ML20044B707

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Partially Withheld Commission Paper Informing Commission of Denial of 790427 Request for Enforcement Action
ML20044B707
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 03/31/1980
From: Malsch M
NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:
Shared Package
ML19290F683 List:
References
FOIA-92-436 SECY-A-80-044, SECY-A-80-44, NUDOCS 9303030164
Download: ML20044B707 (24)
v • d • e


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UNITED STAf ts NUCLEAR REGULATORY CoMM!5SION ADJUDICATORY ITE6i SECY-A-80-44 irch31.1980_

COMMISSIONER ACTION For:

The Co=missioners Martin G. Malsch From:

Deputy General Counse'

Subject:

DIRECTOR'S DECISION UtIDER 10 CFR 2.206 (COMM0 WEALTH EDIS0N COMPAfrf)

Facility:

Zion Station, thics 1 and 2 To inform the Cornission of the denial pf

Purpose:

a recuest for enforce =ent actio twhich./

f Review Time Expire s :

April 9,1980 (as extended)

Discussion:

Sy letter dated April 27, 1979, Ms. Catherine Quigg, on behalf of Pollution and-Environ-cental Problems, 'Inc. -(PEPI), requested-the NRC to prepare ari Environmental-Impact State-cent (EIS) on the use and storage of high burnup nuclear fuel at Zion. 1/

PEPI's request was based on the NRC'li approval on March 7, 1979 of amendments to Zion Units I and 2 to allow the reinsertion of four fuel assemblies in Unit 2 for a c:aximum of two additional fuel cycles (beyond the normal three fuel cycles).

PEPI requested the EIS to provide information which it thought the

"': 7ta in t!.k rad a: e. Jed Public needed because of the following factors i t: ~ a m e '.. t :.u n w,.:.., m ti n associated with the high burnup fuel:

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y (1) greater fission Fas releases from nuclear reactors (2) increased fission gas releases from spent fuel pools due to increased corrosion:

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In a letter dated March 6,1980, lis. Quigg, on behalf of y

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PEPl. petitioned the Co= mission for rulemaking on the generic dP impacts of high burnup fuel.

This petition is now befora 3

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(3) inapplicability of previous governnent research based on " low burnup fuel" in pre-dicting the behavior of "high burnup fuel" in pool storage and (4) greater radiological impact in reactor and spent fuel pool accidents.

Pursuant to 10 CFR 51.5 the staff had pre-i pared an environmental impact appraisal (EIA) and a nego*ive declaration for the amendments, concluding that an EIS was not warranted because the action would not significantly affect the quality of the human environment.

Based on the EIA and the reasons in his denial, the Director decided that a full EIS was not required by any of PEPI's stated i

concerns and denied its request.

On the first issue, the staff found that although the use of the four spent fuel assemblies in extended burnups could result in greater fission gas. releases,_ the increase in releases would not be.significant.

In support of this finding the Director cites the fact that-- only -2.1% of the assemblies in-the core would be irradiated to the extended burnups; they will be used in a low thermal stress section of the core; there are no design changes in these four assemblies from prior ones irradiated at Unit 2; and they will be closely examined before their use in the fourth and fifth cycles.

On the second issue raised, that the in-creased corrosion due to higher burnup could lead to higher radioactive enissions in the spent fuel pool, the Director believes that the control of the coolant chemistry required by the current license is sufficient to keep any increase in corrosion to a negligibic i

amount.

In support thereof, the Director l

cites the fact that the fuel bundles at the Shippingport nuclear reactor irradiated for 12 years resulted in less corrosion than the amount of corrosion that could pose a problem at Zion.

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In response to PEPI's assertion that the existing government research based on " low burnup fuel" is inapplicable for predicting the behavior of "high burnup fuel," the i

Director explained that limited data on higher burnuo fuel is available and was used to support t:1e finding that use of the proposed test assemblies would present no significant problems.

He noted, however, that the current data base would not support a complete fuel reload of extended burnup fuel and that a detailed safety review will be required by the NRC before approving' of a full reload.

PEPI's final concern relates to the effect on loss of coolant accidents due to the use of higher burnup fuel.

The Director's analysis showed that the increase in long-lived radionuclides would be insignificant compared to the total amount of fission noble gases in the fuel.

Thus the pottntial consequences of the accidents given in the Safety Evaluation Reports (SER) dated October 1972 and March 29, 1979 for Units l'and 2 also encompass the l

effect of using the four fuel assemblies for extended burnups.

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Recommendation:

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I Martin G. Malsch i

1 Deputy General Counsel Attachments:

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Director's Decision 2.

Letter from PEPI

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Comissioners' comcats should be provided directly to the Office of the Secretary by c.o.b. Tuesday, April 8,1980.

Comission Staff Office coments, if any, thould be submitted to the Coc.issioners NLT April 4,1980, with an inforr.ation copf to the Office of the Secretary.

If the r

paper is of such a rature that it require!. additional time for analytical review and coment, the Conrnissioners and the Secretariat should be apprised of when coments may be expected.

DISTRIBU1!ON ComissTeners Comission Staff Offices Exec Dir for Operations ACRS Secretariat

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April 4, 1980 C 0 R R E C T I O N N O T I

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TO ALL COPY HOLDERS i

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SECY-A-80 DIRtCTOR'S DECISION UNDER 10 CFR 2.206 (COMMONWEALTH EDISON COMPANY)

(COMMISSIONER ACTION ITEM).

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ATTACHMENT 1 0F THIS PAPER WAS NOT DUPLICATED PROPERLY. A REPLACEMENT IS PROVIDED-

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Dear Hs. Quigg:

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This letter is' in response to.)eur petition on behalf of Pollution and E

Enviromental Problems, Inc. requesting that the Directer of Nuclear d

Reteter Regulation order the preparation of a full envirorriental impact 3

statenent en Anendments Nos. 44 and 41 to the cperating licenses of Zion Station, Units 1 and 2.

5 The HRC Staff has reviewed the infomation relative to your petition..

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~=4 We fird no basis for preparing such a stataent.

For the reasons set forth in the enclosed " Director's Decision Urder 10 CFR 2.206,* your request is E

hereby denied.

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_=i A copy of this decision will be placed in the Cocr:ission's Pdic Document a

Rom 1717 H Street, N.V., Washington, D. C.

2C555, and at He Waukegan 3

Public Library,128 North County Street, W1utegan, Illinois 60085 A copy will EE also be filed with the Secretary.of the Ccenission for' review by the Cocotssion in accordance with 10 CFR 2.206(c) of the Cornission's regulations.

m Enclosed for your inforr.ation is a copy of the notice that is being filed with the Office of the Federal Register for publication.

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Sincerely.

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Director's Decision Under

Ei iiis 10 CFR 2.206 2.

Notice.

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UNITED STATES OF A': ERICA NUCLEAR REGULATORY C0:7.lSS10N 0FFICE OF NUCLEAR REACTOR REGULATION HAROLD R. DENTON, DIRECTOR i

Tn the lhtter of 1

Docket Nos. 50-295 h

50-304 2l (10 CFR 2.206)

CO: VON"EALTH EDISON C0.PANY l

(ZionStation, Units 1&2)

DIRECTOR'S DECISION UNDER 10 CFR 2.206 1

By letter dated Acril 27, 1979, Ms. Catherine Quigg, on behalf of Poliution l

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and Environmental Problems, Inc. (PEPI), transmitted a request pursuant to iD CFR ?.205 for the preparat:en of an environmental impact statement on high burnup fuel at Zion Station, Units 1 and 2.

This request was predicated on the fact that on F, arch 7,1979, the Nuclear Regulatory Conmission issued f

Amendments Nos. 44 and 41, respectively, to Facility Operating License Nos.

4 DPR-39 and DPP-48.

The amendments revise Technical Specifications for Zion Station, Units 1 and 2.M These amend,ents wouls allow the reinsertion.of-a_.

maximum of four fuel assemblies previously irradiated in Unit 1 for a maximum

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of tuo additional fuel cycles (beyond the normal three fuel cycles) in Unit 2 to gain operating experience for ar. anticipated future extended burnup program.

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PEDI requested the preparation of an environmental impact statement to provide information which it thought the public needed because of the following l

factors associated with high burnup fuel:

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greater fission gas releases from nuclear reactors; 2.

increased fission gas releases frcm spent fuel pools 1

due to increased corrosion; If 1..endments 44 and 41 are attached as Appendix A.

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previous gevernnent research, based on " low burnup fuel" is useless in predicting the behavior of "high burnup fuel", and

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potential for greater radiological impact in reactor and spent fuel l

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pool accidents, Consistent with the National Environmental Policy I.ct of 1969 (Public Law I

91-190, 83 Stat. 852) and the Commission's regulations (10 CFR Part 51), an environ.

mental impact statement 2/ was prepared at the operating license stage of Units 1 and 2.

This statement addressed the range of environmental impacts associated witn the operation of,the Zion Station.

However, an environmental impact statement is not required to be prepared for every license amendment.

In this case, the Staff had prepared an environmental impact appraisal 3/ and negative declaratien S/

pursuant to 10 CFR 51.5 for the amendments, and had concluded that an EIS was not warranted because the action will not significantly affect the quality of the hur.an environment.

The negative declaration was published in the Federal Register on liarch 19,1979, (44_ FR 16504).

In the environmental inpact appraisal, the Staff compared the fission gas re-j lease from the extended burnup fuel assemblies in the Unit 2 core to the releases from the other fuel assemblies in the core.

It vas noted that operating Unit 2 2/

Final Environmental Statement Related to Operation of Zion Nuclear Fower Station Units 1 and 2. December 1972.

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Environmental Imoact Appraisal by the Office of !!uclear Reactor Regulation Supporting Amendment No. 44 to Facility Occrating ticense No. _CPR-39 and Anendment No. 41 to Facility Operating License No. DPR-48 dated f* arch 7, 1979.

The Appraisal is attached as Appendix B.

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flotice of Issuance of Amendnents to Facility Operatina Licenses and Negative Declaration dated liarch 7,1979.

The :otice is attached as Appendix C.

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with four spent fuel assemblies from Unit 1 could have greater fission gas releases due to an increase in the fraction of failed fuel in the core over that previously experienced. Ilowever, it was also noted, these increases are not expected to be significant because (1) only four assemblies in the core (2.1%) will be irradiated to the extended burnups; (2) the restrictions in the plant Technical Specifications e

require the four assemblies to be located in the core where the operating thermal i

stresses in the cladding are relatively low and where the thermal limits for cladding should not he apprcached; (3) there are no design changes in these four assemblies from cnes pre icusly irradiated at Unit 2; (4) the licensee will examine the four spent fuel assemb ies before their insertion in the Unit 2 core for their fourth cycle and will only irradiate them in a fifth cycle after these assemblies have demonstrated satisfactory fuel performance in the fourth cycle.

There is a possibility that increased corrosion {'or " crud") o'flh'e' spent fuil due to extended burnup could lead to higher radioactive emissions in the spent fuel pool. However, the facility's Technical Specifications carefully control crolant chemistry to control corrosion of the Zircaloy Cladding of the fuel rods.

S"ildup of " crud" should be negligible as long as coolant chemistry is controlled.

Extended burnup under such controls would add perhaps several thousandths of an inch of oxide to the existing oxide thickness due to corrosion. For example, the fuel bundles which were irradiated in the Shippingport nuclear reactor at pressurized water reactor conditions for 12 years (approximately 4100 calendar days of operation) had a maximum corrosion thickness of 0.5 mil (5 x 10-4 inches).

Corrosion thicknesses even 10 times this value would not affect the integrity of the cladding as a fission-gas barrier or interfere in arty way with safe handling of the fuel in the spent fuel pool.

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i PLPI has stated that preyicus government research based on "lo.y b"rnup fuel" is "uscless" in predicting pool storage behavior of extended burnup fuel.

Tha t statement is incorrect. First of all, the term " low burnup fuel" is misleading, as the nomal burnup rate is not a low burnup.

Fuelwiththisburnup(33,000 ILID/MTU) I as been in the reactor for at least three cycles of operation, which h

is approximately three years. The fuel pellet has swelled, it has released a

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significant amount of fissien-gas, and the cladding mechanical properties have I

reached asymptotic va ses due to irradiation.

Data is available on the behavior of higher burnup fuel.

Alttough this data base is not large, it shorts no signiff-cant problers in reachir nigher burnups than the present ifmits.

llhile.this data base sould not support a complett fuel reload of extendeu surnup fuel, it v

does provide sufficient confidente to allow lead test assemblies to operate for tiro cycles in nonlimiting core positions.

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h'or:ever, before a full reload of assembif es of a new design is approved by the Comission a detailed safet'y review will be required. Part of this review will t

include the presentation of data to show that the fuel assemblies will reet all the requirements for safe operation of fuel in a licensed reactor.

Test assemblies, such as the assemblies authorized at the Zion Station, often, provide a significant enount of these data.

PEPI was also concerned with the radiological impact of high burnup fuel' in the event of loss of coolant accidents. 'The potential impact on safety for four extended burnup fuel assmblies is not greater than that of the ether fuel s

bundles in the Unit 2 core since all fuel bundles are governed by the same safety cr'teria.

In the envirorcr. ental impact appraisal, the Staff addressed Sf

'e';awatt days /!!etric ton uranium.

the ef fect of the four higher burnup fuel asse'blies on the potential consegacnces and the environmental impacts of postulated accidents.

Increasing the burnup of fuel asserblies increases the radioactivity within the fuel assemblies.

The amount of radioactivity of a specific radionuclide in the f.31 increases with fuel burnup until it reaches an asymptotic

  • value. The nagnitude of feel burnup where the ndfoactivity of a specific radionuclide reaches its asymptotic value depends on the halflife of the radionuclide. The short-lived fission products will have reached equilitrium levels at lower burnups and will not be affected.

Irradiating fuel to extended burnups will increase the amount of icng-lived fission products in the core.

The only significant long-lived radionuc116 with respect to potential consequences of the design basis accidents is the noble gas Krypton 85.

Extending burnups of the four assemblies up to about 44,000 Mr/D/MTU (cne added cycle) will not increase the amount of Krypton 85 which was a umed in the fuel at Zion 2 for the postulated design basis accidents. The increase in the amount of Krypton 85 in the four fuel assemblies from 44,000 lHD/iifli, to 55,000 Ks/RT

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(the second added cycle) is not significant compared to the total amount of fission nobic gases in the fuel.

These conclusions are based on the Staff's 'tndep?ndent calculations of the fission gas release from damaged spent fuel and the radiological '

impacts of the postulated accidents.

Therefore, the potential consequences of the accidents given in the Safety O or Units 1 and 2 Evaluation Reports dated Octow 1972, M and furch 29, 1979 f

will not change due to four fuel assemblies in the core being irradiated to burnups up to 55,000 KlD/tiTU.

6f Safety Evaluation of the Zion Nuclear Power Station Units 182, attached as Appendix D.

-7/ Safety Evaluation by the Office ef flu-lear Reactor Regulation Relating to the iodification of the Spent Fuel Storage Pool, attached as Appendix E.

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Cated on the (nvicer, mental impact appraisal dated 'liarch 7,1979, and the reasons set forth at:ve, I have determined that Amendments 44 and 41 will not sig-nificantly af fect the quality of the human environment and that a full environmental Therefor e, the request of PEPI is denied. /

ii. pact statement is not warranted.

A copy of this decision will be placed in the Cannission's Public Document Room at 1717 H Street, N.W., llashington, D. C.' 20555 and the local Public Document Room for the Zion Station located at Zion-Benton Public Library, 2600 Enmaus Avenue, Zion, Illinois 60099.

A copy of this document will also be filed with the Secretary of the Commission for its review in accordance with 10 CFR 2.206(c) of the Commission's regulations.

In accordance with 10 CFR 2.205(c) of the Car. mission's Rules of Practice, this decision will constitute the final action of the Commission 20 days after the date of issuance, unless the Commission on its own motion institutes the review of this decision withis.1 hat time.

A" liaroldTTsenton, Director Office of Huclear Reactor Regulation Dated at Bethesda, Maryland this 13th day of Karch,1980.

Attachments:

Appendix A - Amendments 44 and 41 Appendix B - Environmental Impact Appraisal by HRR (3/7/79)

Appendix C - Notice of Issuance of An.endments to Facility Operating Licenses and Negative Declaration (3/7/79)

Appendix D - Safety Evalution of Zion Nuclear Power Station, Units 162 AppindixE-SafetyEvaluationbyi:RR - Modification of Spent Fuel Storage Pool PEPI also questioned why prior notice was not given before issuing the amendnens j(

The amendnents did not involve a significant hazard consideration and, thereforg the amendments were post-noticed.

See also, Appendix D.

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ATTACFJ:ENT 1 n

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F.s. Catherine Quigg Research Director Pollution and Envirorcental Probleos, Inc.

Box 303 Palatine, Illinois 60069

Dear P.s. Qaigg:

This letter is in response to your petition on behalf of Pollution and Envircr: ental Probleras, Inc. requesting that the Director of flueleer Re. actor Regulation order the preparation of a full environnental irnpact stairent en A en6ents Ibs. 44 ared 41 to the operating licenses of Zion Stati:n, Units 1 and 2.

The HRC itaff has revicwed the inforr.ation relative to pur petition. We fird r.o Lasis for preparing such a statteent.

For the reasons set forth in the enciesed " Director's C. cision Under -10 CFR 2.206,* your request is hereby denied.

A copy of this decision will be placed in the Comission's Public Doctnent Ro:rs,1717 H Street, N.W., !4ashington, D. C.

20555, and at the Waukegan Public Litrary,128 lbrth County Street, Wautegan, Illinois 60085. A copy will also be filed with the secretary.of the Comission for review by the Comission in accorda"ce with 10 CFR 2.206(c) of the Ccmission's regulations.

Erelosed fcr yoJr inforr.ation is a copy of the notice that is being filed with the Office of the Federal Register for publication.

Sincerely, Cf.dnircedty it t. De.tas.

Harold R. Denton, Director Office of Nuclear Reactor Regulation Erclosures:

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Director's Decision Urder

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041TED ST ALES OF A"EklCA NUCLEAR REGULATORY CD:'.115510N 0FFICE OF NUCLEAR REACTOR REGULATION HAROLD R. DENTON, DIRECTOR fn the l'atter of p

Docket Nos. 50-295 50-304 CDi'0m EALT11 EDISON CW.PANY

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(10CFR2.206)

(Zion Station, Units 1&2)

A DIRECTOR'S DECISION UNDER 10 CFR 2.206 By letter dated April 27, 1979, Ms. Catherine Quigg, on behalf of Pollution and Envircnmental Problems, Inc. (PEPI), transmitted a request pursuant to 10 CFR 2.206 for the preparation of an envirore. ental impact statement on high burnup fuel at Zicn Station, l'aits 1 and 2.

This request was predicated on the fact that on March 7,1979, the Nuclear Reg 11atory Commission issued Amendments Hos. 44 and 41, respectively, to Facility Operating I..icense Nos.

OPR-39 and DPPA B.

The amendments revise Technical Specifications for Zion Station, Units 1 and 2.M hese amendments would allcw the reinsertion.of a_

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maximum of four fuel assemblies previously irradiated in Unit 1 for a maximm of two additional fuel cycles (beyond the normal three fuel cycles) in Unit 2 to gain operating expectence for an anticipated future extended burnup program.

PEPI requested the preparation of an environmental impact statement to provide inferration which it thought the public needed t>ecause of the following factors associated with high burnup fuel:

1.

greater fission gas releases from nuclear reactors; 2.

increased fission gas releases from spent fuel pools due to increased corrosion; y

1. endments 44 and 41 are attached as Appendix A.

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with four spent fuel assemblies from Unit 1 could have greater fission gas releases due to an increase in the frat. tion of failed fuel in the core over that previrusly experienced. Itowever, it was iso noted, these increases are not expected to be 1

significant because (1) only four assemblies in the core (2.1%) will be irradiated to the extended burnups; (2) the restrictions in the plant Technical Specifications require the four assemblies to be located in the core where the operating thennal stres,ses in the cladding are relatively low and where the thermal limits for cladding should not be approached; (3) thera are no design changes in these four assemblies from ones previously irradiated at Unit 2; (4) the if censee will examine the four f

spent fuel assemblies before their insertion in the Unit 2 core for their fourth cycle and will only irradiate them in a fifth cycle after these assemblies have denonstrated satisfactory fuel performance in the fourth cycle.

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There is e possibt.ity that increased corrosion (or " crud") oT thelpenf(Oel"~~

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due to extended burnup could lead to higher radioactive emissions in the spent fuel pool. However, the facility's Jechnical Specifications carefully control coolant chemistry to control corrosion of the Zircaloy Cladding of the fuel rods.

Buildup of " crud" should be negligible as long as coolant chemistry is controlled.

Extended burnup under such controls would add perhaps several thousandths of an inch of oxide to the existing oxide thickness due to corrosion.

For example, the fuel bundles which were irradiated in the Shippingport nuclear reactor at pressurized water reactor conditions for 12 years (approximately 4100 calendar days of operation) had a maximum corrosion thickness of 0.5 mil (5 x 10-4 inches).

Corrosion thicknesses even 10 times this value would not affect the integrity of the cladding as a fission-gas barrier or interfere in any way with safe handling of the fuel in the spent fuel pool.

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the effect of the four higher burnup fuel asse-blies on the potential consequences and the environmental impacts of postulated accidents.

Increasing the burnup of fuel assemblies increases the radioactivity within the fuel assemblies.

The amount of radioactivity of a specific radionuclide in the fuel increases with fuel burnup until it reaches an asymptotic value.

The magnitude of fuel burnup where the radioactivity of a specific radionuclide reaches

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The short-lived its asymptotic value depends on the halflife of the radionuclide.

fission products will have reached ecullibrium levels at lower burnups and will not be affected.

Irradiating fuel to extended burnups will increase the amount of long-lived fission products b the core.

The only significant long-lived radionuclide with respect to potential consequences of the design basis accidents is the noble gas Krypton 85.

Extending burnups of the four assemblies up to about 44,000 K!D/MTU (cne added cycle) will not increase the amount pf Krypton 85 which was assur,ed in the fuel at Zion 2 for the postulated design basis accidents.

The increase in the

_ amount of Krypton 85 in t.he four fuel assemblies from 44,000 IND/Imi, t8~55,000 WD/MTV (the second added cycle) is not significant compared to the total amount. of fission,

noble gases in the fuel.

These conclusions are based en the Staff's independent calculations of the fission gas release frcra damaged spent fuel and the radiological impacts of the postulated accidents.

Therefore, the potential consequences of the accidents given in the Safety O or Units 1 and 2 Evaluation Reports dated October 1972, N and l' arch 29, 1079, f

will not change due to four fuel assemblies in the core being irradiated to burnups up to 55,000 K!D/117U.

6f Safety Evaluation of the Zion Nuclear Power Station Units 182, attached as Appendix D.

7/ Safe _ty Evaluation by the Office of f:uclear Reactor Regulation Relating to the :'.odification of the Spent fuel Storace Pool, attached as Appendix E.

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UNITED STATES OF A" ERICA NUCLEAR REGULATORY C0iV;1SS10N OFFICE OF NUCLEAR REACTOR REGULATION IMROLD R. DENTON, DIRECTOR In the Matter of

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Docket Nos. 50-295 and 50-304 C0".MOL'EALTH EDISON COMPANY

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(ZionStation, Units 1&2)

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(10 CFR 2.206)

NOTICE OF ISSUANCE OF DIRECTOR'S DECISION UNDER 10 CFR 2.206 By letter dated April 27, 1979, Pollution and Environmental Problems, Inc.

(PEPI) transmitted a rec,uest pursuant to 10 CFR 2.206 for the preparation of an environ. ental impact statement en Amend.ents Nos. 44 and 41 to the operating Ifcenses at Zion Station, Units 1 and 2.

After a review of the relevant information, the Directcr has detemined that there is no basis for issuing an environmental impact state ent.

Accordingly, the request by PEPI has been denied.

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Copies of the Director's decision are available for inspection in the- --------

Comission's Public Docment Room,1717 H Street, N.W., Oshington, D. C. 20555, and at the Waukegan Public Library,128 North County Street, Waukegan, Illinois 60085.

A copy of this decision will also be filed with the Secretary of the Commission for review by the Ccenission in accordance with 10 CFR 2.206(c) of the Comission's regulations.

As provided in 10 CFR 2.206(c), this decision will constitute the final action of the Comission twenty (20) days after the date of issuance, unless the Comission on its own rotion institutes review of this decision within that tire.

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. Denton, Director Office of Nuclear Reactor Regulation Dated at Bethesda, Maryland this 13thday of March,1980

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Mr. Hereld Denten, Dir e cter i I4WONMENTAL Office of Nuclear Resetor Regulatiets U. S. Wele4.r Re gulatory Ce=:'s eien y

Yaehingten, D.C. 205L J

JROBiEM$

Keed for Environ = ental Impact Statement on Enjer Tederal Actient The Gramting of Eigher Tuel Bur =ap Requeets

.RE:

' Box 309

?alatine, IL 60067 Dear ur. De= ten Vith the decision net to reprocess, the federsi governme=t and the utilities 1 rant to us e core urar.ius in existingTo th

[L lightwater reacters.

Energy (DOE) has initiated ecst-chtred high buruup projects

. ~

The DCE

' L O~~~~ ~ L~

with Duke Feuer Co. and Arks sas Peser & Light.

is s. lee supporting two pellet elad interaction (p.e.i.)

U.#5C'.7 projects = ith Cor.. cer Pev er Co. ead Cc::enrealth Edien Co e,[ [ ~

g y ;-g y a perr.it to Cc:Ed allowing d

... c

.r. o.

On March 7,1979 the @Zien spen.-f:r!~a er e=blies to exte:ded

  • ' e the irradie. tion of feu-Zion's burcups in Zion 2, up to about 53,C00 UD/rU.

. ~

....u i r., a f-,,.**

ihe:e hae beee re ex;erietee 38,C00 GDATJ. The KRO adzit:

.xn o n.

with full size fuel asse:blies irradiated to these burnups,

';l'; C." d - ~*,,,

but nenetheless issued a. Negative Declare.tien stating the

.<...e higher t.u cups weu.1d have cc appreciable entirec=e=tal i= p P4 J,'r..~ "

.w These experinents and ethers are being conducted 4 thout an C'"~ ~ U.'C Envirer= ental I= pact State:ent, even though they could cause

m.. -

effect6 on the hazan-

"ed C O*c'." " '

significar.t leng e d short ter:Accordi=g to the EEFA,

  • ajor Fede signifiezntly ffecting the quality of the hu=en envircr=e=t e nv i rcr= e-t.

require 's detailed Envire== ental Impect Statement (EIS In accordance with the responsible goverr. e=t efficial.10 CTR, is.rt 2 (2 j

request for a full Lis en high hrtup fuel, kth in the reacter and sub segae=tly as a spert fuel warte.

The fo11 ewing specific eec=ents relate to pote::tial signif d censtitute effects of high turmup en the h.:=e.n enviror=ent an the tssis fer my regaesta

c. clear recetors.

Greater fission gas releas ssfre:According to Pa 1.

ing 8...eec=ents fre= the re s earch ce== un lightwater reactor fuela (LG), particularly above 30,C00 WD/C%

Develop =ent, Diviaien of melear Feser, DCE, also

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projects greater fission gas releases as a side-effec

/0 Vj of higher fuel bu: :vp ti es.

7905020 @

THROUGH I D U C A T I O N --

R f 5 7 01 A T I O N

_ ___ r u v i t c N u t N T /. t4

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In its Safety Evaluation Report en incressed fuel burrrap at Zien,- the h7C concedes that "Irradisting fuel to extended bur:r.rf s vill incress e the a-cu :t of long-lived fis sio product s and 8in the core over that previously experianced."

The KRC although the licensee may release core state s a!here fo r e, radioactivity from rion 2 during this extended burnup progran ce=plience with plant technical than during previous cycles, specifications will =sintain concentrations of radioactivity within the allow ed limits.'

In other words, the 530, without notifying the pblic of the quantity or kind of ir.:reased radioactivity rel eeses frem the s decided en our behalf that this increased amount Station, ha The h3C cade this of radioactivity is acceptable to us.

decision unilaterally nitheut netifying the public or without K e call to question hensfit of public heerings' or~ input.

"ecision-:aking process.

the de=ocrsey and ethics of this The public is entitted to know quentitatively and qualitatively the radionuclide esistiens attributable to higher burnup, in The benefits to the utilities of adv ance o f tho s e rel eas e s.

greater uraniu= utilization should not be the deter =ining factor in higher burrap a;provals.

Higher

2. Increased fission ga s releases frem apent fuel peels.

Dr.

irradiation demage to fuel cay occur with higher burnup.

Teter 1.ang states that current 1.KRe have not experienced

' fuel' rods.

._ arcsesive corrosion on the outside surface of the

'If burn.tps and-residence times He suggeetsi hewever,- thet are increased signifiesctly, it is pesible that a thicker layer of oxide end crad deposits say develop, raising the oxide cladding interfs.ca te perature eufficiently to< accelerste co rro sion. '

I cubit that the above-etate possibility of fuel corrosion raises serious questions regsrding the quality of spent fuel If the fuel is more corrodeds produced-under higher barnup; the radioactive asissiens to and frem the spent fuel pool sad subsequently to the atzesphere and public will be higher.

The pblic, in the sbsence of an-EIS, is being askad to accept roles so s.from spent fuel pools the risk of grester fission gs:

in the future - without even an setinate of the quantiti and cakeup of tte se emissiens or their effects en the hu=sn cnyironnent, Freduction of inferior grade nuclear spent fuel which ca.n lead 8

Frsrvious government to long-ters enviror:=ents1 hanards.

research, including M?.EG-0404, is based on low burnup fuel.

It is useless in predicting pool storage behavior of high barn-up fuel.

The pblic is currently being asked to accept graatly increa ed s

a=ounts of spent fuel at the sites of r:uelear resetore seress Tr., NRC's the country, eften in highly populated areas.

f

M.

7 t

t-h"URTir-0404 as sures citic ens that ' At-ree cto r spent N el j

ste rsge can be incretend...with no sacrifice to public heelth j and s erety.' and 'N environnental impact of the proposed increas ed at-reactor spent fu el storage was negligible... $

based on existing pool water technology.'

l It should b e pointed out that exiating pool water technology and research is based on low burr:ap fuel.

A.B. Jennson. Jr.,

in his ' Behavior of Spent Nuclear Fuel in Water Pool Storage,* :

not es the me.ximum Wrnup of stored corz:ercial' fuel is,200 { WD/E"U tad for military J.000 DD/MTU (E.0F at Idaho).. The i E0's projections for saff storage of spent fuel are tiras experience beyond }6,000 WD/ pool' storage experience; wit based on limited lew brnup MTU including cilitary. ~ rhe spent fuel product of the Nture, if high burnup is per=itt ed on a vide r eale,- i s of ur.knoen quality and isi anticipa*J by some scientists to have decidedly peerer structural sharseta istics and integrity-ths.n present Icw turnup specimene. As the EC grants parrission to nors and mere utilities to go to higher burnup, the quality of spent fuel will probably be j degraded; at best it ir u.knern. j The lew brnup spe.t fuel storege experience at the Morrie Opt. ration and thLt re9 earched by A.I. JohnseD, J:

  • of Battelle l Laborate.y becones irreleve.nt as a basis for spent fuel beherie r prediction.: as the United States inves toward higher )

bu rnup. 1 submit that K' REG-0404 should be declared null s_nd void as a docu=e t en which to base spent fuel ss.fety and enviran= ental considerations.. 3efere proceeding with reactor-scale experiments that' eculd endanger their heslt.h and environnent, the public is entitled to scientific projectiens sind s.nalyses of high braup. These should include, bt not be limited to, riska of pre:sature red failure, entier.tions of increased fission' gas releases and fuel rod internal pressure, likelibeod of corrosien and hydriding of cladding and structural =ater1&Is and expectation; o f f.:e1 a s s embly di.=s a sienti and structural changes. Ne shou 16 be given a reaso:mble. explanation of the reasons shy the above research can not be carried en in industry and governnent laborateries, before proceeding with ex;erimentatien in the hu=ca environ =ent.

4. Potential for greater radiological inpact in reactor and spent fuel pool accide.ts.

The projected inpact of high burnup on r reactor and spent f.nel poel seeidects has not been reveales-to the public. The inpaet of larger radiosetive gas rolesses from high Wrnup f.:els in a-less of coolant accident 'either ~ in the reactor or the spent fuel pool should be an important consideration in allowing a utility per=ission for higher b rr.up. According to R. O. L' eyer, Director cf $afety Systems, Office of Nucl ear ?.eector *.egulatione, U.S. SCs '...the 23

( ( has ree. son to b eliev e that the plent s af ety analyses under;redi(- fi s s ie n ga s r e l es s e at hi gh burnup s. " "he public is entitled to-kns, the corrected esticates for incree se in fission gas release dae to high turnup) especially since all. indications are that fission gas release is a direct - functien of burnup. - In eenelusicor-I protest r.str enly the.EC's negativt appraisal of the envirorcental effe:ts of high harnup -- but also the fact that prier public notice of the EC's action was not given. :: Ny assesesent of the erwiron=estal 13;4ct is at variance with the EC. I urgently regaest that you receasider and prepare m full and comprehensive EI3 on high bercup in lightwater reactors in order to better serve the public health and. safety. Sinc erely yours, Q n ' Catherine Quigg, re search director Pollution I Enviror.= ente.1 Froblems, Inc. Box 509 Palatine, Illinois 60067 312/ 3S1-669 5 ces President Ji. _y Carter, and to Meesre. Douglas Co rtle (Ad:iais-trater, US-EPA), Jacob D.=elle- (Chair:s.n, Ill. Pollution Centro) Bd.), Joseph Hendrie (Chair ac, EC), Charles Percy (US So.atee frc= lilinois), Adlai Stevensen (US Senator frcna Illinois), Ja=es S chle singer, (Sec retary,' DOE), Willian Scott (Attorney.. Gen. of Ill.), Philip Crane (US Cengress:En from Ill.), Ja=es Thos; son (Gov. et Ill.), end Charlea farren (Chairman. Ptseid eG Council on Envirec= ental Cuality) f F m + - a m .}}

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