ML20114C923

Comment on Proposed Concentration Averaging & Encapsulation Technical Position

ML20114C923
Person / Time
Site:	Fermi
Issue date:	08/26/1992
From:	Gipson D DETROIT EDISON CO.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
CON-NRC-92-0088, CON-NRC-92-88, FRN-57FR29105, REF-WM-3 57FR29105, NUDOCS 9209040017
Download: ML20114C923 (2)

Text

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August P6, 1992 NRC-92-0088 U. S. Nuclear Regulatory Commission d 5 Hr. Samuel J. Chilk, Secretary Washington, D.C. 20555 g  ;'vi a

e Attention: Docketing and Service Branch M TI '

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Reference:

Ferad 2 7 0 NRC Docket No. 50-3111 NRC 1.fcense No. NPF-43 3Cj cn

Subject:

Detroit Edison Comments on the huclear Hegulatory Commission's " Proposed !'oncentration. Averaging and Encapsulation Technical Position, Revision in Part" Detroit Edison is participating in the industry's review of this-

, proposed Branch Technical Position through the Edison Electrio Institute / Utility Nuclear Waste and Transportation Program. In '

addition, Detroit Edison wishes to present additional comments, as discussed below.

Detroit' Edison is conducting a fuel pool cleanup campaign at. Its Feral 2 nuclear _ power plant. As part of this campaign, control rod blades and neutron monitors which had been removed from the core were packaged in liners for shipment to a'Icw level radwaste disposal facility. Since no such facilities are presently open to Michigan radwaste~ generators, these liners are being stored in the Fermi 2 spent fuel pool. .'

Under accepted nractices at the time of pachaging, which allow averaging of activity over the total waste volume, each of these l . liners is acceptable as Class C wasto.. Under the proposed BTP,.

-however, one of these liners may be considered as greater than Class C ,

i du'e to the presence of neutron sonitors. Although-these monitors comprise less than 45 of the total volume, some of them say be greater li than Class C. Under the proposed BTP, the entire liner must be considered as greater than Class C.

Since the liner may-not be acceptable -for disposal'as packaged and the repackaging of this liner would create significant and unnecessary E

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personnel exposures, it may require long-:,ers storage in the spent fuel pool. This would occupy space that will be needed for spent fuel storage.

9209040017 920826 L PDR- PR:

! -MISC 57FR29105.PDR L

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4 Hr. Samuel J. Chi)k August 26, 1992 NHC.92-0088 Page 2 O

Detroit 10 Edison thus requests that, as a ainlaus, if the proposed BTP issued, a " grandfather" provision be included to allow previously packaged radwaste to be classified in accordance with accepted practices at the time of packaging.

If you have any questions concerning our comments, please contact Joseph Penderast at (313) 586-1682.

Sincerely, pr.f b/

cc: T. G. Colburn  !

i A. B. Davis H. P. Phillips S. Stasek Hegion !!!

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