ML20054B672
| ML20054B672 | |
| Person / Time | |
|---|---|
| Site: | National Bureau of Standards Reactor |
| Issue date: | 04/12/1982 |
| From: | Lochstet W PENNSYLVANIA STATE UNIV., UNIVERSITY PARK, PA |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0877, RTR-NUREG-877 NUDOCS 8204190048 | |
| Download: ML20054B672 (4) | |
Text
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T H E P ENNS YLVA NI A S T ATE U NIV ERSITY 1(M DAVLY LAlloR ATORY UNIVI RslTY PARK, PLNNSYLVANIA 16x02 ol colkge of science 12 April 1982
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Dear Director:
Encloced are my comments on the Draft Environmental Statement related to license renewal and rower increase for the o
National Bureatt of Standards Reactor, NUREG-0877.
Please note that the evaluation nresented here does not necessarily reflect the orinion of the Pennsylvania State University.
I hore t'at these connents are used in develoning the Final Environmental Statement. lould you also plence send me a copy of that Final ElS when it is available.
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Sincerely, WJbb W Y l
Un. A. I,ochstet, Ph.D.
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8204190048 820412 PDR ADOCK 05000184 As iot4L opponresuY rsiu R%In D
The Long Term Consequences of Operation of NBS Reactor by William A. Lochstet, Ph.D.
The Pennsylvania State University
- April 1982 The Nuclear Regulatory Conmission (NRC) has attempted to meet its responsibility under section 102 of the NEPA by the Draf t Environmental Sta tenent NUREG-0877.
Unfortunately, the Draft does not meet the requirement in at least three asnects.
These are the imnacts of releases of Argon-hl, Tritium, and the uraniun fuel cycle used.
It is suggested in table 4.1 that 1600 Ci/yr of argon-61 are exnected to be released. It is shovm that this will nroduce concentrations below maximum permissible concentrations (MPC) and therefore dismissed.
Concentrations below npc do have an environmental innnet and must not be dismissed as such.
One imrortant result of the Lewis APS study of reactor safety i
( Reviews of Vodern Physics, Summer 1975) is that if a large ponulation is exnosed to a small doso, the impact can be quite l
large and significant.
l The situation with the projected release of 900 Ci/yr of tritium ( Tabl e 4.1) is much the same. The health impacts should be evaluated numerically as for Argon-Al.
In addition the possibility of getting denosited onto the ground and getting into surface or groundwater should be discussed.
In particular, what fraction will end un in the DC water supnly described in section 2.2.
The evaluation of fuel supnly and disposal is inadeounte.
The amount of fuel necessary is not stated. The total fuel, and the total amount of ore necessary to be mined for it should be presented.
In addition the emissions of radon from these ores
- For identification nurposes only.
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April 1982 muss be considered for the full anount of time that the.,e materials are radioactive.
Since the major constituent of the ore is Uranium-238, the times necessary are in the billions of years.
The curie content d
the srient fuel is not explicitly stated in the Draft.
The environmental innact of this reprocessing and disposal should be evaluated numerically.
Th e impa ct ' does not ston when the spent fuel leaves the site boundry. Tre inelied reprocessing and disposal must be considered. It is imnortant to notice the impact of long lived products in the waste, particularly lodine-129. This isotope should be evaluated over the entire world ropulation for millions of years.
I trust that these comments will be usc ful in prenarita; an adequate Final Statement.
Lochstet
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d Unisersity Park. Penn9hania 16SO2 Director, Division of Licensing U.S. Iiuclear Regulatory Commission IETIRE RECEPT T a shinr, ton,
D.C.,
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