NRC-92-0088, Submits Comments on NRC Proposed Concentration Averaging & Encapsulation Technical Position.Requests That Grandfather Provision Be Included to Allow Previously Packaged Radwaste to Be Classified Per Practices at Time of Packaging
| ML20118A386 | |
| 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 NUDOCS 9209020302 | |
| Download: ML20118A386 (2) | |
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August 26, 1992 NRC-92-0088 U. S. Nuclear Regulatcry Commission Hr. Samuel J. Chilk, Secratary Washington, D.C. 20555 Attention:
Docketing and Service Branch
Reference:
Fermi 2 NHC Docket No. 50-341 NRC License No. NPP-43
Subject:
Detroit. Edison Comments on the Nuclear Regulatory Commission's " Proposed Concentration Averaging and Encapsulatica Technical Position, Revision in Part" Detroll Edison is participating in the industry's review of this proposed Branch Technical Poaltion through the Edison Electric Institute / Utility Nuclear Waste and Transportation Program.
In addition, Detroit Edison wishes to present additional comments, as discussed below.
l Detroit Edison is conducting a fuel pool cleanup campaign at its Fermi 2-nuclear power plant.
As part of this campaign, control rod blades l
and neutron monitors which had been remvved from the core were packaged in liners for shipment to a low revel radwatta disposal facility. Since no such facilities are presently opei. Lo Michigan radwaste generators, these liners are being stored in the Fermi 2 spent fuel pool.
Under accepted practices at the time of packaging, which allow averaging of activity over the total wa:Le volume, each of these liners is acceptable as Class C waste. Under the paoposed BTP, l:
nowever, one of these liners may be considered as greater than Class G l
due to the presence or neutron monitors. Although these monitors comprise. lese t.han 4% of the total volume, nme of them may be greater l
'than Class C.
Under the proposed BTP, the c.itire 11ner 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 personnel exposures, it may require long-term storage in the soent fuel pool. This would occupy space that will be needed for spent fuel storage.
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Hr. Samuel J. Cnilk August 26, 1992 i
NBC-92-0088 Page:2 Detroit Edison thus requests that, as a minimum, if the proposed BTP is issued, a " grandfather" provision be included to allow previously.
packaged radwaste'to'be classified in accordance with accepted practices at the 'ime of packaging.
If you have any questions concerning our comments, please contact.
Joseph Penderast. at (31~,) 586-1682.
Sincerely, 10 cc T.-G. Colburn A. B. Davis.
H. P. Phillips S.
Stasek degion Ill
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