ML20003E290
| ML20003E290 | |
| Person / Time | |
|---|---|
| Site: | 07001308 |
| Issue date: | 01/12/1981 |
| From: | Wolfe B GENERAL ELECTRIC CO. |
| To: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20003E291 | List: |
| References | |
| 18219, NUDOCS 8104020777 | |
| Download: ML20003E290 (27) | |
Text
p PO/L 90- t 3 OT G ENER AL h ELECTRIC GENERAL ELECTRIC COMPANY 875 CuntNER AvtNut SAN JOSE.CAUFORNIA 95125 OR. B E RTRA*d WOLFC v.Cg pass.ogest asen egnana6 emanagge sewestae twas amo sgav.CES otwision January 12, 1981 Docket No. 70-1308 Materials License No. SNM-1265 Office of Nuclear Material Safety & Safeguards Attn:
R.E. Cunningham, Director Division of Fuel Cycle & Material Safety I
U.S. Nuclear Regulatory Comission Washington, DC 20555
SUBJECT:
AMENDED APPLICATION FOR RENEWAL OF MATERIALS LICENSE NO. SNM-1265 UNDER PART 72, TITLE 10, CODE OF FEDERAL REGULATIONS
Reference:
Application for Renewal of Materials License SNM-1265; D.M. Dawson (GE) to R.E. Cunningham (NRC) dated February 27, 1979 Gentlemen:
General Electric (the applicant) hereby amends its referenced application for renewal of Materials License No. SNM-1265, Docket 70-1308, which was filed in a timely fashion on February 27, 1979, by requesting license re-newal in accordance with the requirements of Title 10, Code of Federal Regulations, Chapter 1, Part 72, " Licensing Requirements for the Storage of Spent Fuel in an Independent Spent Fuel Storage Installation (ISFSI)."
Materials License No. SNM-1265 authorizes the applicant to receive, possess, store and transfe'r irradiated fuel received from light water reactors at its Morris Operation fuel storage installation near Morris, Illinois. The characteristics of the nuclear fuel to be stored, the conduct of activities at Morris Operation, the qualifications and experience of the applicant and other pertinent information are included in the various documents submitted with the original application for renewal referenced above, and in the attach-ments to this letter. The documents previously submitted, as well as Attachments A through H submitted herewith, form a part of this amended application and are incorporated herein by this reference.
8104020.7 g
=
R.E. Cunningham January 12, 1981 Attachments to this amended application are as follows:
o Attachment A provide: the names, titles, and addresses of the applicant's principal officers as 'ffective on December 31, 1980. This attachment revises the correspod ig information furnished with the i 911 cation of February 27, 1979.
o Attachment B contains a response to specific sections of 10CFR72, as requested by letter, L. Rouse (NRC) to 0.M. Dawson (GE), November 12 and 28, 1980, o Attachment C contains references to each and every section of 10CFR72, showing the principal locations of relevent material in the Consolidated Safety Analysis Report, NED0-21326C (the CSAR) or other submitted docunents.
o Attachment D provides a sumary of environmental rek ?t information, referencing specific portions of documents previously turnished by the applicant and documents authored by the ComMssion's Staff or other Federal
- agencies, o Attachment E consists of a copy of General Electric Comoany's Annual Report for 1979 (the most recent report) in response to Part 72.14(e). Also, refer to the CSAR, Appendix A.7 as contained in Attachment G for finanHal arrangements related to decommissioning.
o Attachment F contains the proposed Operator Training and Certification Program, submitted herewith for approval in accordance with Part 72, Subpart I, and Part 72.15(a)(8).
o Attachment G contains the proposed Revision C3 of NED0-21326C, the CSAR.
The proposed revision incorporates new or expanded material in response to requirements of Part 72.
o Attachment H contains proposed Technical Specifications for fuel storage activity at Morris Operation as required by Part 72.16. These specifications have been adapted from the previously approved Operation Specifications, Chapter 10 of the CSAR, NED0-21326C.
Please note that the proposed Revision C3 of the CSAR is' interrelated with the proposed Technical Specifications (Attachment H) and will not be effective until both the proposed revision and technical specifications have been accepted by renewal of Materials License No. SNM-1265 under 10CFR72. At that time re-placement pages for the CSAR, incorporating Revision C3, will be furnished.
A fee of $32,000 was furnished with the referenced Application for Renewal of liaterials License SNM-1265 of February 27, 1979. Therefore, no fee is enclosed with this amended application.
Please contact H. A. Rogers (408*925-6496) or C.C. Herrington (408*925-6385) of the applicant's staff if there are questions regarding this-application.
Correspondence regarding this application should
R.E. Cunningham January 12, 1931 be sent to D.M. Dawson at Mail Code 861 at the above address.
The infornation contained in this subnittal, and r.aterial previously originated and submitted by General Electric and referenced herein, are true and correct to the best of ry knowledge and belief.
Respectfully submitted, GEfiERAL ELECTRIC COMPA'iY
/
, ~
'B'ertrar Wolfe i
State of California County of Santa Clara On this the 12th day of January 1951 be' ore re, the undersigned !iotary Public, personnally appeared Dr. Bertran Wolfe known to ne to be the person whose name is subscribed to the within instrument and acknowledged to ne that he executed the same.
Ifi WITriESS WHEREOF, I hereunto set my hand and official seal.
.,T 0h;.
j1 t
L,, L(f fiotary P'ublic in and for the State of California, County (o.SantaClara l
\\
M n t!G^G T' W[,-
j i,,l., f.
1
/bn
. s.m.,
Attachment
$ ' j,,
)
-n a.~.. J b
NOTICE OF DISTRIBUTION to SERVICE LIST - DOCKET NO. 70-1308 In the matter of General Electric's application for renewal of Materials License No. SN!'-1265, copies of the documents discussed in the attached letter have been forwarded to the law firm of Mayer, Brown and Platt, 231 South LaSalle, Chicago, IL.
60604, counsel for General Electric Company, for transmittal to the service list as shown below:
Andrew C. Goo 2 nope Esq., Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel 3320 Estelle Terrace U.S. Nuclear Regulatory Com-ission Wheaton, Maryland 20906 Washington, D.C.
20555 Dr. Linda W. Little Oceketing and Service Sectior.
Atomic Safety and Licensing Board Office of the Secretary 5000 Hermitage Drivo U.S. Nuclear Regulatory Conrission Raleigh, North Carolina 27612 Washington, D.C.
20555 Dr. Forrest J. Remick Everett J. Quigley Atomic Safety and Licensing Board RR1, Box 378 305 East Hanilton Avenue Kankakee, IL 60901 State College, Pennsylvania 16801
. Atomic Safety and Licensing Appeal Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Bridget Little Rorem Essex, IL 60935 Susan N. Sekuler, Esq.
George William Wolff, Esq.
Office of the Attorney General 188 West Randolph Street Suite 2315 Chicago, IL 60601 Marjorie Ulman Rothschild, Esq.
United States Nuclear Regulatory Commission Washington, D.C.
20555 List 3/28/80 A 4
9
Effective Date:
December 31, 1980 ATTACHf1ENT A APPLICATION FOR RENEWAL OF MATERIALS LICENSE SNft-1265 APPLICANT'S P'INCIPAL OFFICERS Reginald H. Jones - - - - - Chairman of the Board and Chief Executive Officer John F. Burlingame - - - - - Vice Chairman of the Board and Executive Officer Edward E. Hood, Jr. - - - - Vice Chairman of the Board and Executive Officer John F. Welch, Jr. - - - - - Vice Chairman of the Board and Executive Officer James A. Baker - - - - - - - Exect.'ive Vice President, Sector Executive -
Industrial Products and Components Sector Robert R. Frederick - - - - Executive Vice President, Sector Executive - Inter-national Sector Herman R. Hill - - - - - - - Executive Vice President, Sector Executive - Power Systems Sector Christopher T. Kastner - - - Executive Vice President, Sector Executive - Technical Systems and Materials Sector Paul W. Van Orden - - - - - Executive Vice President, Sector Executive - Con-sumer Products and Services Sector Arthur ti. Bueche - - - - - - Senior Vice President, Corporate Technology Daniel J. Fink - - - - - - - Senior Vice President, Corporate Planning & Development Robert B. Kurtz - - - - - - Senior Vice President, Corporate Production and Operating Services Leonard C. Maier, Jr. - - - Senior Vit.e President, Corporate Relations Walter A. Schlotterbeck - - Senior Vice President, General Counsel and Secretary Thomas 0. Thorsen - - - - - Senior Vice President, Finance All principal corporate officers are citizens of the United States of America.
The address for these officers is:
General Electric Company Fairfield, Connecticut 06431 Additional information regarding General Electric Company may be obtained from.its Annual Report, Attachment E.
. - -. -_ _,. _~
ATTACHMENT B RESPONSE TO SPECIFIC SECTIONS OF 10CFR72 Response to opecific sectione listed in Rouse letter of November 12, 1980 as amended by letter of November 28, 1980.
Section
Response
72.ll(b)
Refer to application letter 72.14(e)(2)
Refer to application letter 72.14(e)(3)
Shutdown and decommissioning costs, and financial provisions are described in CSAR Revision C3, Appendix A.7, Section A.7.5-series, including Figure A.7-1.
72.17(d)
A commitment to have and maintain an adequate compliment of trained and certified personnel is contained in CSAR Revision C3, Section 9.2.3.8.
72.20 Information on file and previously submitted; see Attachment D.
72.33(b)(4)
The training and certification program is contained in Attachment F; also, see CSAR Revision C3, Section 9.3.1.
l 72.33(b)(5)
Provisions for use of uncertified personnel are contained in CSAR Revision C3, Section 9.4.1.
- 72.72(e)
Proximity of sites is discussed in the CSAR, Revision C3, Sections 3.3.1 and 8.1.2.
72.76 Criteria for decommissioning are included in the CSAR, Section 4.5.
Subpart I Refer to response to,Part 72.33(4) and (5) i I
t i
s n
a
'vw'-
y-
,w,
. -,,... - - -yv-w.
-yp.-
,v.--
-m---me,r--+-
,., - _4e wrem.-
...p..,
-o,.
4 e.rr.,
pyy
-,,.---,c.ee---
em gy
,-r-
h ATTACHMENT C COMPARIS0N OF PART 72 REQUIREMENTS VERSUS APPLICANT'S DOCUMENTATION AS REQUESTED IN ROUSE LETTER OF NOVEMBER 12, 1980 Documents referenced herein are identified under " Notes" on page C-C.
References are to chapters or sections of the CSAR (note 2) except chere noted otherwise. A section reference followed by the symbol (*) indicates material contained in the CSAR proposed Revision C3; see Attachment G.
A section reference not followed by the symbol refers to the current CSAR, including Revision C1; Revision C2 has been uithdraun. The acronym NRR means, "no response required". Document references indicate principal responses; however, the5 references are not intended to be exhaustive.
Part 72 Applicants Documentation References Subpart A
- NRR Subpart B 72.11(a),(b)-
- See request for amendment (note 1).
(c)
- See request for amendment; copies of CSAR proposed Revision C3 furnished in same quantity as original submission (February 1979).
(d)
- Furnished with original submission (February 1979) 72.12
- NRR 72.13
- NRR 72.14(a)(b)
- See request for amendment (c)
- 1.1.1 (*)
(d)(1)
- NRR (2)
- NRR
'(3)(i)
- 1.1.1 (ii)-
- See request for amendment (4)
- NRR (e)
- See request-for amendment
'72.15(a)
- CSAR (note 2)-
(1)
- 1.1.2, 1.1. 3; 1.2 through 1.2.2.3 including 1.2.1.5(*);
Chapter 3 including sections in'the proposed Revision C3,
especially Sections 3.7.5, and 3.9(*) through 3.9.1.3(*).
c.2 (2)
- 1.2; 1.2.2 through 1.2.2.3; 1.3 through 1.3.6 (3)(1)
(ii)
- Refer to Subpart F (iii)
(iv)
- 4.6(*)
(4)
- 5.3 through 5.8, including 5.5.l(*), 5.5.3.2(*),
5'.5.4.3(*), 5.5.5.4(*), 5.7.l(*), and 5.7.2.3(*).
(i)
- see above (ii)
- Chapter 8, and Appendix A.8, A.9, A.12 and A.13 (5)
- Chapter 7; especially 7.2 and 7.6. Also, see Operating Experience Report (note 3), Sections 4.5 and 5.2.
(6)
- 1.3.5.1; 4.3.8.3 and 4.3.8.4; 5.4.2.3, 5.5.5.8.
Also see Operating Experience Report Section 3.5 and 3.6.
(7)
- See Attachment H (8)
- Chapter 9 (9)
- NRR-(10)
- See response to Part 72.17 1
(11)
- See. response to Part 72.19 (12)
- Chapter 6 (i)
- Operating Experience Report, Sections 4 and 5 (ii)
- 4.3.8.4; 5.4.2.3, 5.5.2 through 5.5.2.4, 5.5.4 through 5.5.4.2, 5.5.4.4, 5.5.5.7 and 5.5.5.8.
Also, see Operating Experience Report, Sections 3.3 through 3.6.
(iii)
- 5.4.2.3 and Operating Experience Report Section 3.6 (13)
- 8.7.1, 8.7.2.1, 8.8.3, 8.9.1, 8.*10.3.1 and Appendix A.13 (14)
- Chapter 11 and Appendix B.8 (15)
- See response to Subpart H (16)
- NRR-(17)
- See response to 72.18 72.16
- See response to 72.33 72.17(a)
- 1.1.l(*)
(b)
- Attachment F
-(c).
- 9.2.3 (d)
- 9.2.3.8
~.-
3 C-3 1
4 72.18(a)
- Appendix A.7 (b)
- Appendix A.7, Section A7.5.3 72.19
- See Radiological Emergency Plan (note 4) 72.20
- See Attachment D 72.21
- NRR Note: Copies of revised documents are furnished in the same quantity as with the original application.
Subpart C
- NRR Subpart D
- General requirements under 9.4.2 and 9.4.2.1; see
+
Attachment H Subpart E 72.61(a)
- Chapter 3 - all sections, and referenced appendixes.
(b)
- 3.3, 3.4, 3.7 series c
(c)
- 3.8 (d)
- NRR f
(e)
- See Attachment D; also, Operating Experience Report (f)
- 3.5.2
-72.62(a) i 4
.(b)
- 3.4, 3.5, and 3.7; also 3.8 (c) 72.63(a).
i (b)
- 3.3, 8.1.2(*)
(c)'
h 72.64(a)
- 3.4, 3.5, and 3.7; also 3.8 (b)
- Attachment D; Operating Experience Report; CSAR
. Appendix A.7.
(c)(i)
- 3.2.3 (ii)
- 3.2.4 through 3.2.4.5 (iii)
- 3.4.3, 3.4.4, 3.6.1 through 3.6.3, and referenced appendixes.
(d)
- NRR
-72.65(a)
- Operating Experience Report; CSAR 8.1.1 through 8.1.1.3 (b)
- Operating Experience Report; CSAR Appendix A.7
0
~f C-4 72.66(a)(1)
- NRR (2)
- fiRR (3)
- NRR (4)
- Appendix B.1 and B.2 (5)
- NRR (6)
- 4.2 through 4.2.5.2.3 (b)
- NRR 72.67(a)
- NRR (b)
- See Attachment H (c)
)
72.68(a)
- 1.2.1.5(*), 3.2.2.4(*)
(b)
- 4.3.6.l(*)
(c)
- NRR 72.69(a)
- 3.2.2.4(*)
(b)
- NRR 72.70
- 3.8(*)
Subpart F 72.71
- NRR 72.72(a)
- 4.4(*) and Chapter 11(*)
(b)(1)
- 4.2(*) through 4.2.6.2 (2)
)
(3)
- 4.4.2(*)
(4)
- 4.3.2.1(*)
(c)
- 4.3.7 through 4.3.7.2(*)
(d)
- NRR (e)
- 4.3.1(*)
(f)
--4.2(*),4.3.4.1(*) through 4.3.4.3 (g)
- 4.2.(*)
(h)(1)
- 4.1.2, 4.2'(*), 4.3.2(*), 4.3.5, 4.3.7, 4.3.8 (includ-ing subsections of these principal sections).
.(2)
-- 4.3.2.1(*)
(3)
- 4.3.3.1(*)-
-(i)
- 4.3.4.1(*)
(j)
- 4.3.4.1(*)
(k)
- 4.3.9.1(*)
C-5 1
72.73(a)
- 4.3.5.1 and Appendix A.10 (b)
- Appendix A.10 and B.5 72.74(a)
- 4.3.6.1(*)
(1) I i
(2)
(3) j
- 4.3.6.2 and 4.3.6.2.l(*)
(4)
(5) )
(6)
- 4.3.6.2.2 (b)
- 4.3.6.2.3 (c)(1)
- 4.3.6.2.4(*)
(2)
- 4.3.6.2.3 (d)
- 4.3.3.l(*)
72.75(a)
- 4.3.8.1 and 4.3.8.3 (1)
- 4.3.4.1 (2)
- 4.3.6.2.2 (3)
- 4.3.2.1 (4)
- 4.2.7.l(*)
(5)
- 4.3.8.3 (b)
- 4.3.8.3 72.76
- 4.5(*)
Subpart G 72.80
- Chapter 11(*) and Appendix B.8 Supbart H f
- See Physical Security Plan (note 5)
.81 72.82
)
72.83
- Part of Physical Security Plan 72.84
- NRR Subpart I 72.91
- See Attachment F 72.92
{
72.93
)
{
o C-6 j
-[
1 Notes:
1.
" Request for amendment" refers to attached letter to R. Cunningham j
(NRC), dated 1/12/81.
2.
"CSAR" refers to Consolidated Safety atnalysis Report for Morris Operation, NED0-21326C, including Revisions C1 and proposed C3 (proposed Revision C3 is attached; Revision C2 was withdrawn).
[
3.
" Operating Experience Report" refers to " Operating Eaperience Report -
Irradiated Fuct Storage at Morris operation.Tanuary 1972 to Dececher 1979, NEDO-209698, inchding revisions through Revision B4, September 1980.
4.
" Radiological Emergency Plan" refers to Radiological Evrgency Plan for Morris 'peration, NED0-21894, including revisions through Revision
-3, September 1980.
5.
" Physical Security Plan" refers to Physical Security Plan - Morris operation, NEDS-14507C4, including revisions through Revision.C4, December 1979. This plan includes a contingency plan and security force qualification and training plan.
j t
i a
h v-
,.-y
,.,p5 o 9
-p.m->
g.
r
..%,q--,y e--
w,w, ar, s--,,m,p.,-,-e,-
py r 7
,y m.
- - ~.
...,w...y,e.--,
y,..,,wm.ye--e,-...,,-,+,-
e.,--
, ~
w
ATTACHMENT D
SUMMARY
OF ENVIRONMENTAL REPORT INFORMATION 01.0 INTR'JDUCTION This document contains the environmental report information related to the renewal of Materials Licente SNM-1265 for General Electric's Morris Operation, required by Title 10, Code of Federal Regulations, Part 72.20 (10CFR72.20).
D1.1 Scope, Content and Summary This document consolidates and summarizes environmental information related to the irradiated (spent) fuel storage activities at Morris Operation that has been previously documented by General Electric, the U.S. Atomic Energy Commission (USAEC), the U.S. Nuclear Regulatory Commission (USNRC), and the U.S. Depart-ment of Energy (USD0E). These documents are listed in Table D-1, and include documents specifically related to the Morris Operation and documents concerned with the generic aspects of spent fuel transport and storage.
~
D1.1.1 Method of Referencing Information In accordance with provisions of 10CFR72.12, this document incorporates pre-viously published information by specific references to the documents listed in Table D-1.
References are made by Table 0-1 item number and specific reference (s) to paragraph or section, or as otherwise appropriate.
For example,
... refer to (13), 3.2.2 for site description..." references item (13) of Table D-1, Section 3.2.2 of the CSAR. Likewise, "... refer to (5), II, A-F for site description..." references Item 5 of Table D-1 Section II, Subsections A through F of the Final Environmental Statement for the Midwest Fuel Recovery Plant (MFRP).
Dl.2 Content Information 'in-this document su marizes t'.e environmental impacts of past m
activity at Morris Operation and forecatts impacts from activity authorized by the proposed license renewal in the period of 1980 - 2000.
D1.3 Summary of Experience Since:1972, more than 1000 bundles of irradiated (soent) fuel from commercial nuclear power plants using light water reactors - - Boiling Water Reactors
.,,. - -.~
,, _ _..., ~, -.,,
o D-2 (BWR) or Pressurized Water Reactors (PWR) - - have been received and stored at the Morris Operation facility.
Effective control of radioactive material in the basin water, water temperature, cask contamination, airborne radio-active materials and effluents has been demonstrated. Methods of cask and fuel handling and storage have also been demonstrated to be safe and effec-tive. There has been no appreciable leakage from fuel in storage as measured by radioactive materials in the basin water and fuel shipments have been com-pleted safely and efficiently.
Experience in water basin storage of spent fuel from light water reactors, both in the United States and abroad, has demonstrated that this storage method is a technically uncomplicated and passive operation. There are no sources of energy involved in fuel storage at Morris Operation with the potential for causing dispersal of radioactive material in a form that could be carried, in any biologically significant amount, to an off-site location to pose a threat to-public health and safety or to c'use environmental damage.
The nine years of spent fuel storage at Morris have resulted in an almost un-detectable environmental impact.
01.3.1 Additional Background Information Background information regarding the Morris Operation may be found in (1) through (5) for MFRP history and in (7) through (9) for fuel storage.
Reference (9) I.B contains a concise discussion of Morris history through the time of the fuel storage capacity expansion to about 700 TeU in 1975.
i D1.4 Status of Licenses A list of licenses and permits required for Morris Operation is contained in Table D-2.
l l
4 4
D-3 TABLE 0-1 APPLICABLE Ef4VIRONMENTAL DOCUMENTS These documents are discussed beginning in Section D1.1 Identi fication Item Source and Title Number Date (1)
GE; Applicanta Enviromental Report - Mid-NED0-14504 June 1971 west Fuel Recovery Plan, Morris, Illinois (2)
GE; Response to AFC Staff Questions Regard-NED0-14504-1 October 1971 ing Applicant, Envircr:nental Repor:-Miduest Fuel Recoverj Plant, Morris, Illinois.
(3)
GE; Applicants Enviromental Repor: Supple-NE00-14504-2 November 1971 2 - Mibes: Fuel Recoverj Flant, men Morris, Illinois.
(4)
GE; Response to AFC Staff Ouestions Regard--
NED0-14504-3 August 1972 inp Applicant: Envircr:nen:al Repor: -
Mibest Fuel Recoverg Plant, Morria, Illinois (5)
USAEC; Final Enviror. mental Sca:ement Rela:ed (None)
December 1972
- o operation of the ne Ribast Fuel Re-covers ?lant by :he General Electric company; Docke' 50-268.
(6)
USAEC; Enviromental Survey of *ranspor-WASH-1238 December 1972 tation cf Radioactive Materials :o and From Nuclear ?ouer Plants.
( 7)
USAEC; Ltr., Chitwood to Rouse, subject (None)
August 1974 Enviromen:al Considera: ions-Issuance of Facility Licence for Possession Only; Docket No's. 50-268 and 70-1308.
(8)
GE; Safety Evaluation Report for Morris NEDO-20825 March 1975 Operation Fuel Storage Eapansion.
(9)
USNRC; Environmental Impact Appraisal by NR-FM-002 December 1975 the Division of Fuel Cycle and Material Safety Related to License Amen 6 ent for Mater'*als License No. SNM-2265 - Morris Operation Facility... ; Docket No. 70-1308.
(10)
GE; Sur: mary Environmental Report - Euel NED0-21624 April 1977 Stomge Facility Eapansion for Morris Operation...
J t.
D-4 TABLE D Cont'd (11)
USf4RC; Final Envirorren:c! Statement en :he fiUREG-0170 December 1977 Transper:a:icn of Radioactive V :erial by (Vols. 1 & 2)
Air and other Mcies; Docket tio. PR-71, 73 (40 FR 23768).
(12)
UStiRC; Final Eneric Envircr.renta! Igac:
fiUREG-0575 August 1979 S::temen: cn Handling and Storage of (Vcis. 1-3)
- pent Light Water ?cuer Rece:cr Fue:.
(13)
GE; Consolidated Safety Analysis Report fiED0-21326C January 1981 for Morris Operation; through Revision C3, January 1981; referred to as CSAR.
(14)
USilRC (by Pacific fiorthwest Laboratory, fiUREG/CR-0956 July 1979 USD0E - Battelle Memorial Institute);
Pfil-3065 Comentary cn Spen: Fuel Storage a:
Morria Cgeration.
(15)
USf4RC; Environ ental I pace AppraiccI Re-(ficne)
June 1980 lated to the Beneual of Materials License Sh?s-l:65 for the Receipt, Storags and Transfer of S;en: Fuel; Docket tio 70-1308 (16)
GE; Cperating Eaperience Repor: -
fiED0-20969B fiovember 1980 Irradiated Fuei Socrage a:.Verrio Operation - January 237: :o Dece~be:
- JS0; including revisions through B4.
(17) b200E; Final Environ ental Igac: S:::em :
00E/EIS-0015 May 1980
- 0.5. Spen: Fuel ?clicy, Vol. 2 s
D-5 TABLE D-2 LICENSE AND PERMITS REQUIRED FROM FEDERAL AND STATE AGENCIES Issuance Expiration Action License No.
Date Date Registration Radiation In-None 8/6/71 None stallation, State of Illinois, Department of Public Health State of Illinois, Environ-063-806-AAC 4/26/78 4/18/81 mental Protection Agency, Division of Air Pollution Cont rol i
Illinois Environmental Pro-1979-E0-440 5/11/79 5/1/84 tection Agency Water Pollution Control Permit; Evaporation.
Pond Permit U.S. Nuclear Regulatory SNM-1265 i2/3/75 8/31/79(a)
Commission, Materials License Revised and Reissued for In-creased Capacity of Facility State of Illinois IL-00329-01 8/14/80 8/31/84 Department of Public Health Radioactive Material License Amendment No. 5 Illinois Environmental Pro-1976-EB-408-1 9/17/76 None t
tection Agency Water Pollution
-Control Permit, Land Disposal System Permit i
(a) Pursuant to 10CFR70.33(b) the applicant made a timely filing for renewal of its license. Therefore, in accordance with 10CFR70.33(b), the license shall not expire until the application for renewal has been finally determined by the Commission.
D-6 02.0 NEED FOR SPENT FUEL STORAGE The need for storage of spent fuel both at reactor sites and at ISFSI's has been analyzed in (12) Vol. 1, 2.0 and 3.0 series; and Vol. 2, Appendix I.
02.: Need for Continuing Operation at Morris
- General Electric needs to continue operation of its spent fuel storage facility a; Morris in order to store: (1) GE-owned fuel, (2) utility-owned fuel either presently in storage or to be received pursuant to existing contracts, and (3) other utility-owned fuel if necessary to fulfill existing limited comitments to certain utilities in the event of an emegency situation or lack of full core discharge capability at their plant sites.
In addition, the ownership of and responsibility for additional fuel bundles originally supplied by GE to four utilities are in dispute. The resolution of the dispute with three of these utilities has been postponed. GE is in liti-gation with the fourth utility.
It is GE's position that it does not own and has no responsibility for any of this fuel.
Continued operation will also have the advantage of providing a storaga place which could be used to alleviate temporary, emergency storage needs of utilities, such as Dairyland Power, as requested by the Department of Energy.
Others foresee specific needs in the near future for continuing fuel storage operatior.s at Morris. These forecasts are supported by the broad base es-tablished in generic studies (12) and (17).
D3.0 SITE AND REGION ENVIRONMENTAL DESCRIPTIONS The site and region are described in (1) III, 1.0 - 8.4; (5) III, A-F and Appendix B; (13) 3.1 - 3.9 and Appendices A.5 and A.6, and Appendix B.1-B.4 and B.9 - B.14.
. Sub,lect of letter, Dauson, GS to Cunningham, NEC, dated April 25, 1980 Cn -December 3,1980, oveq the veto of the Governor of Illinois, the Illinois General Assembly enacted into lau a statute that bans the importation for storage into Illinois of any spent nuclear fuel chich vas used in any nuclear reactor located outside of Illinois.
This statute is sub,fect to litigation attacking its (footnote continued on next page)
Some added conments are contained in (2), (3) and (4)
,,,. - _, - - _,. _. _ _, _,,.. ~..,.... _. _
D-7 04.0 FACILITY DESCRIPTION The facility is described in (13) Chapters 1 and 5.
D5.0 OPERATIONAL HISTORY Operational history of Morris Operation fuel storage activity is contained in (14) all sections, and (16) all sections.
Item (16) is revised periodically to incorporate significant data from recent operations, including environmental monitoring reports.
D6.0 ENVIRONMENTAL AND RADIATION MONITORING PROGRAMS Monitoring programs for Morris Operation are described in (13) 3.2.2.4, 3.4.3, 3.6.3, 7.4.4, and 7.7
- and (16) all sections.
D7.0 ENVIRONMENTAL IMPACTS OF PROPOSED ACTION The proposed continued operation of ine Morris facility through the year 2000, the subject of the current licensing action, involves a possible continuing receipt of spent fuel until the present storage capacity (about 700 TeU) is reached. Non-radiological impacts, including use of water and effluents would continue on about the same unit-time basis.
For example, see (13) 3.6.3 and 5.8.4 through 5.8.4.5 and (16) 5.2 and Appendices A and B-3.
D7.1 Radiological Impacts The radiological impacts of the Morris Operation from January 1972 througn December 1979 are presented in (16), Chapters 2-5 and Appendices. Under 10CFR72, fuel received at Morris Operation will normally have been cooled i
at leae.t one year _ prior to receipt. Summarized data for fuel in storage at Morri. Operation as of August 20, 1980 is contained in Table D-3.
1 1
cona:itutionality for, ci~cv.g other rea3cna, imposing an unc:nctitutional burden upon interstate co merce. See General Electric Cc any cnd Sc'chern Ca:ifornia Ediscn Cc cany v. Tyrone C. Fahner (At:crney General, State of Illincial e: al, do C 6835 (N.D. Illincia December 24, 1330).
The State of Illincia has alac filed an enforcement action under the statute. See Peccle of Illinois v. Sou:hern Cali-fornia Edison Comcany, 30-12-543-CH (13th. Judicial Cours, Grundg County, Illinois, December 24, 1380.
That is, the amount of vater used per year or the amcunt of effluen: frcm the e
boiler per year.
D-8 Radiological source information is provided in (13) 7.3 - 7.3.3, and off-site dose assessmelt is contained in (13) 7.7 - 7.7.2.3.
These analyses assume 750 Teu of spent fuel and only 90 days cooling; therefore, these analyses are very conservative when compared to fuel cooled for about three years, typical of the newest fuel in storage.
Based on the experience data contained in (16), occupational exposure during receipt of fuel to reach storoge capacity, during routine operations while at capacity and during transfer of fuel should be about the same as previously experienced.
Continued efforts to reduce occupational exposures - - see (16) 4.5 and Table 4 - should reduce exposure incurred on specific tasks as well as overall operations.
The proximity of Dresden Nuclear Power Station (DNPS) has been considered in relation to operations at Morris. The measured and calculated dose commit-ments from Morris are a small fraction of the DNPS dose commitments under either routine or accident conditions (or both).
See (13) 8.1.2.
s 750 Teu vaa used as a nominal capacity during licensing activity, but as-buit:
capaaity is about 700 TeU.
D-9 TABLE D-3 DATA
SUMMARY
FUEL STORED AT MORRIS OPERATION August 20, 1980 Item PWR B'd Average Burnup 26,700 mwd /Te 3,600 mwd /Te Average Age 6.9 years 8.7 years Oldest bundles 51 bundles 29 buncles Discharge date April 1970 July 1970 Plant Connecticut Yankee Dresden Youngest bundles 13 bundles 5 bundles Discharge date September 1978 May 1975 Plant San Onofre Lacrosse Maximum burnup 40,550 mwd /Te*
18,990 mwd /Te#
Minimum burnup 10,760 mwd /Te**
19C mwd /Te#
- Point Beach C-64 discharged March 1977
- Connecticut Yankee C-52 discharged April 1970
- Lacrosse I-22 discharged May 1975 Dresden DN-506 discharged July 1970 07.2 Transportation of Radioactive Materials The environmental impacts of transporting spent fuel and other radioactive materials have been reported in (6) and (12). As sunrnar,ized in (6) Sumary and Conclusions, the risks to the environment due to the radiological effects of transportation, including accidents or from comon causes are very small; also, see (11) Volume 1, 5.9 and (17) Appencix C.
These small impacts arts quantified in Sumnviry Table S-4,10CFRbl.
i D-10 D8.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS i
The environmental impacts of accidents at an ISFSI have been analyzed in (12) 4.2.3-series and 4.2.4-series for related transportation accidents.
Analyses of accidents is also contained in (13) Chapter 8.
In all of these analyses, the dose commitments are extremely small and well within the requirements of 10CFR72.68.
09.0 SAFEGUARDS Safeguards have been placed in effect at Morris Operation in accordance with d physical security plan approved by NRC. This,lan includes a contingency plan and a plan for the selection and training of security personnel.
These i
plans and operations comply with requirements of 10CFR73.
l D10.0 DECOMMISSIONING A decommissioning plan is contained in (13) Appendix A.7.
This plan has the principal objective of decontaminating the site to permit future unrestricted use.
011.0 ALTERNATIVES **
Alternatives to the continued operation of the Morris facility which have been considered, include the following: Close the facility as it stands; replace the Morris facility by constructing and licensing a new facility;
{
transfer stored fuel to a private or Government-owned facility; return stored l
fuel to the nucle.3r power p'ut where it was used; transfer stored fuel to any nuclear power plant that has storage space available; reprocess the stored fuel; or dispose of the stored fuel as waste material.
i-None of.these are feasible alternatives to ccntinued operation of the Morris facility for the following reasons:
o Closing the facility with stored fuel in place is a violation-of regulations.
r s
=
- Also, see (.11) and (17)
Subject of letter, Dawson (GE) to Cunningham (NRC), dated April 23, 1980
)
t I
D-11 i
o Replacing the existing facility with a new facility is inconsistent with the current energy and environmental policies of Federal, State, and local governments, such as those to reduce the use of oil and protect the environ-ment from unjustified construction projects.
f o There are no other licensed, private away-from-reactor facil-ities with sufficient capacity to store the spent fuel presently l
stored at Morris.
o There are no known government facilities for storing the spent fuel presently stored at Morris.
o Returning spent fuel to the source power plants may be
[
impossible due to lack of sufficient storage space or in-q l
advisable due to storage congestion and loss of the plant's core reserve.
It is also inadvisable because of additional handling and transport of fuel which would be required.
[
o Transferring stored fuel to power plants with space available i
will create future storage problems at those facilities.
o Reprocessing the stored fuel is contrary to current governmental policies. Commercial reprocessing facilities are not available in the United States.
o Disposing of the stored fuel as waste is not possible due to lack l
of Federal facilities.
-Of the alternatives considered, continued operation of the Morris facility
{
represents the least environmental impact. Closing the facility with fuel still in storage is not considered a viable alternative because it violates regulations. The stored fuel must be removed or the facili'ty must continue l
operation. Replacing the facility requires additional land and resource
[
' utilization and eventual transportation.of the fuel and its associated environ-mental impact, small as it is (shown in 10CFR51, Summary Table S-4).
Moving fthe fuel to any other site involves transportation and if moved to power plant l
r j
sites its presence may, in addition, necessitate plant shutdown and the conse-f quent loss of electrical power generation. - Reprocessing of the fuel requires transportation to a comercial reprocessing facility - - none exist -in the l
l
0-12 1
?
United States - - and the additional environmental impact due to the process I
(shown in 10CFR51, Table S-3),
Discarding the fuel as waste requires trans-portation, land and resource utilization to construct facilities for such disposal and results in loss of the energy value of the fuel thus disposed.
The latter two alternatives cannot be accomplished because Federal policy prohibits reprocessing and Federal policy for waste management and disposal l
has not been implemented.
9 D12.0 COST-BENEFIT CONSIDERAliONS The renewal of Materials License SNM-1265 will permit the continued operation of the Morris facility to provide interim storage of spent fuel pending im-plementation of the Federal waste management and disposal program. The continued operation at Morris provides storage for about 315 TeV of fuel currently in place and an additional, capacity of about 385 TeV that could accommodate future needs of General Electric or emergency needs within the nuclear industry.
The costs incurred to obtain those benefits are nominal, consisting of a small, i
almost unmeasurable dose commitment to the regional population (15) and those along transportation routes (11)(12) - - a total of under 300 person-rem over the next 20 years, including occupational exposures - - operational costs of 4
about $3 million per year, and decommissioning costs of about $6 million l
(1978 estimate).
The costs of not renewing the Morris Operation license involve radio W ical dose commitments equal to or greater than those incurred in continuing operations, as well as significant costs that would be incurred in any alternative con-sidered, including potential loss of electric power generating capacity and increased importation of oil.
0
13.0 CONCLUSION
The fuel storage activities at Morris Operation have been shown to have an environmental impact that is so low as to be almost unmeasurable (16). Pro-jected impacts'over the next 20 years are essentially no greater than those in the past. The benefits of continued operation are much gretter than the cost in terms of environmental impact, even when accidents at the site or in trans-l Fuel transportation costs are not included because transportation capense is not an integral cost of facility operation and could be incurred in any viable alternative.
.Operat onal costs include tou-level caste shipment and disposal.
i
D-13 portation of spent fliel are considered.
Therefore, General Electric has requested that Materials License flo. Stim-126:
be renewed for a period of 20 years.
l
D-14 COMPARISON APPLICANT'S SUPNARY OF EM71RONMENTAL REPORT INF0FFATION VERSUS REQUIREMENTS OF 10CFR51.20 References are by section designation and - - where noted - - by reference to Table D-1 in the attached summary.
Par';
Summary Reference 51.20(a)
D1.0 through Dl.3; D3.0, D3.1 (1)
D7.0 through 07.2 (2)
D7.0 through D7.2 (3)
(4) 011.0 (5)
(b)
D12.0 (c)
D5.0, D6.0, and D7.0; especially Table D-1 (16) all sections.
(d)
Adverse data included, e.g., Table 0-1 (13),
7.7 - - 7.7.2.3
ATTACHMENT E GENERAL ELECTRIC COMPANY ANNUAL REPORT 1979 Copies of General Electric's Annual Report for 1979 are furnished as follows:
o U.S. Nuclear Regulatory Commission:
One copy with each of three signed and notarized originals of the amended application.
o Service List: One copy to each addressee of record as of December 31, 1980.