ML20065T983
| ML20065T983 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 11/01/1982 |
| From: | Cochran T National Resources Defense Council |
| To: | |
| Shared Package | |
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| References | |
| NUDOCS 8211030315 | |
| Download: ML20065T983 (40) | |
Text
_
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kkha UNITED STATES NUCLEAR REGULATORY COM BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
)
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UNITED STATES DEPARTMENT OF ENERGY
)
PROJECT MANAGEMENT CORPORATION
)
Docket No. 50-537 TENNESSEE VALLEY AUTHORITY
)
)
(Clinch River Breeder Reactor Plant)
)
)
TESTIMONY OF DR. THOMAS B. COCHRAN Part III (Primarily Intervenors' Contention 6(b)(1) and (3))
i DATED:
November 1, 1982 8211030315 821101 PDR ADOCK 05000537 T
pop
m s O.1:
Please identify yourself and state your qualifications to present this testimony.
A.1:
My name is Thomas Brackenridge Cochran.
I reside at 4836 North 30th Street, Arlington, Virginia 22207.
I am presently a Senior Staff Scientist at Natural Resources Defense Council, Inc.
My background and qualifications i
have been submitted in previous testimony in this proceeding (Tr. 2870-71, Cochran).
0.2:
What subject matter does this testimony address?
A.2:
This testimony addresses primarily Intervenors' Contention i'
6(b)(1) and (3), which questions the adequacy of the Staff's analysis of the environmental impacts of the CRBR fuel cycle.
Some of my testimony here also relates to contentions 1-4, 6(b)(4), and 7(a), namely pages 7-20 herein.
As amended by the October 26, 1982, Order of the i
Licensing Board, Contention 6 is summarized as follows:
1
- 6. The ER and FES do not include an adequate analysis of the environmental impact of the fuel cycle associated with the CRBR for the following reasons:
b) The analysis of fuel cycle impacts in the ER and FES are inadequate since:
- 1) The impact of reprocessing of spent fuel and plutonium separtion required for the CRBR is inadequately assessed; l - -
.--_-,m,__,._.
l 4
' 3) The impact of disposal of wastes from the CRBR spent fuel is inadequately assessed:
My testimony addressing Intervenors' contention 6(b)(4):
The impact of an act of sabotage, terrorism or theft directed against the plutonium in the CRBR fuel cycle, including the plant, is inadequately assessed, [as] is the impact of various measures intended to be used to prevent sabotage, theft or diversion.
is addressed in Part V of my testimony, provided separately.
Q.3:
What is the Staff's estimate of the radiological health effects associated with the CRBR fuel cycle?
A.3:
The Staff estimated that the dose to the whole body from annual operation of the CRBR supporting fuel cycle would be about 170 person-rem, of which 140 person-rem annually is due to reprocessing.CRBR fuel.
(" Draft Supplement to Final Environmental Statement, CRBR," NUREG-0139, henceforth "DSFES," pp. D-30, D-33.)
0.4:
Do you agree with this estimate?
A.4:
No, I do not agree with the Staff assessment of the risks associated with reprocessing, fuel fabrication, or waste i
management.
Q.5:
Why do you believe the Staff's estimate of the dose i
commitments from reprocessing CRBR fuel, 140 person-i
e,
rem / year, is incorrect?
A.5:
There are several errors and/or unrealistic assumptions in
~
the Staff's estimate of 140 person-rem from reprocessing annual CRBR fuel requirements, due tot a)
Staff's failure to accurately describe the CRBR fuel cycle and realistically estimate (or conservatively bound) risks associated with reasonably foreseeable fuel cycle alternatives (DSFES, pp. D-1 to D-4, and Staff Response to Interrogatory I.2, 27th Set, Oct. 1, 1982, p. 3);
b)
Staff's failure to consider the environmental dose commitment (EDC) to persons beyond the U.S. boundaries (DSFES, p. 5-18; Deposition of Staff witness Branagan, Oct. 13, 1982, p.
14);
c)
Staff's failure to consider the environmental dose commitment (EDC) beyond 100 years (DSFES, p. D-29 ; --
Deposition of Staff witness Branagan, Oct. 13, 1982,
- p. 26-31, 46-47; Response to Interrogatory I.14.h, Staff Response to NRDC's 27th Set of Interrogatories Oct. 1, 1982, p. 27b);
d)- Staff's failure to report the dose to organs other than whole body (DSFES, Section D.2.4, pp. D-29 to D-33);
e)
Staff's failure to use current dosimetric and metabolic models (cf., Staff Response to Interrogatories i
l I.14.c and I.16.m, 27th Set, Oct.
1, 1982, pp. 27a and 29a);
l l
e r f)
Staff's superficial methodology for estimating the gaseous effluents of plutonium and other transuranics from fuel fabrication and fuel reprocessing plants (DSFES, pp.
4 D-9,
-14, -15);
g)
Staff's failure to consider environmental releases due to accidents at fuel cycle facilities (Deposition of Staff's witness Lowenberg, Oct. 12, 1982, p. 28);
h)
Staff's superficial methodology for estimating potential environmental releases from the proposed high-level radioactive waste (HLW) repository (DSFES, Table D.4, fn B,
- p. D-7; Deposition of Staff Witnesses Branagan and Boyle, Oct. 13, 1982, pp. 37-44).
Q.6:
Where is the Staff's description of the CRBR fuel cycle set forth?
A.6:
Section 5.7.2.7 (pp. 5-15 to 5-17) and Section D.1 (pp.
D-1 to D-4) of the DSFES.
i Q.7:
Why doesn't this description fully and accurately reflect the reasonably foreseeable CRBR fuel cycle alternatives?
A.7:
As indicated in Figures AS.1 (DSFES, p. 5-16) and D.1 l
(DSFES, p. D-3), most of the specific facilities that are listed for the proposed CRBR fuel cycle do not now exist; they are hypothetical future facilities.
For example, the source of plutonium to fuel the CRBR has not been I
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. s established; whether and, if so, where CRBR spent fuel will be reprocessed has not been established; and the sites for interim high-level waste storage and for the final high-level waste repository have not yet been established.
The Staff has failed to analyze all reasonably fo'eseeable fuel cycle alternatives, including, for example:
a) providing the initial plutonium. fuel by reprocessing commercial reactor spent fuel at (i) Barnwell or (ii) the Savannah River Plant (SRP), or obtaining the initial l
plutonium from (iii) foreign sources (e.g.,
the UK);
b) as an alternative to the postulated " Developmental Reprocessing Plant" (DRP), using one of the existing chemical reprocessing facilities at SRP, the PUREX facility at Hanford, or a small facility built into the FMEP, for recycling CRBR fuel; c) using plutonium bred in CRBR in nuclear weapons; d) the potential unavailability of adequate plutonium to fuel the CRBR (ruled by the Board as beyond the scope of the LWA-1 proceeding).
All of these are possible alternatives and, considering the great expense to build new facilities, it appears quite likely that existing facilities may be used instead.
Yet none of these alternatives were considered.
Staff makes the bald assertion that the environmental
impacts of alternative fuel reprocessing plants to the DRP will be bounded by the impacts projected for the hypothetical DRP simply because DOE says it will be so in its Environmental Report.
Staff has done no independent analysis of DOE's claim because "[t]here is no basis for analyzing it."
(Deposition of Staff witness Lowenberg, Oct. 12, 1982, at 13-14.)
The Staff gives the same basis
-- that DOE says so -- for its confidence that DOE will comply with current guides and standards in the design for DRP or its alternatives.
(jgi. at 20.)
0.8:
Why is it important to know the source of the plutonium to fuel the CRBR?
A.8:
First, I believe there is insufficient plutonium to provide the initial inventory and first four reloads of the core, and consequently the CRBR will not be able to meet its programmatic objectives during its five-year demonstration period (ruled by the Board as beyond the j
scope of the LWA-1 proceeding).
l Second, the origin of the plutonium and the manner in which it is recycled determines the isotopic concentrations of the plutonium isotopes that are released to the environment from the CRBR and its fuel cycle under normal and accidental conditions.
The somatic (and, to a lesser extent, genetic) risks associated with plutonium i
1
% releases are a function of the concentrations of the various Pu isotopes.
Third, the environmental (and safeguards) effects associated with supplying CRBR fuel, including the first core and initial reloads, and recycling CRBR fuel can vary significantly depending upon the actual facilities that will be used.
The Staff's DSFES is inadequate in its failure to address any of these considerations.
Q.9:
What is the basis for your view that there will not be adequate supplies of low-burnup plutonium and consequently the plutonium isotopic concentrations assumed by the Applicants and Staff csnnot be met?
A.9:
The Applicants'and Staff have assumed that "the initial
[CRBR fuel cycle] feed materials would consist of [ fuel-grade] plutonium (obtained from DOE stockpiles)..."
(DSFES, p. D-4), and have assumed that the CRBR is operated on an open fuel cycle with the initial plutonium making only one pass through the reactor (Deposition of Staff witness Lowenberg, Oct. 12, 1982, pp. 8-10).
But DOE Deputy Assistant Secretary for Nuclear Materials F.
Charles Gilbert stated on March 25, 1981, that quantities of available materials in the fuel-grade inventory are reserved for Defense Programs.
Gilbert wrote that "the 4 i
i
% MT of processed plutonium in the fuel-grade inventory is reserved for authorized activities in both defense and non-defense programs," and "a significant portion of the plutonium in N Reactor spent fuel is reserved for Defense
~
Programs" for use in blending.
(Letter of F. C. Gilbert to Thomas B. Cochran, March 24, 1981.)
With the conversion of the N-reactor from fuel-grade plutonium (12% Pu-240) to weapon-grade plutonium (6% Pu-240) scheduled to have been completed in October 1982, DOE no longer is producing fuel-grade plutonium (DOE, "Hanford Accomplishments, Jan. 1981-Present," Aug. 24, 1982).
DOE is currently blending plutanium from its fuel-grade plutonium stockpile with super-grade plutonium (3% Pu-240) produced at SRP to meet nuclear weapons requirements.
Under current DOE plans, there will be little if any fuel-grade plutonium available for allocation to CRBR for its first core and first few reloads by the time these cores are to be fabricated, due to the higher priority placed on meeting the plutonium requirements of the Defense Programs' activities.
On September 9, 1982, Deputy Secretary of Energy W.
Kenneth Davis and Under Secretary of State Richard T.
Kennedy testified on the Reagan Plutonium Policy before the Subcommittee on Energy, Nuclear Proliferation and Governmental Processes of the Senate Government Affairs 4
. Committee.
The following exchanges took place:
Senator Glenn:
Gentlemen, why do we need the breeder and reprocessing now?
Why do we need new plutonium production?
Mr. Davis:
Our prospective need for pluton-ium, which is some years off, has to be arranged sometime in the near future.
We need a substantial amount to continue in operation our principal research facility, the Fast Flux Test Facility at Hanford, and for some of the other experimental facilities, and we will need a substantial amount of plutonium for the Clinch River Breeder fuel as it continues to operate.
What we are contemplating is the possi-bility of entering into contracts for plutonium, but the plutonium itself would not be delivered for many years.
Senatcr Gle.tna Correct me if I'm wrong, but I don't see how the plutoniual is going to be used, because my understanding is that Barnwell will produce between 12 to 15 tons of this material per year, and that we only have a need for one or two tons per year for the U.S. breeder program.
I understand that currently we have adequate plutonium to fuel all the upcoming breeder R&D that we have scheduled right now.
What are we going to do with the output l
of Barnwell?
t Mr. Wennedy:
We do not have the plutonium needed for Clinch River, we do not have the plutonium needed for the follow-on fuel for FFTF.
Senator Glenn:
What is the relationship between Barnwell and Clinch River?
Is the Department's view that the Clinch River reactor shouldn't be built unless the Barnwell facility is also built?
Mr. Davis:
The Barnwell facility has already been built by private industry.
4 Senator Glenn:
Does one depend on the other?
Mr. Davis:
Only in the sense that we will need to acquire the reactor-grade plutonium needed for Clinch River somewhere.
Senator Glenn:
Do we not now have enough plutonium stockpiled now to run Clinch River if it is built?
Mr. Davis:
No, sir.
Not earmarked for Clinch River.
Senator Glenn:
How much is required to fuel Clinch River?
Mr. Davis:
Over a period of some years, I will have to get the exact numbers.
Senator Glenn:
Is the figure that Barnwell will produce 12 to 15 tons a year; is that correct?
Mr. Davis:
Barnwell at full operation probably would produce something in the order of-10 tons a year, not 15.
~
Senator Glenn:
How much will Clinch River use?
Mr. Davis Over the period we are looking at, to the year 2000, about 15 tons.
Senator Glenn Fifteen tons between now and--
Mr. Davis:
FFTF about 8 tons.
We foresee a requirement in total of perhaps 20 to 25 tons.
Senator Glenn:
My time is up but I would just i
say, Gordon Chipman, head of the Clinch Project, and Kermit Laughan, head of DOE's reprocessing office, told my staff explicitly Barnwell is not needed for Clinch River and that adequate plutonium is available.
Were they wrong?
l Mr. Davis:
We do not know exactly where we will get the plutonium for Clinch River and some of the follow-on activities.
We could
. get it from our military resources, but that doesn't seem to be a vecy good prospect if we are to meet our current Weapons Stockpile Memorandum requirements.
(Senate Governmental Affairs Transcripts for Sept. 9, 1982, after editing by DOE, pp. 44-50, emphasis added.)
In Mr. Davis's testimony above, he notes that DOE will need reactor-grade plutonium for CRBR.
Reactor-grade plutonium is obtained from high-burnup spent fuel.
By DOE definition, reactor-grade Pu contains an isotopic concentration of Pu-240 of 19% or greater.
From the above testimony, it is apparent that DOE now wishes to obtain the initial feed material for CRBR from Barnwell and that the feed is contemplated to be reactor-grade plutonium.
I believe it is unlikely that Barnwell will be operated due to the lack of private interest in
~
completing and operating this facility without a huge i
government subsidy, which is unlikely to be forthcoming.
l Furthermore, the alternative of obtaining plutonium from i
foreign sources, namely the UK, appears highly unlikely due to he controversy this proposal has generated in the UK.
With regard to the Barnwell alternative, there have been numerous reports in trade journals on the lack of interest in private ownership of the Barnwell plant.
One of the present owners, Allied General, is not interested in completing the plant and plans to " shut it down"
i whenever government funding runs out (Nucleonics Week, June 10, 1982, p. 10).
A company official responding to a j
DOE plan for encouraging private ownership staed, " People don't go into the position of investing stockholders' l
money if it doesn't make sense" (ibid.).
There are no reliable reports of other potential owners in private
]
industry, and Bechtel and other potential investors are i
not interested in ownership themselves (ibid.).
Papers with tentative plans to encourage private ownership of Barnwell have been put forth by DOE and the Office of Science and Technology Policy (OSTP) (Nucleonics Week, June 3, 1981, p.
1; Inside Energy, Oct. 18, 1982, p.
1), but, according to press reports, there does not seem to be the remotest agreement within the government on how l
~
this is to be achieved.
DOE's request for $250 million in FY 1984 to subsidize Barnwell thorugh the guaranteed
)
purchase of plutonium from an operating plant is I
considered grossly insufficient by OSTP for convinaing the private sector to get involved (Inside Energy, Oct. 18, 1982, p. 1).
OSTP is reported to have suggested a subsidy of five times more, or $1.25 billion, for the guaranteed I
plutonium purchase, but it has yet to make a formal I
i recommendation (ibid.).
There is no indication that l
Congress would be willing to appropriate this level of funding.
i
I
, [
On the possibility of export of UK civil plutonium to the U.S.
for the breeder program, British Under-Secretary of State for Energy John Moore emphatically announced to I
Commons on July 27, 1982, that there were "no further developments" and "no negotiations" following his original l
announcement of " approval.in principle" on October 19, 1981 (Hansard, 19 Oct. 1961, c.79; 27 July 1982, c.438).
i Moore had stated on Dec. 21, 1981, that a US-UK agreement would probably take the fcrm of a commercial contract i
between the Central Electricity Generating Board (CEGB) and DOE (Hansard, 21 Dec. 1981, c.732-739).
Subsequently, i
strong opposition to the possible export of UK plutonium to the US* emerged from individual employees of CEGB and l
from the Electrical Power Engineers' Association (The Times, April 29, 1982,' p. 3).
Finally, reports appeared i
after the end of April 1982 that the US had abandoned plans to buy or lease plutonium from the UK civil stockpile (Financial Times, London, May 6, 1982, p. 9).
I In sum, there is no basis for assuming that there is sufficient low-burnup plutonium from the DOE fuel-grade stockpile or from civilian power reactor fuel to meet CRBR
(
needs.
Furthermore, there is no basis for assuming that i
the plutonium initially recovered at Barnwell, should that facility ever be operated, or obtained from alternative, B
l sources (other than the DOE stockpile) would have i
i t
t l
. concentrations of the controlling isotopes (Pu-238 and Pu-241) as low as the concentrations assumed by the Staff and Applicants.
~
Q.10:
How is the hazard of plutonium affected by the origin of the plutonium fuel and the manner in which it is recycled?
A.10:
In calculating the Site Suitability Source Term doses at the exclusion area and low population zone (LPZ) boundaries, the Staff assumed that the plutonium had the following isotopic concentrations (weight %):
1% Pu-238 74% Pu-239 20% Pu-240 5% Pu-241 0% Pu-242 (Staff Response to Interrogatory 23, 26th Set, July 27, 1982, p. 23; Tr-3128, Morgan.)
While the basis for the choice of concentrations is not well documented, these values were apparently derived by working backwards from a calculation of total curie release made some five years ago, for the CRBR homogeneous core fueled with plutonium recovered from processing spent LWR fuel (Tr. 2346-47, Bell).
Dr. Morgan demonstrated that the Pu-238 and Pu-241 isotopes are controlling in terms of the bone surface t
.,-.n.-
y e
. dose.
His calculations of the relative Hazard Index of the plutonium isotopes are reproduced in Table 1 below.
Tabla 1 (B)
Bone Surf.
Weight %
(A)
Dose Norm.
Isotope Normalized Curies /
Ci Pu-1/ to Dose Due (A)x(B)
(Pu-1)
Weight % to Pu-239 gram Ci Pu-239 to Pu-239 Hazard Index Pu-238 1
0.0135 16.
3.5 0.81 2.8 Pu-239 74 1.
0.062 1.
1.
1.
Pu-240 20 0.27 0.22 0.%
1.
0.%
Pu-241 5
0.068 120.
130.
0.019 2.35 (Tr. 3129-30, Morgan.)
l In the Staff's NEPA evaluation of accidents (DSFES, Table J.4 at p. J-13), the Staff assumed the inventories of plutonium isotopes in the reactor core were:
~
0.38 mi1 lion curies Pu-238 Pu-239 0.11 0.10 Pu-240 Pu-241 13.0 Pu-242 (DSFES, Table J-4, p. J-13.)
These values are consistent with the isotopic concen-trations used by the Staff in the Site Suitabilty Source Term analysis and reproduced above (i.e.,
1% Pu-238, 74%
Pu-239; 20% Pu-240, 5% Pu-241).
In the Staff NEPA evaluation of routine releases associated with CRBR fuel reprocessing, the Staff assumed
1 i the larger of two estimates of the source term for each isotope of importance:
Table 2 Source Term (Ci/yr)
NRC-ORIGEN2 Basis DOE-Amend XIV NRC-Selected Pu-236 3.3 E-09 1.5 E-09 3.3 E-09 Pu-238 8.1 E-06 (0.1%)
8.5 E-05 (1.1%)
8.5 E-05 Pu-239 2.7 E-05 (83%)
2.1 E-05 (73%)
2.7 E-05 Pu-240 1.7 E-05 (15%)
2.2 E-05 (21%)
2.2 E-05 Pu-241 8.5 E-04 (1.4%)
2.6 E-03 (5%)
2.6 E-03 Pu-242 5.2 E-09 4.7 E-08 4.7 E-08 (The values in parentheses represent my estimate of the corresponding approximate weight % of each isotope.)
In deriving the above source terms, the Staff assumed that j
the CRBR core was always fueled with plutonium containing i
12% Pu-240 (NRC-ORIGEN2 Basis), whereas the DOE had assumed the CRBR was always fueled with 20% Pu-240 (DOE-
~~
Amend. XIV) (DSFES, p. D-12).
I The values under the column labeled "NRC-ORIGEN2 Basis" were claimed by NRC Staff to represent plutonium l
that had an initial isotopic concentration assumed by DOE in the ER which was altered as a result of one pass through CRBR (Deposition of Staff witness Homer Lowenberg, Oct. 12, 1982, p. 18).
For all practical purposes, the NRC-Selected values represent the DOE values (DOE-Amend.
XIV), only the Pu-239 value is increased by 29%.
The relative hazard of two plutonium fuel isotopic conentrations can be compared using a Hazard Index that is e-+-=
- ----m 1-~
. proportional to the bone surface dose, which is controlling for plutonium.
The Hazard Index is taken as:
(HI) = K, M vq Ag.
where K1 = proportionality constant M = mass of plutonium in the reactor core wi = weight % of ith isotope of Pu Ai = specific activity of Pui (Ci/g)
~
Di=
dose conversion factor (for bone surface (assumed to be controlling)) for Pui (rem /Ci)
Neither Applicants nor Staff have analyzed the CRBR core loading that would be required if reactor-grade plutonium from reprocessing commercial reactor fuel were used.
(Staff Response to Interrogatory I.3, 27th Set, Oct.
1, 1982, p. 4).
Nevertheless, the relative mass of plutonium in the reactor can be roughly approximated by:
11
=kzIpvv.,H(
4 whereUk=averagefissioncross-sectionofithisotope of Pu K2
- Proportionality constant Thus the relative hazard of two plutonium-fuel isotopic concentrations ist i
1, Wi Al Di (HI)i 1 W,5-z
=.
N )L h Wi
[u WJ, Al TX 6
s As un example calculation, I will compare the relative hazard of Pu recovered from spent LWR fuel (Column 1 of Table 3) to the Pu assumed by the Staff in Staff's Site Suitability Source Term and DSFES Appendix J dkisapproximatedusinggroup3 analyses.
The value of
constants from ANL 16-Group reactor constants published in ANL-5800.
(HI)9, 74 x 1.% + 20 x 1.59 + 5 x 1.89 X
(HI)1 57.9 x 1.% + 24.7 x 1.59 + ll x 1.89 + 4.4 x 1.45 1.9 x 16 x 8.4 + 57.9 x 0.062 x 10.4 + 24.7 x 0.22 x 10.4 + 11.0 x 120 x 0.194 1.0 x 16 x 8.4 + 74 x 0.062 x 10.4 + 20 x 0.22 x 10.4 + 5.0 x 120 x 0.194 186 605 2
gx g
=
=
Similarly, the Hazard Index for other assumed Pu isotopic concentrations relative to the Haza:d Index of the Pu assumed in the Staff Site Suitability Source Term are:
Relative Hazard Index Staff Site Suitability Source Term & DSFES App. J l
Pu recovered from spent U fuel (Table 3, col. 1) 2 Pu after one 4yr recycle (Table 3, col. 2) 3 Pu after two 4-yr recycles (Table 3, col. 3) 4.3, Pu recycle model BWR (Table 3, col. 4) 3.7 Morgan calculated 5.6.
The dif ference is due to the fact that Morgan, as a first approximatio.1, used only the ratio of the weight % of the Pu-239 and Pu-241 to approximate the relative difference in the mass of plutonium in the reactor in the two cases (see Affidavit of Karl Z. Morgan, Oct. 1, 1982).
i i
Table 3 Calculated Plutonium Composition - Percent 1
2 3
4 Pu Recovered Pu After One Pu After Two Pu Recycle Fr. Spent U Fuel 4-Yr. Recycle 4-Yr. Recycles Model BWR Pu-238 1.9 3.46 4.87 3.4 Pu-239 57.9 38.2 29.4 41.7 Pu-240 24.7 29.4 33.5-29.3 Pu-241 11.0 17.2 17.4 15.2 Pu-242 4.4 11.7 14.9 10.4 Pug
- 68.9 55.4 46.8 57.0 Pug = Pu-239 + Pu-241 As seen by comparing the relative isotopic concentrations I
in Tables 1 and 2 on a per gram basis, the hazard of the plutonium assumed by Staff to be released from the CRBR fuel reprocessing plant is comparable to the hazard of the plutonium assumed by t'he Staff in its Site Suitability analysis.
In sum, by Staff's failure to consider recycle of CRBR fuel, Staff has underestimated the hazard of plutonium releases by a factor of about 4.
Q.11:
What is the effect of ignoring the EDC to persons beyond U.S. boundaries?
A.ll:
The Staff has provided a breakdown of Staff's estimate of annual curie release and the 140 person-rem / year dose commitment to the U.S. population due to principal isotopes as follows:
O
. 100-year Whole-Body Dose Annual Release Commitment to U.S. Pop.
Isotope (Curies /yr)
(person-rem)
H-3 5900 74.5 C-14 14 66.2 Kr-85 5100 0.36 Radiciodine 0.19 I-129 (0.00037)
(0.02)
TRUs 0.105 Other 0.314 141.7 (DSFES, p. D-7; Response to Interrogatory I.16.a, Staff's Response to NRDC's 27th Set of Interrogatories, p. 29a) l By Staff estimates, the 100-year whole body dose.
commitment to the U.S. population for:
H-3 is 98% of the worldwide value; C-14 is 42% of the worldwide value; Kr-85 is 22% of the worldwide value; and consequently the worldwide value is 236 person-rem, with the C-14 contribution 158 person-rem.
Q.12:
What is the.effect of ignoring the environmental dose commitment beyond 100 years?
A.12:
The EPA estimates the worldwide dose commitment from C-14 is:
28 person-rem /Ci released to the atmosphere, for the I
first 100 years; 120 persen-rem /Ci released to the atmosphere, for the
.first 1000 years; 537 person-rem /Ci released to the atmosphere, integrated
. )
over the life of C-14.
(USEPA, " Health Impact Assessment of Carbon-14 Emissions from Normal Operations of Uranium Fuel Cycle Facilities,"
EPA-520/5-80-004, March 1981, p. 22.)
EPk's 100-year doce commitment factor is 2.5 times that assumed by the Staff, i.e., 28 person-rem /Ci, released, compared to the Staff value of 66.2/14 = 4.7 person-rem /Ci.
Use of these EPA data suggests that integrating over 1000 years would increase the worldwide C-14 dose by an additional factor of about 120/28 = 4.3,
)
and that integrating over the lifetime of the C-14 isotope would increase the worldwide C-14 dose by a factor of 537/28 = 19.
Consequently, the' worldwide C-14 dose integrated over the lifetime of the isotope would be about 158 x 19:% 3000 person-rem based on Staff's 100-year dose commitment value, or 537 x 14 0 7500 person-rem using the EPA dose commitment factor.
The Staff similarly has failed to estimate the impact of I-129 beyond 100 years.
Without considering the additional dose contribution due to I-129 or other errors in the Staff's estimates, the l
total whole body environmental dose commitment is approximately 22 to 54 times that presented by the Staff
I
. in the DSFES (3080/140 c: 22 and 7596/140 :54).
Q.13:
What is the effect of Staff failure to report the environmental dose commitment to organs other than whole body?
A.13:
In Staff's response to NRDC 27th Set of Interrogatories (p. 29a and Enclosure B), the Staff reported that its estimate of the 100 year environmental bone dose commitment to the worldwide population, 875 person-rem, was a factor of 875/236 = 3.7 times the whole body worldwide dose commitment.
Furthermore, by Staff estimates 790 person-rer (90% of the 875 person-rem total) was due to C-14, 76 person-rem (9%) due to H-3, ar] 4 person-rem due to plut, onium.
The Staff claims ~its bone dose estimate is conservative because it is based on an old dosimetric model that uses an n-factor of 5, no longer recommended by ICRP.
Although the Staff fails to explain why it did not use current ICRP dosimetric models (and report bone marrow and bone surface dose rather than bone dose), the Staff estimates the bone dose to the U.S. population would be reduced to "about 400 person-rem (Staff Response to Interrogatory I.16 m of the 27th Set, p. 29b).
The Staff gave no further explanation of how it arrived at this value.
l
.__,___ ~__
. O.14:
What plutonium gaseous effluent containment factor does the Staff assume for the CRBR fuel fabrication and fuel reprocessing facilities?
A.14:
For CRBR fuel fabrication, the Staff and Applicants have assumed that all exhaust gases from the proposed SAF line would pass through a series of HEPA filters having an overall cleanup factor of 1.25 x 10-8 (DSFES, p. D-9; Staff Response to Interrogatory I.10, 27th Set, Oct.
1, 1982, p. 14.)
The Staff further assumed that the exhaust gases prior to filtering would contain approximately 10-3 times the plutonium throughpout of the facility for an overall plutonium containment factor of approximately 1.25 x 10-11 1/
For the CRBR fuel' reprocessing, the Staff assumed 5.4 4
x 10 Ci Pu-239 in CRBR spent fuel processed annually and 2.7 x 10-5 Ci Pu-239 released annually for an overall l
l plutonium containment factor of 5 x 10-10, While the Staff claims these estimates are based in part on "the commitment on the part of DOE to use current guides and standards in the design of the proposed DRP t
l 1/
This value is confirmed from Table D-6 (DSFES, p. D-10),
9 Staff's estimate of CRBR Pu-239 released is given as where th Ci/yr = 9.4 x 10-6 g/yr.
The assumgd throughput of 5.9 x 10 CRBR Pu-239 = (0.889 MT Pu) (0.86) = 7.6 x 10 g (DSFES, p. D-10).
The overall containment factor is therefore 9.4 x 10-6/7.6 l
x 105 = 1.24 x 10-11 i
t
)
- ]
i (Staff Response to Interrogatory I.11, 27th Set, Oct.
1, 1982, p. 15), the Staff has made no attempt to see if DOE meets current guides and standards at currently operating DOE facilities, or whether DOE can be relied upon to meet future commitments in this regard.
An assessment of the cleanup factors $ achieved at currently operating facilities, and those that have operated in the recent past, would be essential to assess whether the cleanup factors, 1.25 x. 10-11 for fuel fabrication and 5 x 10-10 for reprocessing, assumed by the Staff are realistic.
Staff witness James Ayres agrees that such assessments would be useful (Deposition of James Ayres, Oct. 13, 1982, pp. 53-54).
Yet the Staff has made no effort to assess the cleanup factors at any such facility, including:
a)
Kerr-McGee, which was used to fabricate FFTF fuel; b)
NFS-Erwin, which formerly fabricated plutonium fuels; f
c)
NUMEC, which formerly fabricated plutonium fuels; 1
l d)
Rocky Flats, which currently chemically processes plutonium and fabricates plutonium components for nuclear weapons; e)
F and H canyons at Savannah River Plant, currently operating chemicel processing plants; f)
NFS-West Valley, which formerly operated as a spent nuclear fuel reprocessing plant;
=
- t g) the Hanford PUREX plant, which formerly chemically processed N-reactor spent fuel; h) any foreign nuclear spent fuel reprocessing plants.
(Responses to Interrogatories I.lO and I.ll, 27th Set, Oct.
1, 1982, pp. 13-15; Deposition of Staff witness Lowenberg, Oct. 12, 1982, at 41-42.)
0.15:
How do the Staff's hypothetical containment factors compare to actual operating experience?
A.15:
I have not reviewed in any detail the appropriate data for each of the above facilities (A.12, above).
I have looked at the Savannah River Plant (SRP) F and H chemical processing facilities, and the Hanford PUREX plant.
The SRP chemical processing plants released approximately 3 Ci of_Pu-239 between 1955 and 1978, and about 3.8 j-1.4 x 10-4 Ci/ year between 1975 and 1978.
(C.
Ashley and C.C. Zeigler, " Releases of Radioactivity at the Savannah River Plant 1954 through 1958," DPSPU 75-25-1, Feb. 1980, pp. 157-158.)
The quantity of weapon-grade plutonium discharged from the Savannah River production reactors and processed at the F and H chemical separation areas during operations through the end of 1978 is estimated to be 30 j-10 metric l
tons, with about 1.6 j- 0.2 MT processed annually in the
T 4
1975 to 1978 period.2,/
These values correspond to about 6
1.7 j; 0.6 x 10 Ci Pu-239 processed between 1955 and 1978 4
and 9 j; l x 10 Ci Pu-239/yr between 1975 and 1978.
Thus, the plutonium containment factor at SRP averaged approximately 1.8 x 10-6 between 1955 and 1978, and about 4 x 10-9 between 1975 and 1978.
In 1972, in its last year of operation, the Hanford l
PUREX plant reportedly processed 1013 MT of N-reactor spent fuel and released as gaseous effluent 3 x 10-3 Ci of
~
alpha activity (Rockwell International, " Environmental Report of Purex Plant and Uranium Oxide Plant - Hanford Reservation," RHO-CD-742, April 1979, pp. III-3, -5).
With fuel requirements of 330 MT/yr, the N-reactor has a capacity of 600-630 kg/yr of fuel-grade plutonium (12% Pu-240).
Assuming that the Pu-239 contribution to the total alpha activity is on the order of 10%, the containment factor for gaseous plutonium releases at PUREX in 1972 was on the order of:
l (3x10-3)(0.1)/((1013)(600/330)(103)(lci/16g)(0.84))
3 x 10-9 or about the same as that for reprocessing at SRP between 2/
These values are my own estimates based on published data on the inventories of strontium and cesium isotopes in radioactive waste at SRP and production reactor operation data for 1978, about 1.4 MT of plutonium per year for 3 operating reactors at reduced output.
l
. 1975 and 1978.
In sum, the NRC is projecting that the CRBR fuel reprocessing facility will have a plutonium gaseous effluent containment factor about 10 times better than what is being achieved at PUREX or SRP in recent years, using current technology, and about 4000 times better than that achieved over the lifetime of SRP, which may include accidental as well as routine releases.
Some, perhaps all, of the other facilities mentioned in A.14 above may have achieved containment factors relative to the NRC Staff assumptions for fabrication and reprocessing operations that are even poorer than calculated for the SRP processing plants above.
Rocky Flats, for example, has experienced plutonium releases more than an order of magnitude larger than those reported for SRP, yet the plutonium throughput at Rocky Flats is not an order of magnitude larger than the Pu production at SRP.
Furthermore, the plutonium releases as a result of accidents at Rocky Flats are believed to have exceeded the routine releases, yet Staff has-given no consideration to accidents at CRBR fuel cycle facilities.
In sum, the l
Staff assumptions cannot be accepted as realistic.
The potential error in the Staff's assumption l
l regarding the plutonium containment factor for CRBR fuel fabrication and reprocessing facilities must be considered 1
i
. in combination with the errors introduced by failure to consider recycled mixed-oxide (MOX) fuel and the uncertainties in the quality factors (particularly the dose distribution factor) appropriate for plutonium lung and bone surface dose calculations as discussed in NRDC testimony at the Hearing on Contentions related to CRBR Site Suitability.
(cf., Tr. 3081-85, Cochran; Tr. 3109, Cobb; Tr. 31391-42, Morgan.)
When all these are considered together, it appears that the Staff is underestimating the potential health effects due to CRBR fuel cycle plutonium release by several orders of magnitude.
The Staff analysis is inadequate in its failure to discuss these uncertainties.
Q.16:
Are there other errors or examples of nonconservatisms in l
the Staff's analysis of the environmental effects l
associated with the CRBR fuel cycle?
A.16:
Yes -- the treatment of the potential health effects associated with waste management and disposal is non-conservative, and the somatic and genetic risk estimators (DSFES, p. 5-13, -20) are nonconservative.
Q.17:
What conclusions did the Staff make with regard to the potential environmental radiological effects associated
(
with CRBR high-level radioactive waste (HLW) disposal?
l
l
. A.17:
The Staff concluded that (a) the effluents from the HLW stored in the geological repository would be zero (or negligible), and the only non-zero radiological effluents are releases of radon and its decay products associated with construction of the repository e.g.,
mining the l
repository cavity (DSFES,p D-21); and (b) these releases (associated with mining the cavity) are negligible by comparison with similar effects from other fuel cycle steps (DSFES pp.D-7, D-21; Deposition of Staff Witnesses Branagan and Boyle, Oct. 13, 1982, pp. 37-44).
1 l
Q.18:
Do you agree with the Staff's conclusions, and if not, what is the basis for your disagreement?
I A.18:
I do not agree that the Staff's conclusions reasonably reflect the uncertainties associated with HLW disposal.
The basis for this disagreement is, in part, as follows:
a)
First, the Draft EPA Proposed Environmental Standards and Federal Radiation Protection Guidance for Management and Disposal of High-Level and Transuranic Radioactive Wastes (EPA, Working Draft 21, 6/14/82) establishes limits I
on radioactivity released to the " accessible environment" which are designed to limit long-term risks to 1000 health effects over 10,000 years for a 100,000 MTHM Repository, l
1
. where:
" accessible environment" includes (i) the atmosphere, (ii) land surfaces, (iii) surface waters, (iv) oceans, and (v) parts of the lithosphere containing significant amounts of groundwater; the accessible environment also includes (vi) parts of the lithosphere containing insignificant amounts of.
groundwater that are more than ten kilometers in any direction from the original location of the radioactive wastes in a disposal system.
(EPA, Working Draft 21, p.
38, emphasis added).
The Staff assumes that CRBR high-level waste (over a 30-year operating period) will represent on the order of, or less than, 1/100 of the total repository volume (DSFES, p.D-20; Staff's response to Interrogatory I.12.1, 27th Set (October 1, 1982), p.17).
Thus, under proposed EPA standards, the CRBR contribution to the total health effects in the accessible environment during the first 10,000 years after closure is meant to be limited to 1000/100=10 health effects, or approximately 0.3 for each year of CRBR operation.
This level of risk is an order of
. magnitude greater than other fuel cycle risks as estimated by the Staff, i.e. 0.023 potential cancers / year (DSFES, p.
5-20).
1 The above EPA limits (1000 health effects in 10,000 years per repository) do not apply to potential radiological releases to the biosphere within 10 km of the l
l repository (i.e. 314 km, or 123 mi2) or releases after 2
l 10,000 years.
The Staff has assumed that some 2 million l
l l
- people will reside within 80 km of the site (DSFES, pp-21; DOE 1980b, Vol 2, p F.2).
Applying this same population density within the 10 km radius implies there might initially be some 30,000 persons in this region, which is not part of the " accessible environment" as defined by EPA.
The proposed EPA limits permit unlimited exposure to this population, for all times, and consequently the i
proposed EPA standards would not limit human health effects associated with CRBR waste operations to 10 persons (or 0.3/ year).
b)
Second, in light of the present status of the Federal efforts associated with HLW disposal, while it is theoretically possible to store HLW safely, I do not believe that there is currently any basis for high I
confidence that the radioactive waste will be safely t
i sequestered.
The basis for this view is set forth l
generally in NRDC testimony in the NRC's Waste Confidence Rulemaking (PR-50,51 (44 Fed. Reg. 61372)).
As but one further example of the many difficulties that remain unresolved, the first of three alternative HLW repository sites which DOE plans to characterize in preparation for licensing review by NRC, is Basalt site at the Hanford Reservation.
Following a November 1981 trip l
report to the Basalt Waste Isolation Project, NRC consultants concluded that the DOE's forthcoming site l
l
.' characterization report, when completed, may be inadequate, in part because There are currently several widely different views on the general pattern of groundwater flow in the Pasco Basin....
It appears the five year hydrology test program will not result in sufficient data to answer basic questions about groundwater movement....
i The conceptual repository design is inadequate because it ignores the consequences of the indicated nigh stress field,...
"The in situ test program that was discussed with NRC (i.e., Phase I of the Exploration Shaft), is insufficient to characterize the site at depth, determine site suitability, and determinedegpgnparametersforthe repository."._
c)
Third, in light of the uncertainties associated with HLW disposal, the Staff's analysis is inadequate in its failure to discuss theffull range of potential health effects associated with these uncertainties.
M.J. Brown and E. Crouch (Health Physics 43L, September 1982, pp. 345-354) have attempted to bound the potential health effects by examining two " extreme scenerios."
Under one highly unlikely scenario involving a volcanic eruption at the repository site, Brown and Crouch estimated that the number of cancer doses from Sr-90 alone exceeded the 3/
- Brooks, D.J.,
et al, " Visit to the Basalt Waste Isolation i
Project (BWIP) - Hernford, Washington, USNPC, Nov.
1981, pp.
l-2.
1
. population of the U.S.
The second scenario, which I find far more credible, involved the contamination of a municipal drinking water supply.
For a containment time of 400 years and a leach time of 6300 years, the cancer risk (from all causes) was increased 25% (;(d. ).
DOE analyzed the 70-year "whole-body" cose commitment from solution mining a 47,000 MTHM salt dome repository for human salt consumption (i.e.,
for table salt) -1000 years after closure and estimated such an event could result in 1.6 x 10-7 person-rem.
(DOE, "FEIS, Managemnt of Commercially Generated Radioactive Wastes," DOE /EIS-0046F, Vol.
1, pp. 5.89-5.92.)
Prorating 1/100 of this dose to CRBR, the resulting 160,000 person-rem is 1000 l
times the whole body dose commitment assumed by the Staff for the entire CRBR fuel cycle.
I do not mean to imply that the probability of such events is larger rather these examples are only to suggest that the Staff's assumption that the health effects will be zero does not adequately reflect the uncertainties and in this regard also could be considered " extreme," but in the opposite direction.
d)
Fourth, EPA and the U.S. Geological Survey ("USGS")
have both expressed substantial reservations about the NRC's finding of no significant risk of radioactive releases from a permanent waste-storage facility.
- EPA,
,o
.? for example, suggested that the " Table S-3" chart (from which some of the DSFES Table D.4 entries were derived),
should be accompanied by a narrative statement emphasizing the uncertainties underlying the numerical entries, i
particularly for-long-term waste storage:
A purely numerical table is, in fact, an implication of far greater certainty than is l
warranted by the facts.
Clearly, for the time spans involved in presenting the impacts of certain radioactive effluents, there are I
environmental impacts difficult to quantify I
that require accompanying narrative.
EPA Response to NRDC's Proposed Questions of November 18, 1977, #2(d) at 1 (undated) (Table S-3 Rulemaking).
These criticisms apply equally to the DSFES Appendix D discussion of HLW disposal, particularly Table D-4 (at p.
D.7).
A report by a panel of earth scientists, submitted to EPA, concluded that there are " extreme numerical l
uncertainties" attached to most of the factors bearing on the possibility of disruption of a waste repository.
Report of Ad Hoc Panel of Earth Scientists, The State of Geological Knowledge Regarding Potential Transport of High-Level Radioactive Waste from Deep Continental Repositories, EPA /520/4-78-044, at 32 (June 1978).
Perhaps more significantly, the USGS -- the federal agency with the greatest technical expertise in geological matters -- concluded that " Table S-3 by itself clearly does not convey an appreciation of the risks involved in
,0
. geologic disposal of high-level radioactive wastes or the uncertainties involved in determining such risks."
USGS Reponse to NRDC's (Table S-3 Rulemaking) follow-up questions of December 16, 1977, #1 at 1 (undated).
Moreover, a later USGS report warned that "given the current state of our knowledge, the uncertainties associated with hot wastes that interact chemically and mechanically with the rock and fluid system appear high,"
and these uncertainties are compounded by "the lack of a i
method for determining the future rates of many
[ geological] events and processes."
Geologic Disposal of High-Level Radioactive Wasted -- Earth Science Perspectives, USGS Circular 779 at 6, 11 (1978).
Indeed, two government reports -- one issued by NRC 1
-- have cautioned that predictions about the performance or feasibility of a waste-storage facility are subject to considerable uncertainty.
The " Report to the President by the Inter-Agency Review Group on Waste Management" ("IRG Report"), for example, pointed out that risk assessments
" based on idealized repository characteristics
...are subject to significant uncertainties," and concluded that l
the "zero release of radionuclides cannot be assured."
l IRG Report, TID-29442, March, 1979, p. 45.
Moreover, the Commission's own staff conceded:
There are still uncertainties in areas such as the effect of waste presence on repository l
l
,- stability; the probabilities and consequences 4 intrusive acts by humans; the validity of data used in modeling studies; the design and regulatory actions needed to minimize possibilities of respository failure; projection of future societal habits and demography; and finally, the relative importance of various potential initiating events.
NUREG-Oll6, at 4-94.
Finally, recent events serve to highlight the persistence of uncertainty regarding the technical feasibility and safety of a long-term waste repository, as well as the institutional question whether an appropriate site can be selected and maintained.
In the currently ongoing Waste Confidence proceeding, for example, the NRC has developed substantial evidence -- summarized in the Report of the NRC Working Groupi/ -- that uncertainty over these issues continues.- There are significant questions about the ability of the Department of Energy (" DOE") to find a suitable repository site and to design and build an adequate facility.
As DOE has candidly admitted:
Additional engineering development work remains to be done before safe waste disposal can acttslly be achieved...Until the [ waste research and development] program is completed, there necessarily remains a degree of uncertainty regarding whether DOE will find the answer to questions still open and whether those answers, when found, will turn out as 4/
U.S. Nuclear Regulatory Commission, Report on the Working Uroup on the Proposed Rule-making on the Storage and Disposal of Nuclear Wastes (January 29, 1981)
0
. I hoped for.
NRC Report, Introductory Statement at 7.
Having identified twenty-six " major issues" still in contention, the Working Group has concluded that "there appear [s] to be a number of contingencies, both technological and institutional, on which the success and timeliness of waste disposal may hinge."
NRC Report, Introductory Statement at 12.
In addition, other agencies continue to note significant uncertainties about the risk assessment models used by DOE.
USGS, for example, has stated that any generic assessment that radioactive waste can be contained in a federal wate repository at acceptable levels of risk l
deserves only " limited credibility."
NRC Report, Part 1.B at 17.
USGS has also~ commented that any current determination of when a repository will be available is necessarily " imprecise and premature."
Id. at 18.
- DOE, too, recognizes that "important gaps exist in knowledge regarding rock properties and responses under extreme I
conditions of temperature, stress, and radiation over long periods of time."
Q.19:
Why do you believe the Staff's somatic and genetic risk estimators (DSFES, p. 5-20) are nonconservative?
r l
l l
0
~
s A.19:
The Staff uses a geometric mean of the two limits on the range of the somatic (and genetic) risk estimates given in BEIR I as Staff's point estimates for the somatic (and genetic) risk estimators (DSFES, p. 5-13).
The Staff takes the upper limit of the BEIR I somatic risk estimator, based on the relative risk model as a
" reasonable upper limit of the range of uncertainty" (DSFES, p. 5-13).
The upper limit on the BEIR I somatic risks (based on the relative risk model) does not represent the full range of expert opinion on somatic
^
risks, as discussed in Part IV of my testimony.
Concluding Question 0.20:
In light of the deficiencies of analysis you have outlined, what is your.overall judgment as to the Staff's analysis of the environmental effects associated with the CRBR fuel cycle?
A.20:
The Staff's analysis is inadequate, primarily in its failure to adequately address uncertainties associatad with Staff's estimates and in its treatment of potential transuranic releases from fuel fabrication and processing operations.
The Staff analysis is also inadequate in its failure to consider all reasonably foreseeable fuel cycle alternatives.
The environmental effects of the CRBR fuel j
cycle could be much higher than indicated by the NRC.
BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
UNITED STATES DEPARTMENT OF ENERGY
)
PROJECT MANAGEMENT CORPORATION
)
Docket No. 50-537 TENNESSEE VALLEY AUTHORITY
)
)
(Clinch River Breeder Reactor Plant)
)
)
AFFIDAVIT OF DR. THOMAS B. COCHRAN City of Washington
)
) ss:
District of Columbia
)
DR. THOMAS B. COCHRAN hereby' deposes and_says:
The foregoing testimony prepared by me and dated November 1, 1982, !s true and correct to the best of my knowledge and belief.
mD BCuD-Dr. Thomas B.
Cochran Signed and sworn to before me this 1st day of November 1982.
w0 /S M
Notary Public A!y Commission Erpires Jufy 31, IM-I I