ML16341C691
| ML16341C691 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/09/1981 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| NUDOCS 8109240635 | |
| Download: ML16341C691 (14) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 September 9, 1981
'DISCUSSION OF ENVIRONMENTAL-EFFECTS OF THE URANIUM FUEL CYCLE ACTIVITIES ATTRIBUTABLE TO OPERATION OF THE DIABLO CANYON NUCLEAR PLANT, UNIT NO.
1 PACIFIC GAS
& ELECTRIC COMPANY DOCKET NO'0-275 PREPARED BY THE OFFICE OF NUCLEAR REACTOR REGULATION U. S.
NUCLEAR REGULATORY COMMISSION The proposed action is the issuance of Facility Operating License No. DPR-76 to the Pacific Gas and Electric Company authorizing operation of the Diablo Canyon Nuclear Plant, Unit 1 at reactor core power levels not in excess of 166.9 megawatts thermal (5'X power) in accordance with the provisions of the license, the Technical Specifications, and Environmental Protection Plan.
The purpose of this Discussion of Environmental Effects is to consider the contribution of the uranium fuel cycle activities to the environmental costs of operating this nuclear
'ower facility.
Table S-3, Table of Uranium Fuel Cycle Environmental
- Data, 10 CFR Part 51, of the Commission's Regulations provides the basis for considering the significance of the uranium fuel cycle impacts resulting from operation of the facility.
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In November 1972, 'a document entitled "Environmental Survey of the Nuclear Fuel Cycle"
( hereinafter referred to as "Survey" )
was published by the Atomic Energy Commissiion (AEC ), predecessor agency of the Nuclear Regulatory Comoission.
Coranents on the Survey were solicited, and an informal rulemaking hearing was held on February 1 and 2, 1973.
Written comments were received in response to the Federal Register notice, and recoranendations for improvement were offered during the hearings.
After consideration of the written coranents and the hearing record, the AEC promulgated the final fuel cycle rule
( the so-called Table S-3) on April 22, 1974 (39 FR 14188). It was intended that, with the inclusion of envirormental impacts from Table S-3, the environmental impact statements for individual light water reactors would set forth a full and candid assessment of costs and benefits consistent with the legal requirements and spirit of the National Environmental Policy Act (NEPA).
The environmental impact of the nuclear fuel cycle was not addressed in the cost-benefit analysis presented in the Final Envirormental Statement (FES)
Related to the Operation of Diablo Canyon Units 1 and 2, issued Hay 1973.
However, during an evidentiary hearing held on October 18-19, 1977, revised Table S-3 values concerning the environmental effects as the Uranium Fuel Cycle were admitted into evidence.
On January 19, 1975, the AEC was abolished and its licensing and regulatory responsibilities transferred to the Nuclear Regulatory Commission (NRC or Commission).
On July 21, 1976, the United States Court of Appeals for the District of Columbia Circuit decided Natural Resources Defense Council v.
- NRC, a case involving judicial review of the fuel-cycle rule, and Aeschliman v.
- NRC, a related case involving the exclusion of fuel cycle issues from an individual power reactor licensing proceeding.
The court approved the overall approach and methodology of the fuel cycle rule and found that, regarding most phases of the fuel cycle, the underlying Environmental Survey represented an adequate job of describing the impacts involved.
However, the court found that the rule was inadequately supported by the record insofar as it treated two particular aspects of the fuel cycle - the impacts from reprocessing of spent fuel and the impacts from radioactive waste management.
In response to that court decision, the Commission issued a General Statement of Policy (41 FR 34707, August 16, 1976) announcing its intention to reopen the rulemaking proceeding on the environmental effects of the fuel cycle to supplement the existing record on waste management and reprocessing impacts to determine whether the rule should be amended and, if so, in what respect.
The Commission thus indicated its intent to handle the question of the envi ron-
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mental impacts of waste management and reprocessing generically rather than in individual licensing proceedings.
The Commission directed the NRC staff to prepare on an expedited basis a well-documented supplement (NURfG-0116) to the Survey (WASH-1248) to establish a basis for identifying environmental impacts associated with fuel reprocessing and waste management activities that are attributable to the licensing of a model light-water reactor.
The revised survey was completed in October 1976, and the Commission issued the October 18, 1976 notice regarding the-proposed interim rule.
The comments received in response to that notice and the Commission's responses to those comments comprise NUREG-0216, Supplement 2 to WASH-1248.
On March 14, 1977, the Commission published in the Federal Register (42 FR
.13803) an interim rule regarding the environmental considerations of the uranium fuel cycle.
It was to be effective for 18 months (it was extended several times, the final extension being to September 4, 1979) and revised Table S-3 of 10 CFR Part 51.
A rulemaking hearing was held to consider whether the interim rule should be made permanent or, if it should be altered, and if so, in what respects (42 FR.26978); this proceeding began on May 26, 1977.
The Hearing Board took extensive written and oral testimony from more than twenty participants.
On August 31, 1978, the Hearing Board submitted to the Commission a detailed summary of the evidentiary record, followed on October 26,
- 1978, by its Conclusions and Recommendations.
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After studying the Hearing Board's Conclusions and Recomnendations and receiving written and oral presentations by rulemaking participants, the Coranission adopted as a final rule the modified Table S-3 recomnended by the Hearing Board (44 FR 45362 dated August 2, 1979).
The modified Table S-3 became effective September 4, 1979.
The impact values in this table differ only slightly from the values in the interim rule.
With two exceptions, these values will be taken as the basis for evaluating in individual light water power reactor licensing proceedings, pursuant to requirements of the
- NEPA, the contribution of uranium fuel cycle activities to the envirorrnental costs of licensing the reactor in question.
The exceptions are radon releases, 1/
presently omitted from the interim rule (43 FR 15613, April 14, 1978),
and 2/
technetium-99 releases from reprocessing and waste management activities.
17 With regard to radon releases, the matter of appropr iate values was considered before the Atomic Safety and Licensing Appeal Board in the proceeding derived from ALAB-480 which involved a consolidation of numerous proceedings.
In ALAB-640, issued on Nay 13, 1981, the Appeal Board issued findings on appropriate radon release rates.
The Diablo Canyon Atomic Safety and Licensing Board found that consideration of these radon release rates associated with Diablo Canyon would not alter the cost-benefit balance (Partial Initial Decision of July 17, 1981, p.8).
2/
With regard to technetium-99 releases from reprocessing and waste management activities, in 44 FR 45362 the Cormission found:
"In view of the Hearing Board' conclusion that the conservative assunption of complete release of iodine-129 tends to compensate for the omission of technetium from Table S-3, the Commission finds it unnecessary to reopen closed proceedings or to disturb consideration of environmental issues in presently pending pro-ceedings to provide for consideration of technetium-99 releases."
Thus, consideration of technetium-99 releases in connection with the licensing of the Diablo Canyon, Units 1 and 2 is unnecessary
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The rulemaking record makes clear that effluent release
- values, standing alone, do not meaningfully convey the environmental significance of uranium fuel cycle activities.
The focus of interest and the ultimate measure of impact for radio-active releases are the resulting radiological dose commitments and associated health effects.
To convey in understandable terms the significance of releases in the Table, the Hearing Board recommended that the modified Table be accompanied by an expanatory narrative promulated as part of the rule.
The recommended narrative would also address important fuel cycle impacts now outside the scope of Table S-3, including socioeconomic and cumulative impacts, where these are appropriate for,generic treatment.
Pending further treatment by rulemaking, the Coranission directed the NRC staff to address the environmental dose commitments and health effects from fuel cycle releases, fuel cycle socioeconomic
- impacts, and possible cumulative impacts in the environmental analysis accompanying a proposal to issue a limited work authorization, construction permit, or operating license for a power reactor.
The Commisssion directed the NRC staff to prepare such a
.narrative.
The staff prepared narrative was published on March 4, 1981 in the Federal
~Re ister (46 FR 15154-15175).
The narrative is of an explanatory nature, providing a discussion of the environ-mental dose commitments and health effects, socioeconomic
- impacts, and possible cumulative impacts associated with the uranium fuel cycle activities representative of a fuel cycle for the Diablo Canyon Nuclear Plant, Units 1
8 2.
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The fuel cycle effects presented in Table S-3, as discussed in the explanatory narrative are sufficiently small so that, when they are superimposed upon the other environmental impacts assessed with respect to operation of the reactor, the changes in the overall environmental impact from operation of the Diablo Canyon Nuclear Plant, Units 1
8 2 are not substantial.
Giving due consideration to the values given in Table S-3 and the information set forth in the explanatory narrative, the NRC staff concludes that the overall cost-benefit balance developed in the Diablo Canyon proceeding remains unaltered.
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