1708 June 3, 2003 COMMISSIONER:

C. Earl Hunter BOARD:

Bradford W.Wyche Christepher McKenney Chairman Systems Performance Analyst (HP)

Mark B. Kent Environmental and Performance Assessment Branch Vice Chairman Division of Waste Management Howard L.Brilliant, MD Office of Nuclear Material Safety and Safeguards Secretary Mail Stop T-7J8 Carl L. Brazell U.S. Nuclear Regulatory Commission Louisiana W.Wright Washington, D.C. 20005-0001 L. Michael Blackmon Re: Conments on the Draft Safety Analysis Long Term Hazard of Millstone Unit Larry R. Chewning, Jr., DMD I's Missing Spent Fuel Rods Potentially Disposed at the Barnwell Commercial Low-Level Radioactive Waste Disposal Facility

Dear Mr. McKenney:

The Department has reviewed the above referenced safety analysis report and provides the following comments:

1. The current decay corrected inventory for the Barnwell site is approximately 103,600 TBq (2.8 million curies).

2. The estimated 17 TBq of activity in the fuel rods does not significantly increase the total activity at the Barnwell site, however the inventories of certain individual radionucides (Pu-239, Pu-240, Pu-241, Am-241, and Am-243) are significantly increased if the fuel rods have been disposed of at Barnwell. We have required that Chem-Nuclear Systems, LLC. (CNS) evaluate the potential long-term impacts of the additional inventories using the recent performance assessment for the Barnwell Site. This assessment was recently provided to the Department and is under review.

3. We agree that the ceramic and activated steel waste forms of the fuel rods will limit the release rate of any radionucides. However, the Department feels that it is important to evaluate whether there is any indication of migration of the radionuclides associated with the fuel rods. The Department has required CNS to sample and analyze monitoring wells that are downgradient of the trenches where the shipments, which may have contained the fuel rods, were disposed.

This included installation of one additional monitoring well. Analytical results SOUTH CAROLINA DEPARTMENT OF HEALTH AND ENVIRONMENTAL CONTROL

from sampling these wells were recently provided to the Department and are under review.

4. The Department agrees that the inadvertent intruder scenario evaluation used as the basis for this part of the safety analysis adequately evaluated the risk to the inadvertent intruder and that any potential doses are well within those considered in the development of 10 CFR Part 61.

5. We recognize that the safety analysis does not address the jurisdictional issued raised by the potential disposal, but hope to continue to work closely with the NRC to resolve these issues.

The Department appreciates the opportunity to provide comments on the report. After we have completed our review of the performance assessment evaluation and the monitoring results we will provide the NRC a summary of the findings. If you have questions regarding these comments, please contact me at (803) 896-4245.

Sincerely, Henry Porter, Assistant Director Division of Waste Management Bureau of Land and Waste Management