ML20134C629

Transmits NRCs Response to Petition Dated 950821,submitted by EC Hadley on Behalf of G Galatis Per 10CFR2.206

ML20134C629
Person / Time
Site:	Millstone
Issue date:	01/08/1997
From:	Lochbaum D AFFILIATION NOT ASSIGNED
To:	Collins S NRC (Affiliation Not Assigned)
Shared Package
ML20134C601	List: ML20134C598 ML20134C621 ML20134C629
References
2.206, NUDOCS 9702030223
Download: ML20134C629 (3)

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be From: PAUL BLANCH Sent: Wednesday, January 08,1997 9:45 AM To: GLEN MILLS

Subject:

MP-12.206 RESPONSE COMMENTS January 8,1997 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 MILLSTONE UNIT 1 REFUELING PRACTICES

Dear Mr. Collins:

l By letter dated December 26,1996, Mr. Frank Miraglia, Jr. transmitted the NRC's response to the petition dated August 21,1995, submitted by '

Mr. 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 Unit 1 facility were not being conducted in accordance within the plant's design and licensing bases-I reviewed this response and disagree with the NRC staffs conclusion, es stated in Director's Decision 96-23 that "the design of the SFP and r: lated systems at Millstone Unit 1 was adequate to protect public health and safety during full-core offloads." The conclusion is superficial because it relies on an incomplete justification by the NRC staff and cannot be reached using good engineering juogement.

As detailed by the petitioners in the public meeting on April 8,1996, in Waterford, Connecticut, on this petition, the licensee was offloading irradiated fuel during refueling outages before the decay time required by the Millstone Unit i licensing bases. The licensee defended that practice during the public meeting on the basis of the spent fuel pool water never having exceeded Technical Specification limits. The NRC staff, in Director's Decision 96-23, discusses spent fuel pool heat r::moval capability in great detail and concludes that it was sufficient for Millstone Unit 1's refueling practices.

However, the design and licensing bases for decay time have nothing to do with decay heat removal. The decay time is based exclusively on the offsite dose consequences from a postulated fuel handling accident. The radiological analyses for the fuel handling accident assume radionuclide inventories in the dropped irradiated fuel assembly and the irradiated fuel assemblies it strikes based on the event occurring at the minimum decay time. By offloading irradiated fuel assemblies in less than the minimum decay time at Millstone Unit 1, Northeast Utilities invalidated the analytical bases for the fuel handling accident described in Chapter Page 1 9702030223 970129 PDR ADOCK 05000245 P PDR

15 of the Final Safety Analysis Report. The petitioners provided

• information to the NRC staff that irradiated fuel was offloaded on Millstone Unit 1 as early as half of the required decay time. Since radionuclide inventories decrease exponentially with time, halving the decay time could more than double the amount of radioactivity released during a fuel handling accident.

To the best of my knowledge, neither the licensee nor the NRC staff have determined that the 10 CFR 100 limits on radiation dose to the general public would not have been violated had a fuel handling accident occurred at Millstone Unit 1 during irradiated fuel movements before the required decay time. At best, it was an unanalyzed condition that violated the law. At worst, it was an undue risk to the public.

The NRC staff's reasoning is incomplete, and its conclusion potentially inaccurate, because it did not evaluate the consequences from the licensee violating the decay time requirement. The conclusion is  !

accurate only if it can be shown that the offsite dose consequences from a fuel handling accident at Millstone Unit i under the actual decay times would have remained a fraction of the 10 CFR 100 limits. The NRC should require that Northeast Utilities evaluate the offsite dose consequences from fuel handling accidents during the most limiting case (i.e., the earliest that irradiated fuel was offloaded) at Millstone Unit i before reaching a final determination on whether its refueling practices adequately protected public health and safety.

The NRC staff should also determine why it reached a conclusion based on en incomplete evaluation. The petitioner provided the NRC staff with emple documentation on decay time violations. The design and licensing bases for decay time is clearly described in numerous sources, including the Millstone FSAR, the Standard Review Plan, and the Standard Technical Specifications. It is discomforting that the NRC staff, after 16 months of examining the issues raised in the petition, failed to address the safety consequences from this licensee's repeated violations of the decay time requirement over a 20 year period.

Sincerely, David A. Lochbaum Nuclear Safety Engineer cc: Chairman Shirley Ann Jackson United States Nuc'sar Regulatory Commission Washington, DC 20555 Mr. George Mulley Assistant inspector General United States Nuclear Regulatory Commission Washington, DC 20555 Paul M. Blanch Energy Consultant 135 Hyde Rd.

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