ML20136C658
| ML20136C658 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 01/13/1997 |
| From: | Blanch P AFFILIATION NOT ASSIGNED |
| To: | Zwolinski J NRC (Affiliation Not Assigned) |
| Shared Package | |
| ML20136C110 | List:
|
| References | |
| 2.206, NUDOCS 9703120146 | |
| Download: ML20136C658 (3) | |
Text
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From:
PAUL BLANCH <PMBLANCH91x.netcom.com>
To:
JZ <JAZWOL9aol.com>
-Date:
1/13/97 5:27am
Subject:
Comments on 2.206
. John Zwolinski:
A hard copy of this letter is being sent to Mr. Collins today. I - thought you may be interested in one of the =B3 sign off-B2 comments.
Subject:
Re: 2.206 Response l
Sent:
1/13/97 8:18 AM Received:
1/13/97 9:10 AM From:
[ REDACTED]
To:
PAUL BLANCH, uunet!IX.NETCOM.COMIPMBLANCH9uunet.uu. net Paul:
No comments on your draft letter.
It raises great points that - go to the heart of the issues.
Regarding your request for NRC's analysis showing that the - offload practices had low safety significance, I'm betting that they are confusing low probability with low risk again. The recent AE00 - stuff shows that NRC underestimated the frequency of such events. As - you point out in your letter, Mr. Lanning concedes that NRC - underestimated the consequences from such events.
Traditionally, risk is - defined:
RISK -3D PROBABILITY X CONSEQUENCES l
I believe that the NRC's definition of risk may actually be:
RISK -3D PROBABILITY X CONSEQUENCES X CARE FACTOR In the case of spent. fuel pools, the NRC adopted Rhett Butler's attitude, they quite frankly don-B9t' give a damn -- therefore, - the
- risk, in their view, is zero.
In reality, a spent fuel pool accident - will release tremendous quantities of radionuclides into the air, and - they will be "Gone With the Wind."
i l
1/13/97 l
l Mr. Samuel J. Collins, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
COMMENT ON NRC RESPONSE TO 10 CFR 2.206 PETITION ON -
, 40'M n3 s
9703120146 970306 PDR ORG NRRA PDR
9 MILLSTONE..... UNIT 1 REFUELING PRACTICES
Dear Mr. Collins:
~
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a By letter dated December 26, 1996, Mr. Frank Miraglia, Jr. = transmitted the
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NRC's response to the petition dated August ~21, 1995, =~ submitted by Mr.
i Ernest C. Hadley on behalf of Mr. George Galatis and =
We the People, Inc. pursuant to Section 2.206 of Title 10 of the Code - of Federal Regulations. The petitioners contended, among other - things, that refueling practices.at Northeast Utilities' Millstone.
l Unit I facility were not being conducted in accordance within the - plant-89s 4
design and licensing bases.
I-The petition requested the Licensee /NRC -B3 perform a detailed - independent analysis of the offsite dose consequences of the total - loss of spent fuel i
pool water.-B2 The response stated -B3The.NRC-B9s - actions to'date...
constitute a partial grant of the -
7 Petitioners-B9 request to perform analysis of such accidents.-B2 All of these referenced documents are either not applicable to -
Millstone, are no longer generically applicable, fail or - underestimate t
property damage and exposure to the public, or did.not - consider the specific design and inoperability of safety systems at -
Millstone at the time of the full core offloads. Mr. Wayne Lanning of = the NRC staff publicly acknowledged that the population doses - predicted by i
NUREG 1353 are significantly enderestimated and are more - than 3 times greater than previously analyzed. Again, in response to - numerous public requests and in response to the 2.206 petition, - please provide this 1-information as previously promised by the NRC =
Staff.
Footnote 5 of the petition response states the -83... safety - significance of these offloads was low...-B2 Please provide me = with a copy of the NRC-89s safety analysis that substantiates this = conclusion. Please indicate i
how the inoperability of the SBGTS and - other systems found to be non-seismic j
and inoperable were factored - into this assessment. Also, how was that the i
fuel was removed from - the reactor commencing at less than 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> from the time of = shutdown factored into this NRC analysis? This request is being made = under the provisions of the Freedom Information of Act.
I await your prompt response.
Sincerely, Paul M. Blanch 135 Hyde Rd. West Hartford CT 06117 860-236-0326 cc:
Chairman Shirley Ann Jackson United States Nuclear Regulatory Commission Washington, DC 20553 Mr. George Mulley Assistant Inspector General United States Nuclear Regulatory Commission 3
l 1, -
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[
i Washington, DC 20555 Ernest Hadley
- Paul M. Blanch Energy Consultant
' 135 Hyde Rd.
West Hartford CT 06117 Tel: 860-236-0326 Fax: 860-232-9350 l
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