ML20137Z551

Expresses Disappointment W/Performance of W Lanning & J Durr at Public Meeting on 961217.Public Led to Believe That NRC Committed to Provide Plant Specific Analysis Re Risk of Loss of Inventory of SFP Water at Plant

ML20137Z551
Person / Time
Site:	Millstone
Issue date:	01/03/1997
From:	Blanch P AFFILIATION NOT ASSIGNED
To:	Zwolinski J NRC (Affiliation Not Assigned)
Shared Package
ML20137Z548	List: ML20137Z551 ML20137Z557
References
RTR-NUREG-1353 NUDOCS 9704250020
Download: ML20137Z551 (2)

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PaulM. Blanch Energy Consultant i

I/3/97 l

l John A.Zwolinski, Deputy Director Division of Reactor Projects -I/II I

Office of Nuclear Reactor Regulation l

Washington DC 20555-0001

DearJohn:

I can't begin to tell you how disappointed I was with the performance of Wayne Lanning and Jacque Durr at the public NRC meetin g on December 17,1996. They still treat the i

general public as thoup it reports to the h RC and the NRC is never wrong.

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During a NRC public meetin earlier this year, the public was led to believe that the NRC j

had committed to provide a ant specific analysis related to the risk of a loss ofinventory l

ofspent fuelpool waterat Millstone plants.

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At subsequent NRC meeting, Mr. Wayne Ianning publicly stated that the consequences of refused to provide anything in writing, statmg it would be a wa

bowever, i

i Mr. Lanning is billing his time at the rate of $250,000 per year to us, we have the right to i

demand truthful and accurate answers. The public will decide what information we want and not have the NRC decide what we should know and not know. He is well aware i

fact that the consequences of a loss of spent fuel pool inventory are many times greater than what he publicl j

to the public. y stated. I believe Mr. Lanning is knowingly making inaccurate statement I

Not only does this previous analysis only assume one third of the core is offloaded, but i

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fails to consider the accident occurs during refueling, the most likely time this event would occur. This would result in the consequences of this high probability accident being j

possibly orders of magnitude greater than previously assumed.

Mr. Lanning on December 17,1996 again repeated the NRC's position and that is there is i

no need to redo the analysis even though the probabilities and consequences of this accident

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haveincreased significantly.

i What Mr. imaning failed to mention to the public is that the sole purpose of the study was i

to evaluate the cost effectiveness of spent fuel pool modifications based on the risk to the public. If the risk is now 100 times that previously assumed, then some type of i

modifications may be costjustified. Further, the study did not consider the ation i

density at Millstone but assumed an ave.tege density within the United States.

additional information is that now the NRC admits the probability of the loss ofinventory I

of greater than one foot is about 1 in 100 reactor years. While this does not quantify th i

probability of a total loss ofinventory, I am sure this probability is orders of magmtude j

.sigher than alarge break LOCA.

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9704250020 970415 PDR ADOCK 05000245 G

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On August 21,1995, Mr. Ernest Hadley submitted a 2.206 petition requesting a detaile independent analysis of offsite dose consequences of the total loss of spent fuel poo In the NRC response to the petition dated December 26,1996 it stated: "Ihe NRC's actions to date in evaluating SFP accidents.. constitute a partial grant of the Petitioners' req perform analysis of such events." Again, the NRC has refused to provide accurate and lete infonnation to the general public related to the potential risks of spent fuel

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nts. Please direct me to an NRC hm=nt that quantifies the probabdity and be l

consequences of a loss of spent pool inventory for the Millstone plants.

I John, the public has the right to know the true risk ofliving near these plants. It is our live L

and our families placed in the paths of these plants and for the NRC to tell us we have no i

right to this information is irresponsible. For Mr. Ianning to falsely state the risk is now three times greater than previously thought, is totally inesponsible, intentionally m i

and inconsistent with the mission of the NRC.

l Mr. Durr added that this accident was "outside the design basis" due to its low proba j

of occurrence however has no basis for this subjective statement. Based on a recent NRC document (AEOD/S96-02), the probability of this accident occurring is many times that of a j

large break LOCA and must be considered in the design basis.

1 If what Mr. Durr stated is correct, then Millstone has and will continue to operate outside i

its design basis and this must be reported under 50.72(b)(ii)(A)&(B). Please explain w the NRC has failed to require reporting this, where by its own admission, the plant is operating "In an unanalyzed condition that significantly compromises plant safety;" and "In j

a condition that is outside the design basis of the plant;"

i I formally request the NRC respond to these concems and those addressed in my letter i

dated February 28,1995 (copy enclosed)in a timely manner.

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Sincerely, i

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Paul M. Blanch i

135 Hyde Rd.

West Hartford CT. 06117 j

860-236-0326 l

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Febmary 28,1995 John A.Zwolinski, Deputy Director Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation Washington DC 20555 0001 Subjectr Mr. Joseph Shea letter to Paul Blanch dated January 19,1995

DearMr.Zwolinski:

On January 26,1995 I requested the following information:

"Section 5.2 ofthe drqft sqfety evaluation states dose to the population would be 8 x 10e8personrem assuming the accident occurred 90 days after shutdown. Given this non-conservative assumption, please provide emosure informationfor my review assuming the event occurs dering refueling.1 wouldlike the dose rate (onsite and ofsite)from direct and indirect shinefrom the emosedfueland also the calculated site boundary doses and dose rates due to the release ofshort and long lived radioisotopes. It should be assumed that the reactor is near the end ofits 40 year hfe and afull core ofload is in the spentfuelpool. Ialso request that these calculations receive inde conducted by utilities. " pendent ven'tication similar to design enini"%s Given this ex psure data from the SER and the potential releases from the spent fuel pool I am concernet about the long term effects of this postulated accident and would like to clarify my previous request. Please provide a response to the following questions.

1.

With this event, (uncovery of the spent fuel)is the ficaaaa stillin compliance with 10 CFR Part 100 limits. This must be considered a credible event as discussed in Part 1 Further, there have been at least three precursors to this event over the past ten years and twoin the past 13 months.

2.

What is the maximum dose and dose rate to an individual residing at the site boundary assuming no evacuation?

3.

What is the maximum dose and dose rate on the site?

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NUREG-1353 estimates this event results in property damage in excess of $20 Billion. A=aming a 50 mile radius, this equates to about $20,000 per acre. While this may reflect an approximme value of the land, does it include homes, baaia*=== and other personal rty? Is this a realistic assumption for an area such as that sunounding Indian Point or am Neck and are these sites bounded by the results of this NUREG7 5.

For a plant such as Indian Point or Haddam Neck, has the ~

upon the local rivers and water suppbes for downstream population been eaa=i in these propeny damage cale=1=+inaP/

6.

Does the $20 Billion assume the N6y is uninhabitable for a finite period of time or does this assume the property is permanently abandoned? The property damage from hurricane Andrew was about $30 Billion and was a much smaller and less populated area and did not result in the abandonment of the land.

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What is the total area effected by this event and how long is this property 4

contaminated before it can be returned to unrestricted use? A plot of contammated land a vs. time would be helpful to explain the potential impact of this event. This plot would i

show the rate at which cantammated land is returned for unrestricted use.

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Your prompt response will be appreciated.

Sincerely, Paul M. Blanch 135 Hyde Rd.

j West Hartford CT. 06117 i.

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From:

PAUL M. BLANCH <PMBLANCH@ix.netcom.com>

To:

JZ <JAZWOL@aol.com>

Date:

11/10/96 3:06am

Subject:

2.206 Response John:

Could you please explain why it takes more than two and a half years to get a response to a public petition whereas a request for a license ammendment is processed in a matter of months.

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 6,1996 Mr. Paul M. Blanch 135 Hyde Road West Hartford, CT 06117

Dear Mr. Blanch:

This letter responds to your Petition of April 13,1994, in which you requested that the NRC take action with all power reactor Acensees regarding the potential for failure of spent fuel stored in spent fuel pools. This Petition was filed pursuant to 10 CFR 2.206 of the U.S. Nuclear Regulatory Commission's (NRC's) regulations. You asked the NRC to (1) immediately issue an information notice or other appropnate notification forwarding all information in its possession to all power reactorlicensees

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regarding the potential failure of fuelin spent fuel pools, and reminding licensees of their responsibilities to perform timely N

operability determinations in accordance with their technical specifications and NRC Generic Letter 91-18; (2) direct each licensee N

to immediately perform an evaluation of this potential deficiency to determine compliance with its current licensing basis; (3) deny all requests for iscense amendments for the expansion of spent fuel pool capacity until these safety concems are fury resolved; and (4) after evaluation by each licensee, if the NRC determines there is little or no risk to public health and safety, the NRC may issue a Notice of Enforcement Discretion (NOED), which represents a determination by the NRC not to enforce an applicable w

technical spoofication orlicense corxistaon.

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Endosures: 1. Final Drector's Deasion (DD-96-18)

2. FederalRegisterNobce ccw/ ends: see next page 1

4 Paul M. Blanch Energy Consultant i

135 Hyde Rd.

West Hartford CT 06117 Voice 860-236-0326 Fax 800232-9350 1

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