ML20151A964
| ML20151A964 | |
| Person / Time | |
|---|---|
| Issue date: | 07/07/1988 |
| From: | Miraglia F Office of Nuclear Reactor Regulation |
| To: | Scinto J NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| References | |
| NUDOCS 8807200179 | |
| Download: ML20151A964 (8) | |
Text
__
.I-July 7, 1988 MEMORANDUM FOR:
Joseph Scinto, Acting Assistant
~
General Counsel for Hearings Office of General Counsel FROM:
Frank J. Miraglia, Jr., Associate Director for Projects Office of Nuclear Reactor Regulation
SUBJECT:
AMENDMENT REQUESTS FOR EXTENSION OF FUEL IRRADIATION AND ENRICHMENT LIMITS SPECIFIED IN TABLE S-4 0F 10 CFR 51.52 In the March 3, 1988 memorandum from Steven A. Varga to William J. Olmstead, we proposed to cite the Notice of Environmental Assessment and Finding of No Significant Impact for extended irradiation and increased enrichment of fuel for concercial LWRS (53 FR 6040) in support of the subject license amendment requests. Our proposal was intended as an interim measure pending final action on a change to Table S-4 of 10 CFR 51.52 (transportation impacts) presently being pursued by RES.
Bill Olmstead indicated that the Federal Register Notice (53 FR 6040) was ambiguous and not a good citation to show No Significant Impact.
In response to Bill's concent, we have independently prepared the enclosed assessment of environmental impacts of extended irradiation and increased enrichment of LWR fuel. Our assessment shows that the subject action would not involve any incremental radiological and/or non-radiological impacts of transportation of materials to and from LWR sites (covered in Table S-4).
We, therefore, propose to cite the enclosed NRR assessment in the environmental section of the Safety Evaluations supporting the subject license amendments pending final action on this issue by RES.
Should ou have any questions en this issue, please contact Mohan Thadani (X21427.
pa.i weo uy:
/rankJ.Miraglia,Jr.
Associate Director for Projects Office of Nuclear Reactor Regulation s
Enclosure:
As stated o
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l MEMORANDUM FOR:
Joseph Scinto, Acting Assistant General Counsel for Hearings Office of General Counsel FROM:
Frank J. Miraglia, Jr., Associate Director for Projects Office of Nuclear Reactor Regulation
SUBJECT:
AMENDMENT REQUESTS FOR EXTENSION OF FUEL IRRADIATION AND ENRICHMENT LIMITS SPECIFIED IN TABLE S-4 0F 10 CFR 51.52 In the March 3,1988 rremorandum from Steven A. Varga to William J. Olmstead, we proposed to cite the Noti'.;e of Environmental Assessment and Finding of No Significant Impact for extended irradiation and increased enrichment of fuel for comercial LWRS (53 FR 6040) in support of the subject license amendment requests. Our proposal was intended as an interim measure pending final action on a change to Table S-4 of.10 CFR 51.52 (transportation impacts) presently being pursued by RES.
Bill Olmstead indicated that the Federal Register Notice (53 FR 6040) was ambiguous and not a good citation to show No Significant Impact.
In response to Bill's coiment, we have independently prepared the enclosed assessment of environmental impacts of extended irradiation and increased enrichment of LWR fuel. Our assessment shows that the subject action would not involve any incremental radiological and/or non-radiological impacts of transportation of matarials to and from LWR sites (covered in Table S-4).
We, therefore, propose to cite the enclosed NRR assessment in the environmental section of the Safety Evaluations supporting the subject license amendments pending final action on this issue by RES.
Should you have any questions on this issue, please contact Mohan Thadani (X21427).
r J
d.A A
'A F
k J. Mirag a, J Associate Dir rf Projects Office of Nuclear Re ctor Regulation
Enclosure:
As stated cc:
T. Murley
ENVIRONMENTAL EFFECTS OF TRANSPORTATION RESULTING FROM EXTENDED FUEL ENRICHMENT AND IRRADIATION INTRODUCTION Several licensees of light water reactors (LWRs) have submitted proposed license amendments to permit use of enriched fuel in excess of four (4) weight-percent uranium-235 and to extend fuel irradiation from the current limit of 33 Gigawatt Days / Metric Ton (GWD/MT) up to 60 GWD/MT.
It is anticipated that, in time, almost all licensees of light water reactors will request approvals to adopt increases in irradiation levels and fuel enrichment.
Paragraph (b) of 10 CFR 51.52 states, among other things, that for reactors using fuel enrichment greater than 4 weight-percent uranium-235 or where fuel irradiation exceeds 33 GWD/MT, the licensee shall provide a full description and detailed analysis of the environmental effects of transportation of fuel and wastes to and from the reactor, including values for the environmental impact under normal conditions of transport and for the environmental risk from accidents in transport.
The statement shall indicate that the values determined by the analysis represent the contribution of such
,1 effects to the environmental costs of licensing the reactor.
[
With respect to this issue, the staff published a Notice of Environmental b
Assessment and Finding of No Significant Impact for extended burnup fuel use in Commercial LWRs in the Federal Register (53 FR 60a0), dated February 29, 1988.
In the above cited notice, the staff concluded that the environmental impacts sumarized in Table S-a of 10 CFR 51.52 for a burnup level of 33 GWD/MT are conservative and bound the corresponding impacts for burnup levels up to 60 l
GWD/MT and uranium-235 enrichments up to five percent by weight.
The staff also concluded that there are no significant adverse radiological or non-radiological impacts associated with the use of extended fuel burnup and/or increased enrichment, and that this use will not significantly affect the quality o' the human environment. Foreover, pursuant to 10 CFR 51.31, the Comission determined that an environmental impact statement need not be prepared for this action.
The staff is in the process of revising the regulations at 10 CFR 51.52 to reflect the findings published in the above cited Federal Register Notice.
In the interim, in connection with its review of proposed license amendments to o
permit use of fuel enriched with uranium 235 in excess of 4 percent and up to 1
5 percent by weight and irradiated to levels above 33 GWD/MT and up to 60 GWD/MT, and pursuant to 10 CFR 51.52(b), the staff proposes to accept the following analysis of the environmental effects of the transportation of such fuel and waste until such time as the revision to the rule is issued.
L ENVIRONMENTAL !MPACTS OF TRANSPORTATION I
In evaluating the environmental impacts of the use of extended irradiation of high enrichment fuel, the Comission has relied upon the following four studies dealing with the transportation impacts:
(1) Pacific Northwest Laboratories' report NUREG/CR-5009 prepared for the Nuclear Regulatory Comission; (2) Nuclear Regulatory Comission's report WASH-1238;
. (3) Envirosphere Company Report AIF/NESP-032, prepared for National Environmental Studies Project (NESP) and the Atomic Industrial Forum, Inc., with the participation of the Comission's staff; and (4) Sandia National Laboratories (SNL) Draf t Report NUREG/CR-2325 All four studies present the results of evaluation of transportation impacts for postulated traffic models.
The results are presented for traffic density, radiological occupational risks, radiological public risks of normal transportation, and risks of transportation accidents. The Pacific Northwest Laboratories (PNL) report and the Envirosphere Company report present the environmental impacts for fuel irradiation levels extending up to 60 GWD/MT and enrichments up to 5 weight percent uranium-?35.
The PNL results appear to have been derived from the analysis presented in the NESP report.
Table I summarizes the results of traffic densities for transportation cf fresh fuel, spent fuel, and other solid waste by truck, rail, and barge used in the four studies.
TABLE I - TRAFFIC DENSITIES 3HIPMENTS PER REACTOR YEAR Trans-PNL NESP-032 WASH-1238 SNL
- portation Mode NUREG/CR-5009 33 GW/MT 60 GW/MT 33 GW/MT 33 GW/MT 60 GW/MT 33 GW/MT TRUCK 112 92 112 92 112 122 RAIL 10 6
10 6
10 2.3 i
BARGE 5
3 5
3 i
The comparison of the results of traffic density analysis shows that there is a good correlation between the SNL results and the other reports.
Both the PNL study and the NESP study show that there will be a reduction in the total number of shipments (fresh fuel, spent fuel, and low level wastes) when higher levels of irradiation (60 GWD/MT) are assumed. Such high irradiation levels may require that fuel enrichment be increased up to a maximum of 5 weight percent.
The reduction in the shipments is due to the fact that there will be fewer outages for fuel reloads resultina in reduced fuel shipments to the reactor and reduced spent fuel shipments from the reactor.
However, there will be an Increase in the shipment of low level solid wastes.
Even when this increase in
- The report does not clearly state the assumptions regarding fuel enrichment and :rradiation levels.
However, since Table S-4 in 10 CFP. 51.52 is based on 33 GWD/HT, the staff has assumed that SNL analysis must be based on the assumptions contained in 10 CFR 51.52, Table S-4.
1
. low level waste shipment is included with the shipment of fresh fuel and spent fuel, the total shipments for higher irradiation (60 GWD/MT) are still somewhat reduced from those at 33 GWD/MT. As a result o# the reduction in number of shipments there should be some reduction in the estimated number of persons exposed.
There should also be no significant change in heat generated per irradiated fuel cask and the weight restriction for transporting vehicle.
The discharged spent fuel at higher irradiation (60 GWD/MT) will have more long lived radionuclides per unit mass compared with the spent fuel irradiated at 33 GWD/MT.
However, there is a smaller amount of annual spent fuel discharged.
Since each spent fuel package will meet the surface radiation level limits imposed by the transportation regulations and there are fewer packages being shipped, there will be an overall reduction in the impacts of normal transportation at higher irradiation levels.
However, the normal transportation impacts of low level wastes will increase with increased irradiation level.
This is due to the fact that slight increases in cooling water activity could occur through increased inventory and gap release fraction.
Because this activity would need to be removed to keep cooling water activity within licensed technical specification limits, a small increase in the quantity of low level wastes is estimated to occur.
Both NUREG/CR-5009 and NESP-0032 conservatively assume a 20% increase in solid waste at 60 GWD/MT irradiation.
Table II sumarizes the environmental impacts of normal transportation activities at 33 GWD/MT and 60 GWD/MT as presented in NUREG/CR-5009 and NESP-032.
TABLE II - NORMAL TRANSPORTATION RADIOLOGICAL EXPOSURE RISK PERSON REM / REACTOR YEAR Exposure Type PNL NESP-032 NUREG70i-5009 33 GW/MT 60 GW/MT 33 GW/MT 60 GW/MT Occupational 4.2*
3 4.2 3
General Public 3.2*
2.5 3.2 2.0 TOTAL (Normal 7.4 5.5 7.4 5.0 Transportation Exposures)
The above results show that there is in fact an overall reduction in the I
radiological impacts of normal transportation (the calculated impacts are lower than the values reported in Table S-4).
- These values are identical to the rounded off values reported in Table S-4
)
of 10 CFR 51.52, and form the basis of the Commission's determination of no significant adverse environmental impacts of transportation of fuel and wastes to and from nuclear reactor sites.
1
. Environmental impacts also result from transportation accidents.
The extended irradiation of fuel will result in an increase in the actinide and fission product inventory in the fuel. Since the spent fuel is transported after an extended storage at the site (5 years), only the long lived fission products and actinides would remain to contribute to the risk.
The PNL analysis shows that the overall effect of a higher inventory of actinides and long lived fission products would be to increase the projected dose in the event of an accident involving spent fuel by a factor of about 2.7, when irradiation is increased from 33 GWD/MT to 60 GWD/MT.
However, because the increased irradiation will correspondingly decrease the amount of the spent fuel discharged, the overall radiological risk will be reduced by the ratio of irradiation levels. The overall effect of the increase in irradiation to 60 GWD/MT would be to increase the radiological risk of spent fuel transportation accidents by about 50%. As stated earlier, the amount of low level waste is conservatively assumed to increase by about 20% when irradiation levels are increased to 60 GWD/MT.
No significant change in compcsition of low level wastes is expected.
Therefore, the transportation accident risks of low level I
waste shipment would increase by 20%.
The transportation risk associated with new fuel shipments would decrease as shipments decreased due to extended burnup.
Although Table S-4 indicates that the radiological risk of accidents is small and not capable of quantification, the radiological risks of transportation accidents were calculated in NUREG/CR-2325.
For the 1985 transportation model, the SNL calculated radiological risk of 1.8 person-rem / reactor year.
The staff has conservatively assumed from the PNL analyses that the higher irradiation (60 GWD/MT) would result in a 50 percent increase in radiological risks due to transportation (even though for low level waste the increase is expected to be 20% or less and fnr new fuel the risk would decrease with this assumption)
SNL calculated risk of 1.8 person-rem / reactor year would increase to 2.7 person-rem / reactor year at 60 GWD/MT irradiation level.
When accident risks at 33 GWD/MT (SNL value) and 60 GWD/MT (Scaled SNL value) are added to normal impacts (PNL and NESP-032 values in Table II), the overall radiological risks at higher irradiation levels are still lower than the risks at 33 GWD/MT irradiation levels. This is shown on Table III.
The analyses presented in NESP-032 show that the radiological environmental impacts of transportation accidents are small at 33 GWD/MT and remain small at 60 GWD/MT. The NESP-032 finding is consistent with finding in WASH-1238 and the results summarized in Table S-4 of 10 CFR 51.52.
TABLE III - TRANSPORTATION RADIOLOGICAL EXPOSURE RISK PERSON REM / REACTOR YEAR l
PNL NESP-032 NUREG7CW-5009 33 GW/MT 60 GW/MT 33 GW/MT 60 GW/MT Nonnal 7.4 5.5 7.4 5.0 Transportation Exposures Accident Exposures 1.8 2.7 1.8 2.7 (from SNL) 9.2 8.2 9.2 7.7
l
,. The non-radiological impacts of transportation accidents are presented in Table S-4 as follows.
(a) 1 fatality in 100 reactor years (b)
I non-fatal injury in 10 reactor years (c) $475 property damage per reactor years As seen in Table 1, the overall shipments of fresh fuel, spent fuel, and low level waste are slightly reduced. Therefore the likelihood of an accident would decrease with the decreased number of shipments, while the non-radiological consequences of transportation accidents would remain unchanged.
In sumary, the environmental finpacts of extended irradiation up to 60 GWD/MT and increased enrichment up to 5 weigt percent are bounded by the impacts reported in Table G-4 of 10 CFR 51.
Table IV shows the sumary of the comparison of impacts. Table IV also supports the staff's conclusions concerning transportation impacts in the Federal Register Notice 53 FR 6040.
TABLE IV -
SUMMARY
COMPARIS0N OF TRANSPORTATION IMPACTS Table S-4 60 GWD/MT and up to 5 percent enrichment Traffic Density Truck Less than 1 per day No increase Rail less than 3 per month No increase Radiological Risk -
Person REM per year Nonnal Transportation 7
5.0 - 5.5 Accidents 1.8 P.7 Total 8.8 7.7 - 8.2 Non-Radiological Risk 1 Fatality /100 No increase 1
Reactor Years 1 Non-Fatal Injury /
No increase 10 Reactor Years
$475 Property Damage /
No increase Reactor Year I
1
- '.. The above evaluation sets forth the changes resulting from increased enrichment (up to 5 weight percent) and extended irradiation (up to 60 GWD/MT), in the environmental impacts of transportatien of fuel and wastes to and from the light water reactors set forth in Table S-4, 10 CFR 51.
The values cet forth in this detailed analysis represent the contribution of '.he environmental effects of transportation of fuel enriched with uranium 235 above 4 weight i
percent and up to 5 weight percent, and irradiated to levels above 33 GWD/MT and up to 60 GWD/MT to the environmental costs of operating the reactors.
As shown above, the environmental cost contribution of the stated increase in fuel enrichment and irradiation limits are either unchanged or may in fact be reduced from those sumarized in Table S-4, as set out in 10 CFR 51.52(c).
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