ML20136C658

Discusses from P Blanch to Collins Re NRC Response to 10CFR2.206 Petition on Millstone Unit 1 Refueling Practices

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
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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 s n3 9703120146 970306 PDR ORG NRRA PDR

9 MILLSTONE..... UNIT 1 REFUELING PRACTICES

~

Dear Mr. Collins:

i-  !

a By letter dated December 26, 1996, Mr. Frank Miraglia, Jr. = transmitted the l

} 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 l 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 I 860-236-0326 cc: Chairman Shirley Ann Jackson l United States Nuclear Regulatory Commission l 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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