ML19248D700
| ML19248D700 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 08/06/1979 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Quigg C POLLUTION & ENVIRONMENTAL PROBLEMS, INC. |
| References | |
| NUDOCS 7908170205 | |
| Download: ML19248D700 (1) | |
Text
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NUCLEAR REGULATORY COMMISSION
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,o AUG G 1979 Docket No. 50-304 Ms. Catherine Quigg, Research Director Pollution and Environmental Problems, Inc.
Box 309 Palatine, Illinois 60067
Dear Ms. Quigg:
This letter is sent to acknowledge receipt of your 10 CFR 2.206 petition requesting that the Director of Nuclear Reactor Regulatici issue a full Environmental Impact Statement concerning the high burnup fuel project at the Zion 2 reactor.
We regret the delay in answering you, but, as indicated in the telephone conversation with Mr. Richard Bachmann of the NRC legal staff on July 11, we are currently reviewing your comments and appropriate action will be taken within a reasonable time.
Sincerely,
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- 11. R. Dataq j Harold R. Denton, Director Office of Nuclear Reactor Regulation 778 :1i 7 90817o20T
2 OLLUTION 8.
April 27, 1979 NVIRONMENTAL Mr. Harold Denton, Directer Office of Nuclear Reactor Regulations U.S. Nue) ear Regulatory Cemission Washit. '.sn, D.C. 20555 RE: Need for Envirornmental Impact Statement on Major Federal h*
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Box 309
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With the decision not to reprocess, the federal government and the utilities want to use more uraniun in existing a: - ;;,**-, =
lightwater reactors. To that end, the U.S. Department of r*,,c, C '- a -
Energy (DCE) has initiated cost-chared high burnup projects c;,yj;,, dl, with Duke Power Co. and Arkansas Power 3, Light. The DCE is also supporting two pellet clad interactic.2 (p.e.i.)
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projects with Censumer Power Co. and Cer.c.cnwealth Edison Co.
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.o a permit to Co=Ed allowing On !! arch 7,1979 the NRC
- e the irradiation of four Zion spen..
assemblies to extended
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burnups in Zion 2, up to about 55,000 EVD/M. Zion's Technical Specifications provide for a burnup limit of
.o.oro,a 38,000 MND/M W.
The NRC adm!.ts there has been no experience
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with full size fuel assemblies irradiated to these burnups,
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but nenetheless issued a. Negative Declaratics stating the higher burnups would have no appreciable envireemental impact.
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These experiments and others are being conducted sd thout an
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Environ: ental Impact Statement, even though they could cause significant long and short term effects on the h2=an environ:n ent. According to the NEPA, ' major Federal actions significantly affecting the quality of the hu: nan environments require 'a detailed Enviren:nental Impact Statement (EIS) by s the responsible goverment official. In accordance with 10 CFR, Part 2 (2.206), please consider this letter my forms.1 request for a full EIS on high burrnap fuel, both in the rascter and subsequently as a spent fuel waste.
The~ following specifio comments relate to potential significant effects of high burnup on the human environment and constitute the basis for my request 1.
Greater fission gas releaseafrem nuclear reactors.
According to Nuclear Safety, Vol.19, No. 6, Nov-Dec.1978:
...coe:nents frem the research ceMty indicate growing evidence for an increased rate of fi.cion-gas release in lightwater reactor fuels (LNR), particularly above 30,000 MWW3C'U.
Dr. 2eter Lang, acti=g dire ctor for LYR Develop =ent, Division e f Nuclear Power, DCE, also
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projects greater fissien gas releases as a side-effect 0'
of higher fuel burnup times.
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ENVIRONM ENT AL RESTO R ATION THROUGH EDUCATION 778 '*?
In its Safety Evaluation Report on increased fuel burnup at Zierrr the NRC concedes that ' Irradiating fuel to extended burnups will increase the amount of long-lived fission products and 'could increase the fractica of failed fuel in the core ever that previously experienced." The NRC states: "Therefore, although t he licensee may release =cre radioactivity from Zion 2 during this extended burnup program than during previous eyeles, cespliance with plant-technical Jpecifications will maintain concentrations of radioactivity wPMn the allowed -limits."
In other words, the NRC, without notifying the public of the quantity er kind of increased radioactivity releases from the Station, has decidel on our behalf that this increased amount of radioactivity is acceptable to us.
The NRC made this decision unilaterally without notifying the public or without benefit of public hearings or input. We call to question the democracy and ethics of this decision-caking process.
The public is entitled to.know quantitatively snd qualitatively the radionuclide enisaiens attributable to higher burnup, in advance of those releases. The benefits to the utilities of greater uranium utilization should not be the detemining factor in higher burnup approvals.
- 2. Increased fission gas releases freur sper:t fuel pools. Higher irradiation damage to -fuel uay oct:ur with higher burnup.
Dr.
Peter Lang-states that current LNRs have not experienced excessive corrosion on the outside surface of the fuel rods.
He suggests, however,- that: "If burnups and rssidence times are increased signifienntly, it is possible that a thicker layer of oxida and crud deposits may develop, raising the oxide cladding interface temperature sufficiently ter accelerate co rro sion. '
I submit that the above-state possibility of fuel corrosion raises serious questions regarding the quality of spent fuel produced under higher barnup. If the fuel is more corrodeds the radioactive emissions to and frca the spent fuel pool and subsequently to the atmosphere-and public will be higher.
~ The public, in the absence of an EIS, is being asked to accept the risk of greater fission gas releases from spent fuel pools in the future -- without even an estimate of the quantity and makeup of the se e:sissions or their effects on the human env iron =ent.
- 3. Production of inferior grade nuclear spent fuel which can lead to long-term environmental hazarde. Previous government research, including NUREG-0404, is based on low burnup fuel.
It is useless in predicting pool storage behavior of high burn-up fuel.
The public is currently being asked to accept greatly increased amounts of spent euel at the sites of nuclear reactors across the country, ef* t in highly populated areas. The NRC's imWa D G72 en 7 78
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NUREG-0404 assures citizens that "At-reacto r spent fuel storage can be increased...with ne sacrifice to public health and safety." and 'The environmental impact of the proposed increased at-reactor spent Nel storage was negligible...'
based on existing pool water technology.'
It should b e pointed out that existing pool water technology and research is based on low burnup Nel.
A.B. Johnson, Jr.,
in his " Behavior of Spent Nuclear Puel in Water Pool Storage,'
notes the maximum burnup. of stored comercial fuel is 33,200 MWD /MTU and for military 36,000 MWD /MTU (ECF at Idaho).. The NRC's projections for safe storage of spent Nel are thus pool' storage experience; with no based on limited low burnup /MTU including military.
experiencer beyond 36,000 MND The spent Nel product of the future,- if high burnup is permitted on a widescale,-is of unknom quality and is anticipated by some scientists to have decidedly poorer structural character-istics and integrity-than present low burnup specimens. As the NRC grants permission to more and more utilition to go to higher burnup, the quality of spent fuel will prebably be degraded; at best it is unknown.
The low burnup spent Nel storage experience at the Morris Operation and that researched by A.B. Johnson, Jr. of Battelle Laboratory becomes irrelevant as a basis fbr spent fuel behavior predictions as the United States moves toward higher burnup. I submit that NUREG-0404 should be declared null and void as a document on which to base spent fuel safety and environmental considerations.
Before proceeding with" reactor-scale experiments that could endanger their -hes.lth and environment, the public is entitled to scientific projections and analyses of nigh burnup. These should include, but not be limited to, risks of pre:sature red failure, estimations of increased fission gas releases and fuel red internal pressure, likelihoo d of corrosion and hydriding of cladding and structural materials and expectations of Nel assembly dimensional and structural changes. We should be given a reasonable explanation of the reasons why the above research can not be carried on in industry and government laboratories, before proceeding with experimentation in the hu=en enyironment.
- 4. Potential for greater radiological impact in reactor and spent fuel pool accidents.
The projected impact of high burnup on -
reactor and-spent Nel pool accidents has net been revealed to the public. The i=ps et-of larger radiesetive gas releases frem high burnup Nels in a-loss of coolant accident either in the reactor or the spent fuel pool should be an important consideration in allowing a utility permission for higher bu rnup. According to R. O. Meyer, Director of Safety Systems, Office of Nuclear Reacter Regulations, U.S. NRO:
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has reason to believe that the plant safety analyses underpredicted fission gas release at high burnups."
"'ho public is entitled to know the corrected estimates for increase in fission gas release due to high burnup; especially since all indications are that fission gas release is a direct
- function of burnup. -
In eenclusienr1 Protest not only the NRC's negative appraisal of the environ = ental effects of high burnup -- but also the fact that prior public notice of the NRC's action was not given. O My assesement of the erwironmental impact is at variance with the NRC. I urgently request that you reconsider and prepare a full and comprehensive EIS on high burnup in lightwater reactors in order to better serve the public heelth and safety.
Sincerely yours, 7
Catherine Quigg, research director Pollution E. Environmental Problems, Inc.
Box 309 Palatine, Illinois 6C067 312/381-6695 ces President Ji=sy Carter, and to Meests. Douglas Co stle (Adminis-trator, US-EPA), Jacob-Dumelle- (bhair=an, Ill. Pollution Control 3d.), Joseph Hendrie (Chair: nan, NRC), Charles Percy (US Senator frem Illinois), Adlai Stevenson (US Senator from Illinois),
James Schlesinger, (Secretary, DCE), William Scott (Attorney.
Gen. of Ill.), Philip Crane (US Congressman from Ill.), James Thompsen (Gov. of Ill.), and Charles Yarren (Chairman, President's Council on Environmental Quality)
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