ML20151S408

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Forwards Proposed Rule Addition of Ra-222 & Tc-99 Values to Table S-3,Addition of App B-Explanatory Narrative & Revs Resulting from Consideration of High-Burnup Fuel for Comments & Recommendations
ML20151S408
Person / Time
Issue date: 06/13/1988
From: Morris B
NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To: Cunningham R, Shao L, Stohr J
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), Office of Nuclear Reactor Regulation
References
REF-WM-1 NUDOCS 8808150186
Download: ML20151S408 (122)


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NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20655 5

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4 MEMORANDUM FOR: Those on Attached List FROM:

Bill M. Morris, Director Division of Regulatory Applications, RES

SUBJECT:

PROPOSED RULE ENTITLED, "ADDITION OF RADON-222 AND TECHNETIUM-99 VALUES TO TABLE S-3; ADDITION OF APPENDIX B - EXPLANATORY NARRATIVE; AND REVISIONS RESULTING FROM CONSIDERATION OF HIGHER-BURNUP FUEL."

Your assistance is requested in reviewing the enclosed document and providing me with your comments and recommendations.

The following is a summary of this request:

Title:

"Addition of Radon-222 and Technetium-99 Values to Table S-3, Addition of Appendix B - Explanatory Narrative, and Revisions Resulting from Consideration of High-Burnup Fuel."

Task Leader:

S. P. Turel, RDB/DRA/RES Task Number:

RA-701-1 Cognizant Individual: 0. D. T. Lynch, NRR/DREP/PRPB and W. E. Thompson, NMSS/IMNS/0B Requested Action:

Review and comment Requested Completion Date:, July 5, 1988 Backgound: The proposed rule would revise 10 CFR Part 51 as described in the title.

z/L/72%%ctor L-Bill M. Morris, Dire Division of Regulatory Applications, RES

Enclosure:

Proposed FRH 8800150106 0B0803 PDR W AST E PDR WM-1

2 Addressees - Memorandum dated f //S/?g R. E. Cunningham, Director, IMNS, NMSS L. C. Shao, Director, DEST, NRR J. P. Stohr, Acting Director, DREP, NRR D. H. Grimsley, Director, DRR, ARM S. A. Treby, Asst. General Ceunsel, OGC F. P. Gillespie, Directo, PMAS, NRR G. A. Arlotto, Director, DE, RES R. E. Browning, Directot, HLWM, NMSS

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NUCLEAR REGULATORY COMMISSION 10 CFR Part 51 Addition of Radon-222 and Technetium-99 Values to Table S-3, Addition of Appendix B - Explanatory Narrative, and Revisions Resulting From Consideration of Higher-Burnup Fuel AGENCY:

Nuclear Regulatory Commission.

ACTION:

Proposed rule.

SUMMARY

The Commission is proposing to amend its Table of Uranium Fuel Cycle Environmental Data (Table S-3) n 10 CFR P y adding new esti-mates for releases of technetium-99 and radon-222, by updating other esti-mates, and by adding a new appendix to explain the basis for and signifi-cance of the environmental data shown in the table.

One effect of this rulemaking would be to remove the environmental impacts related to the values in Table S-3 from consideration in individual LWR reactor licens-ing proceedings.

Another effect would be to extend the applicability of the rule to cover a broader range of uranium-235 isotope enrichments in fresh nuclear fuel and also to cover the higher irradiation levels now expected to be reached before the spent fuel is removed from the reactor.

DATE:

The comment period expires [ Insert a date allowing 90 days for public comment].

Comments received after this date will be considered if it is practical to do so, but assurance of consideration cannot be given except to those comments received on or before this date.

ADDRESS:

Send comments to the Secretary of the Co'mmission, U.S. Nuclear Regulatory Commission, Washington, DC 20555, Attention: Docketing and Service 05/26/88 1

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1 Branch.

Copies of the comments received may be inspected and copied for a fee at the NRC Public Document Room, 1717 H Street NW., Washington, DC.

FOR FURTHER INFORMATION CONTACT:

W. E. Thompson, Office of Nuclear Material Safety and Safeguards, Telephone: (301) 492-0629, or Stanley P.

j Turel, Office of Nuclear Regulatory Research, Telephone: (301) 492-3739, U.S. Nuclear Regulatory Commission, Washington, DC 20555.

SUPPLEMENTARY INFORMATION

Background

i In November 1972, a document entitled "Environmental Survey of the Nuclear Fuel Cycle"1 (WASH-1248) was published by the Directorate of Licensing of the Atomic Energy Commission (AEC) to establish a technical basis for estimating the environmental impacts of the uranium fuel cycle.

Another report, WASH-1238, "Environmental Survey of Transportation of Radioactive Materials to and from Nuclear Power Plants" was published in December 1972 to establish the basis for estimating the environmental effects of transportation.

These surveys were intended to show the environmental effects that might be attributed to the various operations, including transportation, involved in producing the fuel, reprocessing or storing the spent fuel, and disposing of the radioactive wastes for a light-water-cooled nuclear power reactor (LWR).

In WASH-1248, WASH-1238, and the subsequent Table S-3 and Table S-4 rulemaking proceedings, the Commission considered and disclosed the environmental impacts of the 2 Copies of this and other related documents are available for inspection and copying for a fee at the Commission Public Document Room, 1717 H Street NW., Washington, DC.

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uranium fuel cycle and determined that there was no need to reconsider and reweigh them in each individual reactor licensing proceeding.

On April 22, 1974, the AEC promulgated the fuel cycle rule, which contained Table S-3, "Table of Uranium Fuel Cycle Environmental Data" and Table S-4, "Environmental Impact of Transportation of Fuel and Waste to and from One Light-Water-Cooled Nuclear Power Reactor" (39 FR 14188).

Tables S-3 and S-4 provided a summary of the environmental impacts related to the LWR fuel cycle facilities and processing operations.

The environmental impact values are expressed in terms normalized to show the potential impacts attributable to the fuel required for a year's opera-

. tion of a 1,000-MW(e) nuclear power plant, at an 80% availability factor.

This is referred to as one reference reactor year (RRY) and is assumed to cover the processing of the average amount of uranium necessary for a year's operation of a model nuclear power plant, which produces about 800 megawatts (0.8 gigawatts) of electricity.

The RRY fuel replacement requires, as raw material, about 182 metric tons (tonnes) of Va0s.

Based

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upon U.S. uranium industry averages, which are expected to hold well into the next century, the ore assay is assumed to be 0.1% Us0s and the recovery of uranium from the ore to be about 90%.

Thus, the mining of about 202,000 tonnes of ore per RRY would be required.

The values in the proposed Table S-3 are based on the mining and milling of this quantity of

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ore, and the subsequent processing of related quantities of uranium compounds through all steps of the uranium fuel cycle, including radio-active waste disposal.

On July 21, 1976, the United States Court of Appeals for the District of Columbia Circuit found, in NRDC v. NRC, 547 F.2d 633 (D.C. Cir.1976),

that the original Table S-3 fuel cycle rule was inadequately supported by the record with respect to the impacts from reprocessing spent fuel and 05/26/88 3

[7590-01) radioactive waste management.

Although the Commission appealed this deci-sion to the Supreme Court; it also announced on August 16, 1976 (41 FR 34707), that the rulemaling proceeding on the environmental effects of the fuel cycle would be reopenad before a special Fuel Cycle Rulemaking Hearing Board to supplement the existing record with regard to reprocess-

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ing and radioactive waste management, to determine whether the rule should be amended, and if so, in what respect.

The NRC staff prepared a supple-ment to WASH-1248, which more specifically addressed environmental impacts associated with reprocessing and waste management.

This supplement, NUREG-0116, "Environmental Survey of Reprocessing and Waste Management Portions of the LWR Fuel Cycle," was published in October 1976.

In March 1977, a supplemental report covering the public comments on NUREG-0116, i

staff responses to these comments, and additional information about repro-cess;ng and waste management was made available as NUREG-0216 (Supple-WASH-1248), "Public Comments and Task Force Responses Regarding ment 2 3

'The Environmental Survey of the Reprocessing and Waste Management Por-tions of the LWR Fuel Cycle' (NUREG-0116)." On March 14, 1977, the

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Commission promulgated an interim, amended rule (42 FR 1383).

Public

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hearings on the amended rule were held before the Fuel Cycle Rulemaking Hearing Board between January and April of 1978.

While these proceedings were still in progress, the Supreme Court reversed the decision of the Court of Appeals regarding the Table S-3 rule and remanded it for further j

consideration by the lower court.

Tho Commission, however, elected to complete the special proceeding on reprocessing and waste management, after which they promulgated a final cycle rule (44 FR 45362, 8/2/79) in-corporating mier changes brought out in the hearings.

The Commission also announced that, as recommended by the Hearing Board, it would publish an explanation of the values in Table S-3.

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The Commission had noted in the rulemaking record that effluent release values, standing alone, did not meaningfully convey the environ-

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mental significance of uranium fuel cycles activities.

The focus of interest and the ultimate measure of the impacts of radioactive releases were recognized to be the resulting radiation dose commitments and their estimated health effects.

In 1979, the Commission directed the develop-ment of an explanatory narrative that would convey to the public, in understandable terms, the significance of the release values summarized in the table and would include a discussion of the health effects.

On March 4,1981, the Commission published a proposed rule in the Federal Register (46 FR 15154) for public comment that would have revised its regulations in 10 CFR Part 51 to include the new narrative explanation as an appendix.

The purpose of the appendix was to provide a description of the way in which the Estimates were developed to obtain the values con-tained in Table S-3, and to convey their significance by placing them into perspective with respect to the potential risks they impose.

How-ever, work on this rulemaking was stopped when, on April 27, 1982, the U.S. Court of Appeals for the District of Columbia Circuit, in a decision on the remanded Table S-3 case (Natural Resources Defense Council In1 vs. U.S. Nuclear Regulatory Commission, 685 F.2d 459, D.C. Cir., 1982) combined with other challenges to the interim and final rules, vacated the Commission's original, interim, and final fuel cycle rules governing the treatment of uranium fuel cycle environmental impacts in individual nuclear power reactor licensing proceedings.

This decision was also appealed to the U.S. Supreme Court.

On June 6, 1983, in a unanimous deci-sion, the U.S. Supreme Court upheld all three versions of the Commis-sion's Table S-3 rule (Baltimore Gas and Electric Co. vs. NRDC 51 05/26/88 5

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l U.S.L.W. 4678).

The Supreme Court did not make publication of an explanatory narrative mandatory.

Following the Supreme Court decision, the Commission decided to continue its previous rulemaking procedures, including a discussion of the comments that had been received on the proposed rule.

In addition, the rulemaking would be expanded by adding new values for radon-222 (Rn-222) and technetium-99 (Tc-99), updating other values in Table S-3, and substantially revising the narrative explanation from that presented in the Federal Register notice (46 FR 1514, March 4, 1981).

NBCNP Petition for L m.naking i

On November 5, 1975, the New England Coalition on Nuclear Pollution j

(NECNP) submitted a petition to the Commission requesting amendment of Table S-3 in 10 CFR Part 51.

A nMice of the filing of their petition was published in the Federal Register (41 FR 2448) on January 16, 1976 and it was assigned Docket No. 51-1.

The Commission's response to the petition was published in the Federal Register (43 FR 15613) on April 14, 1978, summarizing the content of the petition and explaining the Commis-sion's action with respect to the issues raised by the petition.

In summary, the Commission's response was that (1) the request for Table S-3 to be amended to revise the values for tritium, krypton-85, and carbon-14 was in effect granted, (2) the portion of the petition requesting that Table S-3 be amended to include health effects was denied (but it was noted that the Commission would reexamine this issue at a later date),

l and (3) the portion of the petition requesting that the value for Rn-222 j

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be revised was decided by deleting the radon-222 value from Table S-3.

Pending generic consideration of a new estimate of radon releases from the uranium fuel cycle, the Commission stated that this issue could be evaluated in individual nuclear power plant licensing proceedings.

The new estimates of the values for radon-222 and technetium-99 that are l

included in the prasent propa. sed rule complete the Commission's response to the NECNP petition.

Light Water Reactor (LWR) Fuel Irradiation The values shown in Tables S-3 and S-4 of Part 51 were originally I

developed on the basis of an average fuel irradiation (burnup) of 33,000 megawatt-days (of thermal power) per metric ton of uranium (33,000 MWD /MTU).

Discussions and analyses in NUREG/CR-5009 (PNL-6258), "Assess-ment of the Use of Extended Burnup Fuel in Light Water Power Reactors,"

February 1988, shew that irradiation of fuel up to 60,000 MWD /MTU will result in environmental impacts that are no greater and in many instances are less than the values shown in Tables S-3 and S-4 (see especially Table S.1 on page viii in NUREG/CR-5009).

Thus no revision to these tablu would be required as a result of extended fuel burnup to at least 1

60,000 MWD /MTU.

In order to extend the period between fuel changes, which l

is a major reason for going to the higher burnup, it is necessary to 1

increase the initial uranium-235 (U-235) enrichment level in the fresh fuel.

Analyses for both BWR and PWR type fuel show that reactivity (criticality) safety can be assured and that releases of radioactivity will not increase with enrichment levels up to 5.5 percent U-235.

If necessary, high burnup fuel can be stored for additional time until the l

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radioactivity decays enough to be within limits for shipping.

Experience i

in handling fuel with burnups over 55,000 HWD/MTV and up to 5.5 percent U-235 enrichment has not revealed any unresolved safety problems.

The original analyses on which Table S-4 was based is the report HUREG-75/038, "Environmental Survey of Transportation of Radioactive Materials to and from Nuclear Power Plants, Supplement 1," published in i

April 1975.

This report shows that the transportation distances for l

spent fuel and high-level wastes were assumed to be less than 1000 miles j

for almost all reactors except those located in the far western states.

Shipping distances for other packaged wastes were assumed to be even shorter.

The locations selected for the high-level waste repository and the Regional disposal sites for low-level wastes result in high-level waste transportation distances that, on the average, are longer than i

i those assumed in NUREG-75/038 and low-level waste transportation dis-tances that are shorter.

The environmental impacts of transportation are so small that even an increase by a factor of 10 would not significantly change the total environmental impacts of the whole fuel cycle.

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location of the high-level waste will be at Yucca Mountain in Nevada.

The values in Table S-4 do not need to be updated, because the con-servatism built into these estimates assures that the total fuel cycle environmental #mpacts per reactor are not underestimated.

This rule would not change the data in Table S-4, but Section 51.52, "Environmental ef fects of transportation of fuel and waste-Table S-4," would be revised to change the reference from four percent U-235 enrichment to 5 percent in paragraph (a)(2) and to change reference to irradiation of fuel from 33,000 MWD /MTU to "60,000 HWD/HTU" in paragraph (a)(3).

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New and Updated Estimates for Table S-3 Radon is emitted from mining and milling activities and has been the subject of extensive investigations and regulatory actions by the Environ-mental Protection Agency (EPA) as well as the NRC.

Technetium-99 is a fission product and is created in the amount of about 14.5 curies (Ci) per tonne of uranium in the spent fuel.

It, also, has been investigated by EPA, as well as NRC, in studies of the environmental effects of radio-active waste management activities.

Information from these investigations provides the technical data base for the new estimates in Table S-3.

The

, narrative explanation of Table S-3 is based on the additional information available in WASH-1248, as supplemented by NUREG-0116, NUREG4216, the Table S-3 rulemsking record, and new reports on the results of research.

Further review of the information on radon-222 releases from the uranium fuel cycle was provided by staff testimony in individual nuclear power plant hearings and in a hearing before the Atomic Safety and Licensing Appeal Board in Harrisburg, Pennsylvania on February 26, 27, and 28, 1980.

At this hearing, the radon-222 releases and their postulated health effects, which.had been presented by the NRC staff in 17 individual reactor licens-ing cases, were reconsidered by the Appeal Board, along with the views of intervenors and other interested parties.

The Commission made public the documents containing the technical data which provided the basis for the staff's radon estimates given in testimony at the hearing.

The final environmental impact statement on uranium milling, NUREG/CR-0706, "Final Generic Environmental Impact Statement on Uranium Milling," was published in September 1980.

A report 05/26/88 9

[7590-01) on the research program to determine Rn-222 releases from underground mines, NUREG/CR-1273, "An Investigation of Radon-222 Emiss 4ns from Under-ground Uranium Mines," was published in February 1980.

A report on the research program to determine Rn-122 releases from open pit mining, NUREG/CR-2407, "Radon and Aerosol Release from Open Pit Uranium Mining,"

was published in August 1982.

The staff's Rn-222 estimates, which were intreduced into the public record in the Perkins and other reactor licens-ing proceedings, had been developed using preliminary data from these research programs.

The Appeal Board decision (ALAB-640, May 13, 1981) l supported the staff's estimates of radon-222 releases from the uranium fuel cycle.

Subsequently, on September 17, 1982, the staff notified the appeal board and all parties to the hearing that the final report on Rn-222 releases from the open pit mining presented new data that increased the total fuel cycle releases by an estimated 10L Since then, other minor changes have been made as a result of new Environmental Pro-tection Agency standards for controlling radon releases from underground mining and from mill tailings.

These changes are included in the new values now being added to the table.

A further increase of 20%, which would have been required because the uranium from spent fuel is not being recovered and recycled in the United States, as was originally assumed in WASH-1248, is offset by improvements in fuel management in the reactor and by lower operating capacity factors.

These two changes, in total, have reduced the average annual uranium requirement per RRY by 20L The Appeal Board's decision on health effects (ALAB-701, 16 NRC 1517, November 19,1982) supported the staff's estimates, but was appealed by

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the Three Mile Island and Peach Bottom Intervenors to the Commission for review.

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i On May 27, 1983 the Commission, in memorandum CLI-83-14 (In the i

Matter of Philadelphia Electric Company et al.), deferred further sepa-

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rate consideration of the radon issues in individual nuclear power plant licensing proceedings pending the final Commission decision on the appro-priate disposition of the ALAB-701 decision.

The Commission's final decision is scheduled to be formalized after completion of action on this present rulemaking.

With respect to technetium-99 (Tc-99), the Commission had noted in its promulgation of the final fuel cycle rule on August 17, 1979 (44 FR 45362), that releases of technetium from the fuel cycle were not included in Table S-3 and could be considered in individual licensing proceedings.

A value for Tc-99 had not previously been included in Table S-3, because there was no scientific basis for establishing a reliable estimate.

The original hearing board concluded that an assumption of complete release of iodine-129 (I-129) tended to compensate for the omission of a Tc-99 value.

In February 1985, the Commission published NUREG/CR-3738, "Envi-ronmental Effects of the Uranium Fuel Cycle - A Review of Data for Tech-netium." This document reviewed sources of potential releases of Tc-99 from both the uranium-only and the no recycle fuel cycle options.

The i

values for Tc-99 which are being added to Table S-3 through this rule-making are based primarily on this document.

Findings The Commission finds, based on the Table S-3 rulemaking record, that the fuel cycle impacts addressed by Table S-3 do not significantly, within the meaning of being important and caused by something other than 05/26/88 11

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chance, affect the environmental cost-benefit balance for a light water reactor.

As provided in proposed 10 CFR SS 51.51 and 51.75, after (insert date of the effective rule), Table S-3 and the material in the explanatory narrative will be referenced in environments 1 reports and encironmental impact statements as supoort for a generic conclusion that these fuel cycle impacts do not significantly affect the cost-benefit balance for a light water reactor.

No further consideration of fuel cycles impacts rasulting from the values in Table S-3 shall be required in individual LWR licensing proceedings.

i Finding of no Significant Environmental Impact The Commission has determined, under the National Environmental Policy Act of 1969, as amended, and the Commission's regulations in Sub-part A of 10 CFR Part 51, that promulgation of this regulation is not a major Federal action significantly affecting the quality of the human environment and therefore an environmental impact statement is not required.

The proposed action deals with the environmental impacts of the uranium fuel cycle, but it will not have any environmental impact of its own.

It is concerned with studies and analyses and the writing of envi-ronmental reports.

Thus, its impact is on LWR license applicants' and NRC resources, rather than on the environment per se.

Table S-3 will provide the basis for treating the environmental impacts from the LWR uranium fuel cycles generically, instead of requiring that these issues be consid-ered at each individual LWR power reactor licensing proceeding.

By using a generic and summary explanation, there will be significant reduction of 05/26/88 12

[7590-01) time and effort on the part of license applicants, NRC staff, and other participants.

Although the extensive efforts involved in revisions and litigations represent adverse impacts from generic use of the table since it was promulgated in 1974, nevertheless, it is believed that the major issues have been decided and that litigations in the future will have less impact on the NRC staff and other participants.

Paperwork Reduction Act Statement This final rule does not contain new or amended infoNation ColleC-tion requirements subject to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.).

Existing requirements were approved by the Office of Management and Budget approval number 3150-0021.

Regulatory Flexibility Certification In accordance with the Regulatory Flexibility Act of 1980, 5 U.S.C.

605(b), the Commission hereby certifies that this rule will not have a significant economic impact on a substantial number of small entities.

This rule affects only the licensing of nuclear power plants which do not fall within the scope of the definition of 'small entities" set forth in the Regulatory Flexibility Act, 5 U.S.C. 601, or the Small Business Size Standards set out in regulations issued by the Small Business Administra-tion at 13 CFR Part 121.

Since these companies are dominant in their service areas, this rule does not fall within the purview of the Act.

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List of Subjects Administrative Practice and Procedure, Environmental Impact State-ment, Nuclear Materials, Nuclear Power Plants and Reactors, Reporting Requirements.

For the reasons set out in the preamble and under the authority of the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, as amended, the National Environmental Policy Act of 1969, as amended, and 5 U.S.C. 552 and 553, the NRC is considering adopting the following amendments to 10 CFR Part 51.

PART 51 -- ENVIRONMENTAL PROTECTION REGULATIONS FOR DOMESTIC LICENSING AND RELATED FUNCTIONS 1.

The authority citation for 10 CFR Part 51 continues to read as follows:

AUTHORITY:

Sec. 161, 68 Stat. 948, as amended (42 U.S.C. 2201);

secs. 201, as amended, 202, 88 Stat. 1242, as amended, 1244 (42 U.S.C.

5841,5842).

Subpart A also issued under National Environmental Policy Act of 1969, secs. 102, 104, 105, 83 Stat. 853-854, as amended (42 U.S.C.4332, 4334, 4335); and Pub. L.95-604, Title II, 92 Stat. 3033-3041.

Section 51.22 of 10 CFR Part 51 also issued under sec. 274, 73 Stat. 688, as amended by 92 Stat. 3036-3038 (42 U.S.C. 2021).

2.

In Section 31.51, paragraph (a) is revised to read as follows:

6 51.51 Uranium fuel cycle environmental data - Table S-3, 05/26/88 14 l

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i (a) Every environmental impact report prepared for the construction permit stage of a light-water-cooled nuclear power reactor, submitted on or after [ Insert effective date of the final rule], Eshaii3 must take Table S-3, Table of Uranium Fuel Cycle Environmental Data and the hecith effects shown in Appendix B, "Table S-3 Explanatory Analysis," as the basis for evaluating the contribution of the environmental effects of uranium min-ing and milling, the production of uranium hexafluoride, isotopic enrich-ment, fuel fabrication, reprocessing of irradiated fuel, transportation of radioactive material, and management of low-19 vel wastes and high-level wastes related to uranium fuel cycle activities to the environmental costs of licensing the nuclear power reactor.

Table S-3 [shali) must be included in the environmental report.

[and-may-be-supplemented-by-a-discussion-of the-environmentai-significance-of-the-data-set-forth-in-the-table-as weighed-in-the-analysis-for-the proposed-facility-]

3.

Section 51.51.(b) is revised to read as follows:

6 51.51 Uranium fuel cycle environmental data - Table S-3.

(b) Table S-3 05/26/88 15

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Table S-3 Table of Uranium Fuel Cycles Environmental Data!

Maximum effect per refer-ence reactor year of model Environmental considerations Totals 1000-MWe LWR Natural Resources Land (acres):

Temporarily committed 168 Undisturbed area 125 Disturbed area 43 Equivalent to a 110-MWe coal-fired power plant.

Permanently committed 18 Overburden moved (millions 2

of tonnes )

6 Equivalent to a 95-We coal-fired power piant.

Water (millions of gallons):

Discharged to air 242 2% of model 1,000-MWe LWR with cooling tower.

Discharged to water bodies 11,100 Discharged to ground 273 Total 11,600 Less than 4% of model 1,000-MWe LWR with once-through cooling.

Fossil fuel:

Electrical energy (thousands of MW-HRS) 325 Less than 5% of model 1,000-MWe LWR output.

Equivalent coal (thousands of tonnes) 120 Equivalent to the consumption of a 45-MWe coal-fired power plant.

Natural Gas (million-SCF) 140 Less than 0.4% of model 1,000-MWe energy output.

2 Wastes are maximized for either of the two fuel cycles considered (uranium only or no recycle).

The contribution from transportation ex-cludes transportation of cold fuel to a reactor and of irradiated fuel from a reactor, which are considered in Table S-4 of 6 51.52(c). The contributions from the other steps of the fuel cycle are given in columns A-H of Table S-3A in the accompanying narrative explanation (see Appendix B), which is a modification of Table S-3A of WASH-1248.

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Table S-3 Table of Uranium Fuel Cycles Environmental Datal (Continued)

Maximum effect per refer-ence reactor year of model Environmental considerations Totals 1000-MWe LWR Chemical Effluents (Tonnes) l Combustion Gases (including entrainment): 3

(

50 4,457 l

N0**

1,192 Equivalent to emissions from 45-MWe coal-fired power plant for 1 year.

Hydrocarbons 16 C0 30 Particulates 1,164 Other Gases:

l F-0.6 Principally from UFs production, enrichment, and reprocessing.

Con-centration within range of State standards - below l

1evels that have effects l

on human health.

Liquids:

50 -

9.9 From enrichment, fuel 4

NO3-26.0 fabrication, and rep *o-Fluoride 12.9 cessing steps.

Components Ca++

5.4 that constitute a pote0-Cl-8.5 tial for adverse enviror.-

Na-12.1 mental effect are present NH2 11.5 in dilute concentrations Fe

.4 and receive additional dilution to levels that i

are below permissible standards in the bodies of water they mix with.

Tailings solutions (thousands From mills only - no of tonnes) 528 significant effluents to the environment.

j 1

Solids:

260,000 Principally from mills -

j no significant effluents l

to the environment.

3 Estimated effluents are based on combustion of equialent coal for power

'i generation, primarily for U-235 isotope enrichment.

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Table S-3 Table of Uranium Fuel Cycles Environmental Datal (Continued)

Maximum effect per refer-ence reactor year of model Environmental considerations Totals 1000-MWe LWR Radiological Effluents (Curies)

Gases (including entrainment):

Rn-222 4,866 Released during mining and milling operations to pro-duce the uranium required for one RRY.

Rn-222 33Ci/yr Long-term releases from mining and milling sites after decommissioning.

Ra-226 0.0 Th-230 0.1 Uranium 0.1 Tritium (thousands) 18 C-14 24 Kr-85 (thousands) 40 Ru-106 0.1 Principally from fuel reprocessing plants.

1-129 0.0004 I-131 0.8 Tc-994 0.006 Fission products and TRU

.230 Liquids:

Uranium and daughters 4.5 Prix.jally from milling -

incluoed in mill tailings and returned to the ground.

Ra-226 3x10 3 From UFs production.

Th-230 1.5x10 3

  • Tc-99 from chemic61 reprocessing is removed from recycled UFs before it enters the isotope enrichment cascade.

About 4 ppm is recycled to the front-end of the LWR fuel cycle.

This entry is only for the recycled portion.

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Table S-3 Table of Uranium Fuel Cycles Environmental Datal (Continued)

Maximum effect per annual fuel requirement or refer-ence reactor year of model Environmental considerations Totals 1000-MWe LWR i

Th-234

.01 From fuel fabrication plants.

Fission and activation products 3/yr Released into groundwater from a Federal Repository.

Tc-99 0.005/yr Released into ground water from a Federal Repository.

Stored Solids (Not effluents)

Other than high-level 11,300 9,100 Ci from low-level wastes and 1,500 Ci from reactor decontamination and decommissioning buried at land burial facilities.

600 Ci from natural uranium decay products will be included in mill tailings returned to the ground.

There are no significant releases into the environment from these sources.

TRU and High-level wastes 11x106 Buried at Federal Repository Tc-99 507 Buried at Federal Repository Effluents - thermal (billions of BTU. )

4,145 5% of model LWR thermal l

effluents.

]

Transportation (person-rem) exposure of workers and public 2.5 Occupational exposure

[ person-rem) 180 Primarily from uranium mining and milling and spent fuel reprocessing.

05/26/88 19

[7590-01]

4.

Section 51.52 is revised to read as follows:

S 51.52 Environmental effects of transportation of fuel and waste-Table S-2.

AAA (a) ***

(2) The reactor fuel is in the form of sintered uranium dioxide pellets having a uranium-235 enrichment not exceeding [40%) 5.0% by weight, and the pellets are encapsulated in zircaloy rods; (3) The average level of irradiation of the irradiated fuel from the reactor does not exceed 50,000 megawatt-days per metric ton, and no

. irradiated fuel assembly is shipped until at least 90 days after it is discharged from the reactor.

A A

A A

A 5.

Footnote number 1 in Table S-4 is revised to read as follows:

1.

Data supporting this table are principally taken from the 1

Commission's "Environmental Survey of Transportation of Radioactive Mate-rials to and from Nuclear Power Plants," WASH-1238, December 1972, from "Environmental Survey of Transportation of Radioactive Materials to and l

from Nuclear Power Plants, Supplement 1," NUREG-75/038, April 1975, and from NUREG/CR-5009, "Assessment of the Use of Extended Burnup Fuel in Light Water Power Reactors, December 1987.

These and other pertinent documents are available for inspection and copying for a fee at the Commission's Public Document Room at One White Flint North, 11555 Rockville Pike, Rockville, MD 20555.

These documents may be purchased from the National Technical Information Service, Springfield, VA 22161.

05/26/88 20


,----,.,,,-_.,-e.--

i

[7590-01]

l 6.

Section 51.75 is revised to read as follows:

S 51.75 Draft environmental impact statement - Construction permit i

A draft environmental impact statement relating to issuance of a construction permit for a production or utilization facility will be prepared in accordance with the procedures and measures described in SS 51.70, 51.71, 51.72, and 51.73.

The contribution of the environmental effects of the uranium fuel cycle activities specified in S 51.51 [shall]

must be evaluated on the basis of impact values set forth in Table S-3, Table of Uranium Fuel.fcle Environmental Data, which [shail] must be set out in the draft environmental impact statement.

[With-the-exception-of

.raden-222-and-technetium-99-releases-] No further discussion of fuel cycle release values and other numerical data that appear explicitly in the tatle shall be required.[4] [The-impact-statement-mest-take-acceent ef-dese-eemmitments-and-hesith-effects-from-feei-cycie-efficents-set-forth i n-T a b l e 3-a n d-me s t-i n-a d di ti o n-t a k e - a c c e en t-o f-e c o n om i c-- s o ci e e t e n emi c -

and pessible-cameistive-impacts-and-such-other-feel-cycie-impacts-as-may reasonabiy appear-significant.]

7.

Delete footnote 4 in 951.75.

8.

A new Appendix is added to read as follows:

APPENDIX B TABLE S-3 EXPLANATORY ANALYSIS Section I The Light Water Reactor Uranium Fuel Section II Potential Radiation Doses, Health Effects, and Environmental ImpactsSection III - Potential Radiation Doses, Health Effects, and Er :ironmental Impacts 05/26/88 21

[7590-01]

SECTION I.

THE LIGHT WATER REACTOR URANIUM FUEL A.

Introduction Table S-3, "Table of Uranium Fuel Cycle Environmental Data," ident-ifies the estimated environmental and radiation impacts from the plants and activities that comprise the light-water-cooled nuclear power reac-tor (LWR) uranium fuel cycles.

The purposes of this narrative are to explain the derivation of the values in the table, to assist the reader to use and apply the data in the table, to discuss and evaluate the potential radiation doses, and to explain the estimated health effects which may result from uranium fuel cycle operations.

The values in Table S-3 are derived primarily from information con-tained in reports listed in the bibliography at the end of this section.

These documents and the complete record of the rulemakings, as well as other documents referenced in the narrative, are available for public inspection and copying, for a fee, in the NRC Public Document Room at 1717 H Street, NW, Washington, DC.

Section I of this appendix contains a discussion of the fuel cycles.

In it the individual operations of the LWR uranium fuel cg les are briefly described.

Section 11 contains a description of the environ-mental and radiation impacts estimated to result from the operations and activities of the LWR uranium fuel cycle.

Section III.A contains a dis-cussion of the estimated radiation doses, dose commitments, and the health effects that might result from these releases.

Section III.B includes a discussion of how dose evaluations over extended periods of time might be performed and what their significance might be.

Section III.C contains a 05/26/88 22

[7590-01) discussion of what, if any, radiation impacts might result from releases of radioactive waste from disposal sites over very long periods of time.

An attempt has been made to discuss and explain the purposes and application of Table S-3 values in terms that are easily understood by the general public.

The rulemaking records, dating from April 22, 1974 (39 FR 14188) under docket RM-50-3, contain the explanations and tech-nical evaluations necessary to support the regulatory positions.

Differ-ences of opinion on these positions will continue, because there is no factual manner to prove the true value for estimated data.

No attempt has been made to discuss socioeconomic impacts for each of the LWR fuel cycle facilities.

The staff has examined these impacts, but did not discover any that are significant or unusual in relation to the impacts discussed in this appendix.

It has been concluded that socio-economic values are best derived and evaluated on an individual case basis when licensing the particular fuel cycle facility.

This is done in the initial licensing process when the applicant evaluates the structures, systems, and components in an environmental report, which is submitted with the license application.

The environmental report is reviewed by the NRC staff and a final evaluation which includes socioeconomic impacts is issued in its environmental impact statement or environmental assessment.

Table S-3 shows the estimated environmental impacts attributable to the LWR uranium fuel cycles, normalized to the annual fuel requirement for a reference reactor year (RRY).

For the purposes of developing the f

values in Table S-3 the model LWR was assumed to have a capacity of 1000 megawatts of electric power and to operate at 80% of its rated capacity.

Thus, it produces about 800 MW years (0.8 gigawatts) of electricity per year.

The annual fuel replacement requirement, averaged over an assumed 05/26/88 23

[7590-01]

i reactor operating lifetime of 30 years, was labelled "annual fuel require-ment" (AFR) in WASH-1248.

The term AFR was changed to "reference reactor year" (RRY) in NUREG-0116 and NUREG-0216, because the acronym AFR was being used extensively to designate "away-from-reactor (AFR)" storage of spent fuel at the time NUREG-0116 and -0216 were issued.

The term refer-ence reactor year, or RRY, will be used in this narrative.

For purposes of this narrative, the operations necessary to process the fuel up to the time it is put into the reactor are collectively refer-red to as the "front end" of the fuel cycle.

The operations or activ-ities associated with the front-end are mining (which is not licensed by NRC), milling, production of uranium hexafluoride (UFe), uranium-235 (U-235) isotope enrichment, and fuel fabrication.

The "back end" of the fuel cycle consists of the operations following irradiation of the fuel.

The steps in the back-end of the fuel cycle are disposal of spent fuel or chemical reprocessing of the spent fuel to recover the useful elements and disposal of the high-level (HLW) and low-level (LLW) radioactive wastes.

For purposes of this narrative only the uranium is presumed to be recycled, i

B.

Alternative Fuel Cycles Several different fuel cycles could be used to provide fuel for an l

LWR. The alternatives discussed in this narrative are:

Once-Through Fuel Cycle:

\\

The spent fuel would be disposed of without recovery of residual l

fissionable isotopes.

This is essentially the present operating mode 05/26/88 24

[7590-01) for all LWRs in the United States, because spent fuel currently is being stored and not reprocessed.

The Nuclear Waste Policy Act of 1982 (NWPA) provides for long-term storage of commercial spent fuel in a Monitored Retrievable Storage Facility (MRS) and for the disposal of spent fuel and other high-level radioactive waste at a repository.

Repository is defined here as any system licensed by the Commission that is intended to be used for the permanent deep geologic disposal of HLW and spent fuel.

Uranium-Only Recycle:

Uranium could be recovered from spent fuel by chemical reprocessing and could be recycled with fresh uranium to make LWR fuel.

Plutonium could be stored separately or combined with residual radioactive materials as wastes.

Uranium-only recycle, including plutonium storage, was con-sidered to be the most likely alternative at the time that WASH-1248 was prepared (1972-1974), and was the principle fuel cycle addressed in that document.

In NUREG-0116, plutonium was considered to be a waste which would be disposed of at a repository.

In updating Table S-3, the Com-mission has reconsidered the environmental impact estimates for uranium mining and milling but has not revised them to reflect the fact that uranium from spent fuel is not being recovered and recycled in the United States as had been assumed in the earlier Teble S-3 estimates.

This is because the 20% increase in uranium mining and milling which would have been required to make up for the loss of recycled uranium has been offset by a 20% reduction in uranium requirements as a result of improvements in fuel management in the reactsr and of experiencing operating capacity factors below t coM 89%.

If, in the future, the uranium recycle 05/26/88 25

[7590-01) is initiated, uranium mining and milling requirements will be reduced, l

and the environmental impacts will be less than the new estimates given in Table S-3.

Uranium and Plutonium Recycle Both uranium and plutonium can be recovered from spent fuel by chem-ical reprocessing and can be recycled as mixed oxide fuel to the reactor.

The wide scale use of this fuel cycle was considered in the Commission's rulemaking proceedings on the use of recycled plutonium as mixed oxide

. fuel in a LWR, which was covered by the generic environmental impact statement report, NUREG-0002 (referred to as the GESMO report).

For purposes of this narrative, the mixed oxide fuel cycle is not considered licensable, because the GESMO rulemaking proceedings were never completed. The only two LWR fuel cycles that are considered cur-rently licensable in the United States are the once-through uranium fuel cycle and the uranium-only recycle.

The repro:essing and waste manage-ment activities related to these fuel cycles were considered in WASH-1248, and were more thoroughly reviewed in NUREG-0116.

The NUREG-0116 values are incorporated into Table S-3, and the totals include the larger of the environmental and radiation impact values from either of these two fuel cycles. This is done to ensure that impacts are not underesti-mated, regardless of which fuel cycle is actually used.

The total values for the fuel cycle to support one re'm ence reactor year (RRY) are included in Table S-3.

Even though there are no reprocessing plants operating in the United States at this time, both the once-through and the uranium-only fuel cycles are considered, in order to cover the 05/26/88 26

l

[7590-01]

possibility that reprocessing may be started in the future, within the operating lifetime of nuclear power plants being licensed on the basis of Table 5-3 data, l

C.

Fuel Cycle Operations The five operations involved in preparing fresh fuel for use in a reactor, known collectively as the front end of the fuel cycle, are shown in Figure 1.

Although mining is not licensed by the NRC, radon-222 is released at this stage and, with other mining impacts, is included in TaLle S-3.

In the milling step, the ore is leached, eitF.er by acid or caustic solutions, to selectively dissolve the uranium.

The product from milling is called "yellowcake," which is an impure uranium oxide.

The yellowcake is purified and converted to uranium hexafluoride (UFs) at a UFs conversion plant.

The UFs is fed into an isotope enrichment cascade where the uranium-235 (U-235) is enriched from about 0.7% (the natural abundance of this isotope) to a value generally in the range of 3 to 5.5%.

In the United States, enrichment operations to date, the U-238 and U-235 isotopes have been separated by a process involving diffusion through a porous membrane.

The enrichment plant consists of a large number of separation stages cascaded in series.

The U-235, being lighter than the U-238, diffuses more rapidly through the membranes.

The process involves separation of the gas streams enriched in U-235 from the streams depleted in U-235.

The stream depleted in U-235 (commonly called tails) is removed and stored in metal cylinders.

The enriched UFe is withdrawn in smaller cylinders and shipped to a fuel fabrication plant, where the UFs is converted to uranium dioxide, which is compacted into pellets and l

05/26/88 27

[7590-01)

Figure 1 (Get camera-ready copy) 05/26/88 28

[7590-01]

u

.o zircaloy tubes (rods).

The rods are then fabricated into x waolies, which are especially designed for each type of reactor.

The operations following irradiation of the fuel in the reactor are known collectively as the back end of the fuel cycle.

In the once-through 1

fuel cycle (Figure 2A), the spent (irradiated) fuel from the LWR is stored at the reactor, at an independent spent fuel storage installation (ISFSI),

i or at a Monitored Retrievable Storage (MRS) facility.

The spent fuel is then presumed to be packaged and disposed of in an underground repository.

I In the uranium-only recycle mode (Figure 2B), spent fuel is stored until shipped to a reprocessing plant. There the uranium is recovered in a form suitable for feed to enrichment plants and combined with fresh uranium feed material.

Af ter enrichment, it is converted to U02 and fabricated into new fuel and recycled as the LWR fuel replacement.

The recycling of uranium would result in a saving of about 20% in the quantity of uranium that must be mined and milled to provide fuel for one RRY.

D.

Annual Throughput of the Model Reactor Fuel Cycle and the Effects of Higher Burnup of the Fuel The quantity of uranium which must be processed in each step of the fuel cycle depends upon the processing losses and factors related to the characteristics of the uranium compound being produced.

It is also affected by the extent of burnup of the U-235 in the nuclear power plant.

Burnup is expressed in terms of the number of megawatt-days (HWD) or reac-tor power output per metric tonne of uranium (HTV) in the reactor fuel.

Going to higher levels of burnup means that the fuel stays in the reactor 4

longer before it must be replaced with new fuel, and therefore the aver-age number of tonnes of fuel per year of operation is reduced. When 05/26/88 29

[7590-01) l Figure 2A and 2B (Get camera-ready copy) t 05/26/88 30

[7590-01]

Table S-3 was first developed, reactor fuel burnups were expected to average about 33,000 MdD/MTV with annual shutdowns for reloading part of the fuel, and this fuel management plan was the basis for the estimates for Table S-3.

Since then burnup levels as high as 50,000 to 60,000 MdD/

MTU have been investigated, with fuel reloading schedules extending to 18 or 24 months.

Some reactors are operating on fuel management plans that call for an average burnup level of 45,004 MWD /MTU and reloading on an 18-month cycle.

It is expected that higher burnup levels will be employed by more reactors in the future because going to higher burnup reduces the quantity of uranium required for the fuel, reduces the reactor down time for fuel reloading, reduces the quantity of spent fuel that must be stored, reduces the number of fuel shipments to and from the reactor site, and reduces the occupational radiation exposure of workers.

However, going to higher burnup requires higher enrichment of U-235 in the fuel to support the longer lifetime in the reactor.

This means that more uranium must be supplied to the enrichment process to produce a ton of fuel grade enriched uranium, but this is more than offset by the reduc-tion in the number of tons of uranium needed for a year's operation of the reactor, as shown in Table 1.

Analyses of the sensitivity of calculated values to changes in basic assumptions have shown that extending the reload interval to 24 months requires higher enrichment in the fuel and increases the mining, milling and enrichment requirements by about 5%.

Although the 24-months reload cycle offers some advantages, it has some disadvantages also, and does not significantly reduce the annual fuel consumption.

The 24-month reload interval has not come into wide use; most high-burnup operating plans are based on the 18-month reload cycle.

05/26/88 31

[7590-01]

Table 1 Requirements for One Reference Reactor Year * (RRY)

Fuel Cycle Output Burnup Level (MWD /MTU)

(18-month reload cycle) 33,000 40,000 50,000 60,000 Mining (MT of ore) 202,000 195,000 191,000 190,000 Milling (MT of U 0s) 182 175 172 171 3

Enrichment Level (weight % U-235) 3.6 4

4.6 5.4 UFs Conversion (MT of UFs) no recycle 270 260 255 254 with recycle of uranium 216 208 205 204 Separative Work Units (MT) 134 133 132 135 Fuel Fabrication (MT of UO )

40 32.7 26.1 21.8 2

Fuel for 1 RRY (MT of V) 35 28.9 23.1 19.3 "Data based on Table 3.11 in AIF/NESP-032, "The Environmental Consequences of Higher Fuel Burnup," June 1985.

Detailed studies of the effects of higher burnup indicate that nearly all the environmental impact values in Table S-3 are the same or less at the 60,000 MWD /MTU burnup level as at 33,000 MWD /MTU.

The few that are calculated to be higher are not significantly higher, reflect-ing at most increases of about 10%, which is within the error band of the estimates and well below the limits which are acceptable under EPA and other environmental regulations.

The change to high burnup causes increases in the quantity of fission product and transuranium elements in the spent fuel assemblies.

The number of fissions of U-235 atoms per ton of fuel is directly propor-tional to the burnup; at 60,000 MWD /MTV the number is 1.82 times higher than at 33,000 MWD /MTV.

It should be noted that the number of fissions required to produce a year's power output (800 MW years) of the model reactor is the same, whether the burnup level is 13,000 WD/MTU, 60,000 l

MWD /MTV, or some other level.

The difference it. in the number of fis-sions per tonne of fuel.

At higher burnup, there will be fewer tonnes 05/26/88 32

[7590-01]

per RRY but more fissions per tonne.

However, the concentration el shnrt-lived fission products per tonne of fuel in the reactor rapidly 1

reaches an equilibrium at which the decay of the fission products balances their forma +. ion, and thereafter they do not increase further regardless of burnup or time, and the total per RRY decreases with the decrease in Y the num5er of tonnes of fuel required for one RRY,g The long-lived fis-sion products continue to increase in the reactor in proportion to the increase in burnup level; but the increase in fission products per tonne of fuel is offset by the decrease in the number of tonnes consumed per year, and there is no net change in the average annual output of long-iived fission products from the reactor.

Based on the results of these detailed analyses, the Commission con-cludes that the values in Tables S-3 and S-4 are conservative and are applicable to fuel burnups at least as high as 60,000 WD/MTU.

Table 2 shows the comparison of environmental impact values for 33,000 WD/MTV and 60,000 WD/MTV.

A 1-RRY quantity of spent fuel, af ter being removed from the reac-tor, still contains nearly all the original uranium with its enrichment depleted to levels slightly above natural uranium. [8).

In a year's operation of the reactor, approximately 1 tonne of U-235 will have been consumed, creating fission products and transuranium elements as well as energy for producing 800 W years of electricity.

For the once-through fuel cycle, the spent fuel is presumed to be stored for at least 5 years before being disposed of at a repository.

The spent fuel might be stored for a shorter period if it were to be chemically reprocessed.

The fis-sion products, TRU, and other radioactive waste are presumed to be pro-cessed for disposal in any case, l

05/26/88 33

[7590-01]

Table 2 COMPARISON OF ENVIRONMENTAL IMPACTS FOR 33,000 MWD /MTV WITH THOSE CALCULATED FOR FUEL BURNUP OF 60,000 MWD /MTU*

Extended BLrnup 33,000 MWD /MT 60,000 MWD /MT Natural Resource Use:

Land (Acres):

Temporarily Committed 168 82 Undisturbed Area 125 63 Disturbed Area 43 19 Permanently Committed 18 11 Overburden Moved (106 MT) 6 2.7 Water (106 Gallons):

Discharged to Air 242 165 Discharged to Water Bodies 11,100 11,462 Discharged to Ground 270 122 Total 11,600 11,741 Fossil Fuel:

Electrical Energy (1000 MWH) 325 331 Equivalent Coal (1000 MT) 120 121 Natual Gas (106 SCF) 140 115 Effluents - Chemical (MT):

Gases:

S0 4,457 4,544 x

N0 1,192 1,219 x

Hydrocarbons 16 14 C0 30 30.2 Particulates 1,164 1,192

  • Based on Table 1 in AIF/NESP-032, "The Environmental Consequences of Higher Fuel Burnup," June 1985.

05/26/88 34

[7590-01]

Table 2 (Cont'd)

COMPARISON OF ENVIRONMENTAL IMPACTS FOR 33,000 MWO/MTU WITH THOSE CALCULATED FOR FUEL BURNUP OF 60,000 MWD /MTU*

Extended Burnup 33,000 MWD /MT 60,000 MWD /MT Effluents - Chemical (MT) (Cont'd):

Other Gases:

F"

0. 6 0.66 Liquids:

x--

50

9. 9 10.0 4

NO 26 11.6 3

Flouride 12.9 10 8 Ca++

5.4 5.6 Cl-8.5 8.7 Na*

12.1 12.3 NH 11.5 7.0 3

l Fe 0.4 0.4 Tailings Solutions (103 MT) 528 512 Solids 260,000 252,000 Effluents-Radiological (Curies):

Gases (Including Entrainment):

Rn-222 4,866 4,572 Rn-222 (after decomississioning) 33/yr 30/yr i

Ra-226 0.0 0.0 Th-230 0.1 0.1 05/26/88 35 7v

[7590-01)

+

Table 2 (Cont'd)

COMPARIS0N OF ENVIRONMENTAL IMPACTS FOR 33,000 MWD /MTU WITH THOSE CALCULATED FOR FUEL BURNUP OF 60,000 MWO/MTU*

Extended Burnup 33,000 MWD /MT 60,000 MWO/MT Effluents Radiological (Curries)

(continued)

Uranium 0.1 0.1 Tritium (Thousands) 18 17.7 C-14 24 15 Kr-85 (Thousands) 40 31 Ru-106 0.1 0.1 1-129 0.0004 0.0005 I-131 0.8 0.5 Fission Products

& Transuranics 0.23 0.26 Liquids Uranium & Daughters 4.5 4.3 Ra-226 0.003 0.003 Tc-99 0.005/yr 0.005/yr Th-230 0.0015 0.0015 Th-234 0.01 0.01 Fission & Activation Products 3.0/yr 2.6/yr 05/26/88 36 e

w.

[7590-01)

Table 2 (Cont'd)

COMPARISON OF ENVIRONMENTAL IMPACTS FOR 33,000 MWD /MTU WITH THOSE CALCULATED FOR FUEL BURNUP OF 60,000 MWD /MTU*

Extended Burnup 33,000 MWD /MT 60,000 MWD /MT Effluents Radiological (Curries) j (continued):

Solids (Buried on Site)

Low Level (Shallow) 11,300 11,300 TRU & HLW* (Deep) (106) 11 11 Tc-99 507 424 Effluents-Thermal (109 BTU):

4,145 4,107 Transportation (Man-Rem)

Exposure of Workers and General Public 2.5

1. 9 Occupational Exposure (Man-Rem) 22.6 12.5 l

l

  • Transuranic and High Level Wastes.

05/26/88 37

[7590-01]

E.

Sensivity of Estimates to Changes in the Fuel Cycle 3 _

y The values given in Tables S-3 and S-4 were calculated from industry averages for the performance of each type of fuel cycle facility or opera-tion.

Recognizing that this approach meant that there would be a range of reasonable values for each estimate, the Commission staff followed the policy of choosing the assumptions or picking the factors to be applied so that the calculated values would not be underestimated.

This approach was intended to make sure that the actual environmental impacts would be less than the quantity shown in Tables S-3 and S-4 for all nuclear power plants within the widest reasonable range of operating conditions.

The following paragraphs discuss the sensitivity of the estimates to changes in assumptions or factors used by the Commission staff in making the environmental impact analyses.

This discussion is provided to show the degree of conservatism used in d weloping estimates, and thus to give an indication of the uncertainty of the estimates when they are applied to a particular nuclear power plant.

The methodology was deliberately

~

constructed to estimate impacts closer to the upper bound than to the mathematical average or median.

Considering this approach, one can judge that the level of precision in the estimates is about 10% at best, prob-ably no more than single significant digit accuracy in most cases.

For this reason, and to simplify the presentation, many subtle fuel cycle parameters and interactions were recognized as being beyond the precision

% of the estimates and were ignored or mentioned briefly to show that they were considered but had no effect.

To determine the quantity of fuel required for a year's operation of a nuclear power plant, the staff defined the model reactor as a 1000-We 05/26/88 38

[7590-01]

light-water-cooled reactor operating at an 80% capacity factor with a 12-month fue

&eloading cycle and an average fuel burnup of 33,000 MWD /

MTV.

The sum of the initial fuel loading plus all of the reloads for the lifetime of the reactor can be divided by the nominal 30 year life-time to obtain an average annual fuel requirement.

This was done for both BWR and PWR reactors, and the higher annual requirement, 35 HT of uranium made into fuel for a BWR, was chosen as the basis for the refer-ence reactor year.

Since the original estimates were made for Table S-3, a number of fuel management improvements have been adopted by nuclear power plants to ach; eve higher performance and to reduce fuel and separ-ative work (enrichment) requirements.

These improvements reduce the i

i annual fuel requirement by 10 to 15%.

Further, the average plant capa-city factor achieved by reactors operating in the United States has been below 80% in every reporting period to date and this means that the con-sumption of fuel has been below estimated amounts.

Some more recent studies have assumed average capacity factors of 70-75%, indicating a reduction of 6 to 12% in annual fuei consumption.

The original assump-tion that uranium fuel would be recycled is no longer appropriate, since there is no reprocessing in the United States.

Today's "no recycle" fuel cycle could be expected to require 15 to 20% more uranium from mining and milling to compensate for no recovery and recycle of uranium from spent fuel.

However, this increase in requirements is assumed to be offset by the decreases due to improved fuel management and the lower average operating capacity factor, and the average fuel requirement for 1 RRY is still estimated to be 182 MT of U 0, as it was in WASH-1248.

However, there has been another change of 33 even greater significance in the elimination of U.S. restrictions on importation of foreign uranium.

The economic conditions of the uranium i

05/26/88 39

[7590-01]

market now and in the foreseeable future favor full utilization of foreign uranium at the expense of the domestic uranium industry.

These market conditions have forced the closing of most U.S. uranium mines and mills, substantially reducing the environmental impacts from these activi-ties.

The Table S-3 estimates have not been reduced accordingly, however, in order to assure that these impacts, which have been experienced in the l

past and may be fully experienced again in the future, are considered.

This suggests that the environmental impacts of mining and milling could drop to levels far below those given in Table S-3.

In a somewhat similar situation, the Table S-3 estimates for enrich-ment are based on the gaseous diffusion process which has been used in the U.S. since the earliest days of the nuclear power program.

Here, there can be significant changes in uranium feed requirements as a result of changes in the quantity of U-235 left in the process tails.

The range of tails assay is generally from 0.16 to 0.30 weight percent U-235, and the value assumed in making Table S-3 estimates is 0.25%.

If the value of 0.16% had been chosen, 16% less uranium feed would be required and environmental impacts would be correspondingly lower.

At 0.30% tails, uranium requirements would increase by 11% anti environmental 1

impacts would be higher.

Far greater potential changes would come from the use of enrichment services from overseas or from the use of centri-fuge technology for enrichment in the U.S.

The largest impacts of the gaseous diffusion process are attributable to the large requirement for electric energy to run the plant especially to the assumption that the electricity will come from coal-fired power plants, and to the large

{

amount of cooling water used in the gaseous diffusion process equipment.

The centrifuge process uses 90% less electrical energy and therefore 05/26/88 40 R

[7590-01]

would have far lower impacts from the coal-fired power plant and the cooling water.

Clearly, when overseas enrichment services are utilized, impacts from U.S. enrichment plants would drop nearly to zero.

These potential reductions are not reflected in Table S-3 estimates.

Since there is no centrifuge enrichment ple.t in the U.S., this potential l

reduction is not reflected, even though such plants are operating in Europe.

The assumption of continued use of U.S. diffusion enrichment services assures that environmental impacts are not underestimated.

It er.ay be noted that the recycling of uranium in spent fuel would have only minor effects on enrichment because the recycled uranium has about the same U-235 assay as fresh natural uranium and would thus require about the same amount of enrichment.

There is an increase in the concentration of the U-236 isotope in recycled uranium, and this acts as a "poison" in the nuclear fuel, requiring more U-235 to overcome it.

Each kilogram of U-236 that is present in the recycled fuel requires an additional 0.3 kilogram of U-235 to compensate for it.

In total, the few kilograms of U-236 in the fuel cause increases of about 2 to 4% in the enrichment impacts. The quantity of uranium feed for enrichment would increase by a similar amount.

There are only two U.S. plants for converting the uranium oxide product from the mills to UFs feed for the enrichment plant.

The UFs conversion plants use two different processes:

one is a "dry" process using gaseous reagents; the other is a "wet" process which starts with dissolving the yellowcake in nitric acid and purifyiig it by solvent extrac-tion.

In the "dry" process, final purification is accomplished by frac-tional distillation of the UFs.

In the "dry" process, impurities are eliminated as volatile compounds or as solid wastes; in the "wet" process, 05/26/88 41 l

[7590-01]

many impurities are eliminated in the aqueous phase from solvent extraction.

In both cases environmental releases are so small that changing from 100%

use of one process to 100% use of the other would make no significant difference in the totals given in Table S-3 or Table S-4.

The assumption that half is processed by each method does not contribute significantly to the error band of the totals.

In the fuel fabrication plants, it has been assumed that the UFs from enrichment will be converted to UO2 by the ammonium diuranate "wet" process.

An alternate "dry" process for direct conversion of UFs to UO2 powder is being introduced as obsolete facilities are replaced or as new capacity is added.

This change reduces environmental impacts, but the impacts from fuel fabrication are so small that the changes are not significant.

Factors related to reactor operation can have a significant effect on the fuel cycle.

The original Tables S-3 and S-4 were based on a 12-month fuel reloading cycle.

Current practice favors an 18-month cycle, although in certain circumstances the original 12-month cycle or a longer 24-month cycle might be favored.

Parametric studies show that each 6-month extension of the reload interval requires an increase of about 5% in the uranium feed stream.

The higher burnup of fuel achieved in the longer reload cycles reduces the average annual output of spent fuel by as much as 45%.

Enrichment impacts are nearly constant in relation to the level of burnup but increase by about 10% with each 6-months extension of the reload cycle, l

The reduction in the annual output of spent fuel at high burnup would correspondingly reduce the environmental impacts associated with transpor-tation of spent fuel, with repiocessing and with waste disposal. There 05/26/88 42

[7590-01) would also be a decrease in occupational exposure to radiation because of the reduction in processing and handling requirements.

Population radia-tion doses would be lower because of the reduced number of shipments per year.

There are other significant changes which would apply to reprocess-ing if this fuel cycle step were to be undertaken in the U.S. in the future.

In Table S-3A in Section II, estimates for reprocessing impacts were based on the Barnwell and Exxon reprocessing plant designs of the 1970's.

The radioisotope release fractions used in the 1976 report HUREG-0116 are now considered to be conservative by at least two orders of magnitude in comparison to design values for today's reprocessing j

plants.

Also, the original Table S-3 assumption that 100% of the volatile radiostopes and compounds would be released is no longer valid.

EPA regulations in 40 CFR 190 require that after 1983 releases of krypton-85 and iodine-129 must be limited to 50,000 curies / gigawatt year and 5 millicuries / gigawatt year, respectively.

Since the model reactor that is the basis for Table S-3 and Table S-4 values produces 0.8 gigawatt years of electricity, the EPA limits translate to 40,000 curies /RRY and 4 millicuries /RRY, respectively.

Since plants will not be permitted to operate in violation of the EPA requirements, the Table S-3 values have been revised to reflect compliance with the new EPA requh ?ments.

A further requirement is that releases of alpha-emitting transuranic elements with half lives longer than one year must be limited to 0.5 millicuries / gigawatt year, or 0.4 millicuries per RRY.

This limit for transuranic elements required no change in the Table S-3 estimate, which was already well below the new standard.

Another conservatism in the NUREG-0116 estimates for Table S-3 is the assumption of a cooling time of 160 days between the discharge of 05/26/88 43

[7590-01]

spent fuel from the reactor and the reprocessing of the fuel.

This 1

160-day cooling period was based on the optimum for recycling plutonium as well as uranium.

With the recycling of uranium only, or with the present "no recycle" mode of operation, there is no incentive to keep the cooling time short, and, indeed, virtually all spent fuel in storage today has been cooling for years.

In comparison to 160-day-old spent fuel, fuel that has been cooled one year or more would have its radio-activity reduced by at least 50% and its radioactive decay heat emission similarly reduced.

The effect of cooling for five years or more, the age range of most spent fuel today, is to reduce the radioactivity and the

. decay heat by more than 90% and therefore the radioisotope release may be as low as 10% of the amount shown in Table S-3, in which case dose commitments and health effects calculated for Table S-3 releases would be overestimated by a factor of 10.

One effect of going to higher burnup of the fuel is to increase the formation of transuranic elements, with the result that spontaneous neutron emission from transuranic elements becomes an important shielding consideration as well as gamma radiation.

This has potential effects on the transportation of spent fuel.

At the time of discharge from the reactor, high burnup fuel may create up to 25% more radioactivity and decay heat at 60,000 MWD /MT, but this increase disappears as the cooling time is lengthened.

The emission of neutrons also decreases with longer cooling.

Gamma radiation is shielded with lead or.otner dense materials, while neutrons are best shielded by water and neutron-absorbing mate-rials, such as boron or cadmium.

It has been shown that present spent fuel transportation casks can be made safe for high burnup fuel by the addition of boron to the cooling water in the casks.

Longer cooling 05/26/88 44

[7590-01) times would increase the margin of safety.

With the large inventory of spent fuel that has accumulated, the age of any spent fuel that is repro-cessed or transported to a repository is likely to be many years.

At the conclusion of the hearings on reprocessing and waste management, the Hear-ing Board concluded that five years would be a reasonable value to use in making estimates.

The scenario that is visualized today for emplacement of spent fuel and high-level waste in a geologic repository calls for this final disposal to occur after the spent fuel or waste is ten years old.

The 1982 EPA regulations for high-level and transuranic wastes

, (40 CFR Part 191) established standards to limit the releases of radio-active material from a repository.

The basic requirements are that there should be no leakage to the environment in the first 300 years and that j

the annual releases thereafter should not exceed one part in 100,000 of the total inventory of that radionuclide calculated to be present 1,000 years following permanent closure of the repository.

Studies have shown that with proper geologic selection and application of known engineering techniques, these goals are reasonable and attainable.

The previous Table S-3 estimates have been revised to reflect compliance with this require-ment.

However, the assumption is made that releases from the repository would be at the maximum rate permitted by the EPA regulations in 40 CFR Parts 190 and 191.

This assumption is conservative by a considerable margin because no credit is taken for known technology that keeps gaseous releases well below EPA limits and because no credit is taken for radio-active decay of long-lived radio! otopes prior to release.

In summary, it is clear that the Table S-3 estimates of environ-mental impacts are higher than the actual impacts will be under any 05/26/88 45

[7590-01]

foreseeable combination of reactor and fuel cycle operating conditions, including higher burnup of the fuel.

The greatest changes would come i

from the use of foreign uranium and foreign enrichment services, which i

could easily reduce U.S. environmental impacts from the front end of the fuel cycle by factors of 10 to 100.

Beyond that the greatest uncertain-i ties are in the estimates of environmental releases from high-level waste handling and storage.

Lacking experience in actual operation of the facilities that will be built in tha future, the staff has estimated that releases will be at the maximum levels permitted by EPA and NRC regula-tions, whereas some engineering tests indicate that it may be possible to keep releases to much lower levels.

The Table S-3 estimates could easily be high by a factor of 10; they are not likely to be low.

l 05/26/88 46 J

[7590-01]

BIBLIOGRAPHY 1.

"Environmental Survey of the Uranium Fuel Cycle," WASH-1248, U.S.

1 Atomic Energy Commission, April 1974.

l 2.

"Final Generic Environmental Statement on the Use of Recycled Pluto-nium in Mixed 0xide Fuel in Light Water Cooled Reactors," NUREG-0002, U.S. Nuclear Regulatory Commission, August 1976.

3.

"Environmental Survey of the Reprocessing and Waste Mangement Por-tions of the LWR Fuel Cycle," NUREG-0116 (Supp. 1 to WASH-1248),

U.S. Nuclear Regulatory Commission, October 1976.

4.

"Public Comments and Task Force Responses Regarding the Environ-mental Survey of the Reprocessing and Waste Management Portions of the LWR Fuel Cycle (NUREG-0016)," NUREG-0216 (Supp. 2 to WASH-1248),

U.S. Nuclear Regulatory Commission, March 1977.

5.

"Final Generic Environmental Impact Statement on Uranium Milling,"

NUREG-0706, U.S. Nuclear Regulatory Commission, September 1980.

6.

"Radon Releases from Uranium Mining and Milling and Their Calcu-lated Health Effects," NUREG-0757, U.S. Nuclear Regulatory Commis-sion, February 1981.

05/26/88 47 t

[7590-01]

1 7.

"Environmental Effects on the Uranium Fuel Cycle - A Review of Data for Technetium," NUREG/CR-3738 (0RNL/TM-9150), Till, J.E.; R.W. Shor; F.O. Hoffman, Oak Ridge National Laboratory, February 1985.

8.

"The Environmental Consequences of Higher Fuel Burn-up," AIF/NESP-032, John J. Mauro, Raymond Eng, Stephen Marschke, and Wallace Chang, Envirosphere Company, June 1985.

9.

Documents contained in the records of proceedings related to Table S-3:

RM 50-3 Initial Table S-3 Rulemaking and Special Hearings on Reprocessing and Waste Management RM 50-5 GESMO Hearings PRM 50-1 NECNP Petition for Changes to Table S-3 Dockets 50-277, 50-278, 50-320, 50-354 and 50-355, Consolidated Hearing on Radon Before the Appeal Board 1

10.

"Potential Health and Environmental Impacts Attributable to the Nuclear and Coal Fuel Cycles," R.L. Gotchy, NUREG-0332, U.S.

Nuclear Regulatory Commission, June 1987.

NOTE:

All referenced documents are available for public inspection and copying for a fee in the Commission's Public Document Room at 1717 H Street, NW., Washington, DC 20555.

05/26/88 48

[7590-01]

SECTION II.

ENVIRONMENTAL EFFECTS OF THE LWR FUEL CYCLE A.

Environmental and Radiation Data Table S-3 summarizes the environmental impacts attributable to all steps of the uranium fuel cycle supporting a model 1,000-MWe LWR, Data from the front end of the uranium fuel cycle, originally based on WASH-1248, have been updated to incorporate newer information on mining and milling, especially radon-222 emissions, ano new regulations on mill tailings.

Data from the back end are based on NUREGs-0116 and -0216 and the rulemaking proceeding (Docket No. RM-5C-3), with some updating to incorporate the effect of new waste management plans and regulations.

Data based on the referenced documents, records of the rulemaking proceedings, and other authoritative sources have been used to develop the individual values shown in the Table S-3A, which follows.

The values under the column heading marked "Total" in Table S-3A are the values used in Table S-3.

In all cases the higher of the values from either the once-through (column F) or the uranium-only (column G and H) fuel cycles have been selected to ensure that the values in Table S-3 are not underestimated.

The terms "once-through" and "uranium-only" will be explained later.

The column labeled "Coal Fired Plant" in Table S-3A is for comparison purpose.

It contains the corresponding impact values, where they are available, for the coal fuel cycle producing an annual fuel requirement of coal equivalent to a RRY.

The values in this column are derived from NUREG-0332, "Potential Health and Environmental Impacts Attributable to the Nuclear and Coal Fuel Cycles,".Tabie 17, Pg. 3-16.

Land use and certain other values related to mining and to uranium recovery at the mill are being increased by a factor of 2.2 to reflect 05/26/88 49

[7590-01) two significant changes:

(1) the average ore grade now being mined and anticipated to continue into the next century is reduced to 0.1% from the 0.2% used earlier in WASH-1248, resulting in a doubling of'the quantity of ore mined and milled per RRY; and (2) instead of 100% recovery at the mill, only 90% recovery of the uranium from the lower grade ore is now assumed.

New environmental release values for technetium-99 (Tc-99) and radon-222 (Rn-222) are being added to Table S-3.

The Rn-222 estimates include the effects of the lower grade of ore now being mined and the 90% mill recovery efficiency.

The following is a discussion of the fuel cycle options and related environmental impact values:

1.

Back End of the Once-through Fuel Cycle At present, spent fuel discharged from LWRs in the United States is being stored.

President Reagan announced on April 28, 1982, that his administration supported the commercial reprocessing of spent fuel.

How-ever, there are no plans at present for commercial fuel reprocessing in the United States.

Thus, the only LWR fuel cycle now in use in the U.S.

is once-through.

The environmental impacts reltted to spent fuel storage under the once-through fuel cycle are summarized in column F of Table S-3A.

Column F includes the impacts for storage of spent fuel at the reactor, at an Inde-pendent Spent Fuel Storage Installation (ISFSI), at the Monitored Retriev-able Storage (MRS) Facility which was provided for in the Nuclear Waste Policy Act of 1982 (NWPA), and at the final geologic disposal repository.

Low-level, decontamination, and decommissioning wastes from all segments-of the fuel cycle are also included in column F [1].

There are no 05/26/88 50 4

~r

Table S-3A Summary of environmental considerations for the LWR fuel cycles by components normalized to model LWR reference year A

B C

D E

F G

H I

Spent Waste Fuel Mangent Enrich Strg &

Repro-Uranium Trans-Mining Milling UFs Prod.

ment fuel Fab.

Disp.

cessing Recycle portation Total Coal Natxral Resources Used Land (Acres)

Temporarily Committed 122 1.1 2.5 0.8

0. 2
7. 7 32 9.0 0.0 168 Undisturbed Area 84 0.4 2.3 0.6 0.1 7.5 28.5 8.6 0.0 125 Olsturbed Area 38 0.7 0.2 0.2 0.0 0.2 3.5 0.4 G. 0 43 248/264 Permanently Comitted 4

5.3

0. 3 0.0 0.0 7.7 0.1 8.4 0.0 18 15/25 Overburden Moved -

6 0.0 0.0 0.0 0.0 0.0 0.0 0.0 6

[tillions of metric tons (tonnes)]

Water (millions of gallons)

Discharged to air 0.0 143 3.3 84 0.0 11.4 6.6 0.7 0.0 242 Discharged to water bodies

0. 0 0.0 23 11006 5.2 0.1 54.8 0.0 0.0 11100 Discharged to ground 270 0.0 0.0 0.0 0.0 3.1 0.0 3.5 0.0 273 Total Water 270 143 11090 5.2 14.5 61.4 4.2 0.0 11,600 6880/8800 Fassil Fuel Electric Energy 0.6 6.0 1.7 310 1.7 1.9 4.0 2.3 0.0 325 (thousands of N-Hr)

Equivalent Coal 0.2 2.2 0.6 113 0.6 0.7 1.5 0.8 0.0 120 (thousands of tonnes)

Natural Gas (millions of scf) 0.0 61.5 20.0 0.0 3.6 12 28.6 14 0.0 140 O

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7590-01]

significant amounts of TRU wastes generated separately in the once-through fuel cycle, as they remain with the spent fuel.

It is presumed for the purposes of this narrative that spent fuel or high-level wastes, including the TRU, will be disposed of in a repository (1). Operation of a repository and the resultant environmental impacts are presumed to be similar for either spent fuel or high-level waste.

The permanent disposal of spent fuel and high-level waste in a geo-logic repository has not yet been demonstrated in the United States, and the plans advanced by the Department of Energy for such disposal have been controversial.

As early as 1979, in response to a decision by the

. United States Court of Appeals for the District of Columbia (State of Minnesota v. NRC, 602 F.2d 412 D.C. Cir. 1979), the Commission conducted a proceeding to reassess the degree of confidence that radioactive waste produced by nuclear facilities will be safely disposed of, to determine when any such disposal will be available, and to assess whether such wastes can be safely stored until they are disposed of (44 FR 61372, October 25, 1979).

The generic waste confidence decision was a separate rulemaking procedure.

It was also different in scope and purpose from the rulemakings dealing with Table S-3.

In the final waste confidence proceedings the Commission made the following findings:

(1) Safe dis-posal of high-level radioactive waste (HLW) and spent fuel in a mined geologic repository is technically feasible.

(2) One or more geologic repositories for commercial HLW and spent fuel will be available by the years 2007 and 2009, and sufficient repository capacity will be available within 30 years beyond the expiration of any reactor operating license to dispose of existing commercial HLW and spent fuel originating in the 05/23/88 54

7590-01]

o reactor and generated up to that time.

(3) HLW and spent fuel will be managed in a safe manner until sufficient repository capacity is avail-able.

(4) If necessary, spent fuel can be stored safely and without significant environmental impacts for at least 30 years beyond the expiration of that reactor's operating license at either an on-site or off-site independent spent fuel storage installation and that safe inde-pendent spent fuel storage will be made available, if needed.

In a separate Federal Register notice (44 FR 45362, 8/2/79), the Commission also concluded that the staff's model for assessing impacts of waste dis-posal is reasonable and adequate.

In 1982 the EPA published its proposed standards for high-level and i

transuranic wastes (40 CFR Part 191) [2] which incorporated the minimum requirements given in the NRC's high-level waste regulation, 10 CFR Part 60.

The most important requirements for use in assessing environ-mental impacts are that the waste package containment remain substant-ially complete for a period of not less than 300 years and that the release rate after the contairmient period not exceed one part in 100,000 per year of the total inventory of that radionuclide calculated to be present 1,000 years following permanent closure of the repository.

The estimates for Table S-3 were based on compliance with these requirements.

The radiological impacts related to gaseous releases from the spent fuel are accounted for by assuming that they will be controlled to levels which meet the EPA standards in 40 CFR 190.[1] Since these gaseous and volatile radionuclides (tritium, krypton, carbon, iodine) are important contributors to the radiation dose, this assumption establishes a reason-able upper limit for the dose commitments, because, even though complete 05/23/88 55

7590-01]

l 1

release of gaseous and volatile radionuclides is assumed, the impact is j

i evaluated on the basis of processing and confinement to assure that the l

l releases reaching the environment do not exceed the maximum permissible levels of radioactivity.

i 2.

Back End of the Uranium-only Recycle Fuel Cycle If at some future time LWR spent fuel is reprocessed, the short-term (100 years or less) impacts from reprocessing and related waste manage-ment activities would not be significantly different whether both uranium and plutonium are recycled or only the uranium is reused.

The possible use of plutonium in commercial power reactor fuel, either for LWR or breeder reactors, or both, is a separate issue that will~be resolved when proposals for this use are considered.

However, to cover the con-tingency that at some future date spent fuel from LWRs may be repro-cessed, it is assumed here that only the uranium recovered from chemical reprocessing will be recycled.

The radiation impacts of the uranium-only' fuel cycle are summarized in columns G (Reprocessing) and H (Waste Manage-ment) of Table S-3A.

It should be noted that column F, and columns G and H are not added together to arrive at totals, but are alternatives; and, the higher value from column F or from G and H has been used in arriving at the total.

Column F presents the impacts associated with the back-end of the once-through fuel cycle and columns G and H present the impacts associated with the back-end of the uranium-only recycle option.

The impacts from waste management activities directly related to reprocess-ing, such as storage of liquid wastes in tanks, waste solidification and l

packaging, and interim storage of solidified wastes at the reprocessing site are included in column G.

I 05/23/88 56 l

7590-01) 3.

Front End of the Uranium-only Recycle Option Land use and other values would decrease for the uranium-only recycle option, because less fresh uranium would have to be mined if uranium is recycled. However, no reduction is made in the table, because the higher value for the two options is used to ensure that the Table S-3 values are not underestimated.

Technetium-99 is created, at about 507 curies (Ci) per RRY, as a fission product in the spent fuel.

About 20% of the Tc-99 will follow the uranium in the uranium recovery process, and the remaining 80% will be stored for disposal in a repository with the HLW.

Of the 20% recycled

.with the uranium, all but about 4 ppm will be removed at the enrichment plant to meet quality control requirements. [3] Most of the Tc-99 removed at this step is currently being stored.

It is assumed here that all of the Tc-99 will eventually be disposed of at a repository.

Table S-3 shows three entries for Tc-99.

The releases from recycled uranium are shown under the "Effluents-Radiological" subheading "Gases." The estimated amount released each year from a repository in groundwater (0.005 Ci/ year /RRY) is shown under the subheading "Liquids:". The value shown under "Stored Solids" includes impurities removed from the enrich-ment feed and recovered for disposal with high-level wastes.

B.

Impacts of Uranium Fuel Cycle Options This section provides a brief explanation of how the Table S-3 values were derived and how they can be converted into cumulative radiation impacts for the lifetime of a reference reactor (assumed to be 30 years) and for the total nuclear power industry.

l l

05/23/88 57

7590-01) 1.

Natural Resources a.

Land Land use per RRY is based on the actual area of the site of each facility divided by the number of RRYs produced by the facility during its lifetime.

For the total fuel cycle, land use per RRY is about 168 J

acres, of which about 125 acres remain undisturbed and only about 18 acres are permanently committed.

About 72% of the land used by fuel cycle facilities is associated with uranium mining, and most remains j

undisturbed.

Temporarily committed land is used during the lifetime of a particular fuel cycle facility and then can be released for unre-stricted use after the facility is decommissioned.

Permanently committed land is that land which will be permanently committed for radioactive waste disposal or for other purposes and will not be released to unre-stricted use after a facility is decommissioned [4).

The mining of uranium ore accounts for nearly all of the overburden moved.

The land use values were calculated for Table S-3 on the basis of an ore assay of about 0.1% and 90% recovery of uranium at the mill.

As the ore assay decreases from the 0.2% originally used in Table S-3 to 0.1%, the land requirements for mining the uranium required for a RRY would double. [5] Recovery of only 90% of the uranium from the ore will result in further increases in the quantity of ore that must be mined and thus will increase the estimates of the related impact values.

The total land use for the fuel cycle operations to support a model reactor for its entire lifetime can be calculated by multiplying the "Temporarily Committed" values or the "Permanently Committed" value by 30, which is the assumed reactor operating lifetime.

To get the total 05/23/88 58

7590-01]

l land use value for an entire nuclear power industry multiply the tempo-rary lifetime land use factor by the number of operating nuclear power plants (103 at the end of 1987) and the permanent lifetime land use factor by the number of nuclear power plants that have been licensed (108), including those not in operation.

b.

Water The principal use of water (95%) in the fuel cycle supporting the model LWR is for cooling at the power stations that supply electrical energy for uranium enrichment [6).

A total of 11,600 million gallons of water is used per RRY.

Almost 250 million gallons of water are dis-charged to air (evaporated) per RRY, with about 140 million gallons of that total evaporated from mill tailings ponds, and 84 million gallons evaporated from cooling water towers at the enrichment plant.

Drainage water pumped out of uranium mines (270 million gallons /RRY) and water used for waste management operations (3.5 million gallons /RRY) are discharged to the ground, where some will evaporate and the balance will go into surface streams or aquifers.

To determine the cumulative water use impacts for the entire nuclear industry, multiply by 30 (reactor operating lifetime) and then multiply by the number of operating nuclear power plants (103),

c.

Fossil Fuel The electrical energy used in the fuel cycle is about 325 gigawatt-brs per RRY, about 95% of which is used for uranium enrichment, and is produced mostly by fossil fuel fired power plants.

Most of the process heat used in the fuel cycle is supplied by the combustion of natural gas, 05/23/88 59

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estimated at 140 million scf per RRY.

About 45% of the natural gas is used for drying yellowcake, 15% in UFs production, reprocessing, and 10%

in waste management operations.

To determine the impacts from use of fossil fuel for a reactor life-time multiply the summation of "Equivalent Coal" and "Natural Gas" values in Table S-3 by 30.

To get the value for the entire nuclear industry multiply the lifetime value by the number of operating reactors (103).

2.

Chemical Effluents a.

Gases The nonradioactive gaseous chemical effluents, labeled "Combustion Gases" under "Chemical Effluents" in Table S-3, result mostly from the combustion of the fossil fuel needed to provide electrical energy or proc-ess heat for the fuel cycle facilities [6).

The 50 and NO effluents x

x are attributable almost entirely to coal-fired power plants that provide electricity for isotope enrichment.

Small amounts of fluorides from UFe conversion, uranium enrichment operations, and fuel fabrication are released as gases.

To determine the cumulative gaseous chemical impacts, nultiply the appropriate values by 30 to obtain values for the reactor lifetime.

To get the value for the entire nuclear power industry multiply this value by number of operating nuclear power plants (103).

b.

Solids and Liquids Except for solids related to coal mined and burned to produce elec-tricity for the fuel cycle, nonredioactive solids released in the uranium 05/23/88 60

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fuel cycle are negligible.

A number of chemicals, such as compounds of calcium, chromium, zinc, chlorine, are released in water used for cooling.

The major quantities of chromium and zinc are in the water from the enrichment plant's cooling water tower blow-down.

Treatment of the water ensures that EPA and state water quali+y I,ts;ndards are met.

The concentra-tion of chemicals are further reduced by dilution in rivers, and other receiving bodies of water.

The liquid effluents from fuel fabrication facilities contain nitrogen compounds from.he use of ammonium hydroxide in the production of UO2 powder, and from the use of nitric acid in scrap recovery operations.

The fluorine introduced into the fuel cycle during UFe production becomes a waste product during the production of UO.

The 2

fluoride is removed from the effluent streams by precipitation with lime and is packaged for disposal as low-level waste (about 11 cubic yards per RRY) [7].

The coal fuel cycle generates acid wastes from coal washing opera-tions and from combustion gas scrubbers, as well as acid mine water and acid rain, which have been thought to be responsit,le for killing aquatic life in certain streams and lakes of the eastern U.S.

Data are not avail-able to estimate the quantit M which ultimately get into streams and lakes, but the effects are observable and are being studied.

Fly esh and combustion gas scrubber solid waste from 502 removal constitute the i

largest solid wastes in a coal-fired power plant.

Depending on the ash and sulfur content of the coal, the combined ash and scrubber sludge from the 1000-MWe coal fired plant may range from one million to 1.8 million tonnes per year, which is several times the quantity of mill tailings slurry wastes.

The nuclear power pl.. has no comparable solid chemical 05/23/88 61

7590-01) wastes.

No other values for nonradioactive solids from the nuclear fuel cycle are shown in Table S-3, because their impacts are regligible.

c.

Thermal Approximately 4145 billio.: BTU of heat are released per RRY from the uranium fuel cycle.

Most of this heat, about 80%, is rejected to the atmosphere at the power plants that supply electrical energy to the enrichment plant and at the enrichment plant itself [8).

About 18% of the heat released comes from the back end of the fuel cycle as a result of the decay of radionuclides.

The release of process heat from fuel cycle facilities accounts for the remaining 2% of the thermal effluent.

To determine the heat rejected by the fuel cycles over the model LWR lifetime, multiply the thermal effluent value by 30.

To get the value for the entire nuclear power industry, multiply this factor by the n. *er of operating nuclear power plants (103).

3.

Radioactive Effluents Table S-3 shows the estimated number of curies of radioactivity l

released in effluents from fuel cycle facilities under the general head-ing "Radiological Effluents (curies)."

In general, naturally occurring radionuclides (uranium, thorium, radium, radon) are released from the front-end, and the other radionuclides are released from the back end of j

the fuel cycle.

The exception is that a small amount of fission product Tc-99, which is generated in the back end of the fuel cycle, may be recycled and released from the front end operations.

Most of it would be i

removed from the UFs teed to the enrichment plant and disposed of as high-lev:1 waste.

It is assumed that all of the Tc-99 is ultimately 4

05/23/88 62

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released from the waste repository at the slow rate of 0.005 Ci/yr/RRY by leaching into grount, water, a.

Gases.and Liquids In the front end of the fuel cycle small amounts of uranium, thorium, and radium are released to the environment in the process effluents and in the ventilation air discharged to the atmosphere from milling, UFs conversion, enrichment, and fuel fabrication facilities.

Small amounts of uranium are also released in the liquid effluents from these facil-ities, but most of these radionuclides become part of the solid waste collected in the tailings pile from mining and milling operations or in settling ponds associated with the other front-end operations.

The most serious health hazard, by orders of magnitude, is represented in the release of gaseous Rn-222 from the tailings piles at the milling step.

Radon is created from the radioactive disint a ration of radium and is a chemically inert, radioactive gas.

It has a radiological half-life of about 3.8 days.

Regulations require that mill tailings be stored and disposed of in a manner that reduces Rn-222 emissions and meets EPA standards.

It is estimated that a total of about 4866 Ci of Rn-222 are l

re eased per RRY in mining and milling operations.

It is estimated that 29 C1/ year per RRY will be released from mining and milling sites after they ne de ommissioned, and that this may increase to 33 Ci/ year after degradation of reclamation measures many years in the future.

These estimates are based on the assumption that radon releases will be reduced to the levels required to comply with the new EPA standards for radon releases from mining [9] and mill'w [10,11].

05/23/88 63

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To find the total number of curies of Rn-222 released for the entire nuclear power industry multiply the summation of the values listed in Table S-3 for Rn-222 by 30 and then multiply this factor by the number of nuclear power plants that have been licensed (108).

The HRC staff has identified those radionuclides that have the greatest potential for migrating from a repository, and has determined which of these would be significant contributors to the radiation dose.

In general, the gaseous and volatile radionuclides that could escape from failed fuel, that have long half-lives, or that have low retardation in soils, such as krypton (Kr-85), Tc-93, and I-129 trould be the principal contributors to such radiation dose.

As previously mentuned, it is assumed that tritium (H-3), C-14, Kr-85, and I-129 have been released prior to sealing of the repository.

Previously the radiation impact for Tc-99 was considered to have been a vered by using a conservatively high value for I-129.

In the revised Table S-3, separate entries for Tc-99 are provided.

About 50% of the Kr-85,10% of the C-14 (as carbon dioxide), and 1% of the H-3 and I-129 contained in the ' pent fuel exist within the gas space in the fuel rod.

These are very likely to be released, at least over the lifetime of a repository.

The amount of H-3 1

and C-14 shown in Table 5-3A represents the total number of curies esti-1 mated to be in the RRY fuel replacement, aged for 5 years as spent fuel.

EPA regulations (at 40 CFR 190, SS 19tl.10. 190.11, and 190.12) require that releases of Kr-85 and I-129 generated after January 1,1983 must be less than 50,000 curies of Kr-85 and 5 millicuries of I-129, respec-tively, per gigawatt of electricity (1 RRY = 0.8 GWe).

Therefore, it is assumed that provisions will be made to control the releases cf Kr-85 and I-129 from the spent fuel or from chemical reprocessing.

The values 05/23/88 64 l

I

7590=01) shown in Table S-3A reflect compliance with EPA requirements.

Since there is no reprocessing in the U.S. and no permanent spent fuel reposi-l tory, the actual performance in meeting EPA requirements has not been demonstrated.

Therefore, the staff has assumed that releases will be the maximum allowed under the regulations.

To calculate the reactor lifetime impacts from gaseous and volatile radioactive effluents, sum the values, or use the individual values, 1

listed under "Gases (including entrainment):" and multiply these values I

by 30.

Multiply this factor by the number of operating nuclear power plants (103) to obtain the total value for the entire industry.

1 i

b.

Solids 5'aurries from uranium mills account for a large part of the liquid and solids effluents from the fuel cycle facilities.

These effluents are estimated to total 528,000 tonnes per RRY for liquids and 202,000 tonnes per RRY for solids.

These slurries are collected in an impoundment where they slowly dry by natural processes, principally through evaporation, leaving the tailings solids for eventual disposal.

The radiation doses for the Rn-222 released from these tailings were discussed under Section i

III.3.a.

There are two types of UFs conversion processes, the "dry" process and the "wet" process.

The radiation impacts estimates for Table S-3 are I

based on equal production of UFs by each process.

The "dry" process yields solid wastes, which are mainly impurities from the feed material.

The "wet" process produces two aqueous waste streams.

One is made up of f

dilute scrubber solutions that are treated with lime to precipitate calcium fluoride.

The solids are collected in a sealed settling pond and 05/23/88 65

7590-01]

the water effluent is either evaporated or released to a water body.

The other is a raffinate stream which is also neutralized with lime and held in a sealed settling pond.

The solids recovered from the settling ponds are presumed to be packaged and ultimately buried as low-level waste.

i Moreover, some of the radioactive effluents from waste management are so small in relation to other segments of the fuel cycle that they do not l

appear separately, but are included in the totals shown in Table S-3A [12].

Most of the naturally radioactive elements formed in the decay chain descending from uranium-238, about 600 curies per RRY, will be added to the tailings piles per RRY [13].

About 100 curies of radioactivity, including fission products and activation products, are added from the back end of the fuel cycle per RRY.

About 10,700 curies of mixed radio-nuclides from reactor operations and decommissioning are buried per RRY at low-level waste land burial sites [14].

4.

Transportation The dose commitment to workers and the public related to the tran-sport of nuclear materials between fuel cycle plants supplying the model 1,000-MWe LWR is estimated to be about 2.5 person-rem per RRY [15].

The estimated consequences of fuel cycle transportation accidents or sabotage do not appreciably increase the total risk attributable to normal fuel cycle operations.

The nuclear fuel cycle accident risk, including transportation, is about 1% of the accident risk of generating nuclear electric power in general, thus, the reactor risk reasonably approximates the full accident risk for nuclear power.

The impacts of transportation of spent fuel and HLW from the reactor operation are summarized in Table S-4 05/23/88 66

7590-01]

To determine the transportation dose commitment over the model LWR lifetime, multiply the dose commitment per RRY by 30.

To determine the value for an entire nuclear power industry multiply this factor by the number of operating nuclear power plants (103).

a.

Transportation of Spent Fuel and Radioactive Wastes In 10 CFR 51.52, Table S-4, summarizes the environmental effects sf transporting fresh fuel to the nuclear power plant and spent fuel and radioactive wastes to other sites for storage or disposal.

This table is based on transporting unirradiated fuel to the nuclear power plant by truck and transporting spent fuel and radioactive waste to other sites by truck, rail or barge in shielded containers.

The effects are esti-mated for normal conditions of transport and for accidents that may occur.

Table S-4, given below, summarizes the environmental impacts given in the reports, "Environmental Survey of Transportation of Radioactive Mate-rials to and from Nuclear Powers Plants," WASH-1238, December 1972, and Supplement 1, NUREG-75/038, April 1975.

Additional information on the i

impacts of accidents was given in NUREG-0170, "Transportation of Radioac-tive Material by Air and Other Modes," December 1977.

This latter report was updated and extended in February 1987 in a new report, NUREG/CR-4829, "Shipping Container Response to Severe Highway and Railway Accidents."

[16-19).

All of the studies and investigations covered by the reports cited above show environmental impacts that are very small, even under the worst accident conditions.

The large shipping casks used for transporting spent fuel are designed to contain the largest quantities of rautoactive mate-rial and to provide heavy shielding for the radiation and high mechanical 4

l 05/23/88 67 i

7590-01)

Summary Table S-4--Environmental Impact of Transportation of Fuel and Waste To and From One Light-Water-Cooled Nuclear Power Reactor!

Normal Conditions of Transport Environmental-Impact Heat (per irradiated f uel cask in transit)..........

250,000 8tu/hr.

Weight (governed by Federal or State restrictions)..

73,000 lbs. per truck; 100 tons per cask per rail car Traffic density:

Truck.............................................

Less than 1 per day Rail..............................................

Less than 3 per month Estimated Range of doses Cumulative dose Exposed population number of to exposed indi-to exposed persons viduals2 (per population (per exposed reactor year) reactor year)3 Transportation workers..

200 0.01 to 300 millirem 4 man-rem General public:

Onlookers............

1,100 0.003 to 1.3 millirem 3 man-rem Along Route..........

600,000 0.0001 to 0.6 millirem i

Accidents in Transport Environmental risk Radiological effects...............

Small*

Common (nonradiological causes)....

1 fatal injury in 100 reactor years; 1 nonfatal injury in 10 reactor years; $475 property damage per reactor year 2 Data supporting this table are given in the Commission's "Environmental Survey of Transportation of Radioactive Materials to and from Nuclear Power Plants," WASH-1238, December 1972, and Supp. 1 NUREG-75/038 April 1975.

Both documents are available for ir.spection and copying at the Commission's Public Document Room 1717 H St.. N.W., Washington, D.C. and may be obtained from the National Technical Information Service, Springfield, Va. 22161.

WASH-1238 is available from NTIS at a cost of

$5.45 (microfiche, $2.25) and NUREG-75/038 is available at a cost of

$3.25 (microfiche, $7. 25).

2The Federal Radiation Council has recommended that the radiation doses from all sources of radiation other than natural background and medical exposures should be limited to 5,000 millirem per year for individuals as a result of occupational exposure and should be limited to 500 millirem per year to individuals in the general population.

The dose to indivi-duals due to average natural background radiation is about 130 millirem per year.

3 Man-rem is an expression for the summation of whole body doses to indivi-duals in a group.

Thus, if each member of a population group of 1,000 peop'a were to receive a dose of 0.001 rem (1 millirem), or if 2 people were co receive a dose of 0.5 rem (500 millirem) each, the total man-rem dose in each case would be 1 man-rem.

4Althoegh the environmental risk of radiological eff6 cts stemming from transportation accidents is currently incapable of being numerically quantified, the risk remains small regardless of whether it is being applied to a single reactor or a multireactor site.

05/23/88 68

7590-01) strength for resistance to damage and leakage in accidents.

The latest and most detailed scientific analysis of the worst transportation acci-dents that have occurred shows that if a spent fuel cask had been at the worst spot in the accident, the external radiation levels near the wrecked cask might exceed the normally permissible levels by three times and the leakage of radioactive gases and breathable particulates might exceed normally permissible levels by a factor of three.

These worst case scenarios result in low radiation exposures of workers and of a small segment of the population, with calculated health effects less than 5% of the total shown in Table S-4.

Even if several such accidents should occur in one year, a most unlikely case, the population health effects would still be less than the totals shown in Table S-4.

The effects of going to higher burnup of reactor fuel have been analyzed by Pacific Northwest Laboratory and reported in the document, "The Use of Extended Burnup Fuel in Light Water Power Reactors," NUREG/

CR-5009, February 1988.

The major effects are a reduction in the quant-ity cf spent fuel per RRY and an increase in the quantity of long-lived fission products and transuranic elements per tonne of spent fuel.

Short-lived radionuclides which are in equilibrium at 33,000 MWD /MT do not increase with higher burnup.

1 In order to support higher burncp, fresh fuel may require enrich-ments of the uranium-235 content to 5.5%.

NRC regulations require criticality analyses to demonstrate that fresh fuel would not achieve criticality even if the shipping container were to be damaged and immersed in water.

Analyses of the effects of greater heat emission and higher levels of radioactivity per tonne of fuel show that for higher burnup fuel, longer cooling times would be required to keep the heat 05/23/88 69

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4 release rate below the current cask design capacity of 250,000 BTU / hour.

Generally, burnup to levels of 50 to 60,000 MWD /MT requires that the 'uel be given about 3 to 4 months more cooling prior to shipment to reduce the heat emission rate to levels below 250,000 BTU /hr.

Analyses of the radiological impacts of spent fuel at higher levels of burnup show that the increase in radioactivity of the fuel would not significantly change the radiation levels outside the shielding.

Therefore, the reduction in the number of shipments per year reduces the radiation exposure of workers and the general public by a proportional amount.

Table 3 shows the typical reductions in radiation exposure estimated for all modes of transportation as burnup levels increase.

On the basis of these analyses, it is clear that the present values in Table S-4 conservatively cover the environmental impacts of transporta-tion of radioactive materials, even when the effects of higher burnup of the fuel are considered.

5.

Occupational Exposure The occupational exposure value given in Table 5-3 (180 person-rem) includes the exposure from uranium mining and milling operations l

(140 person-rem) plus an upper limit for the exposure value (22.6 person-rem) related to reprocessing and waste management activities associated with the back end of the fuel cycle when the model LWR is operated in uranium-only recycle mode [16].

The occupational exposures estimated to occur in the other steps of the fuel cycle are negligible.

For compar-ison, the occupational exposures related to the back end of the once-through uranium fuel cycle without reprocessing, are estimated to be 5 person-rem per RRY.

The occupational exposures related to uranium 05/23/88 70

l TABLE 3 ENVIRONMENTAL IMPACT OF RAIL TRANSPORT OF IRRADIATED FUEL ASSEMBLIES WASH-1238 Burnup (MWD /MT) 33,000 40,000 45,000 50,000 60,000 Number of railcar loads / year 10 9

8 7

6 Milss travelled / trip 1,000 1,000 1,000 1,000 1,000 1.

Heat Release (BTU /hr) 250,000 250,000 250,000 250,000 250,000 2.

Weight and Traffic Density No Effect No Effect No Effect No Effect No Effect 3.

Radiation Exposure (1) Brake Man 10 10 10 10 10 Individual Dose / Shipment (ares) 0.5 0.5 3.5 0.5 0.5 Cumulative Annual Dose (man-res) 0.05 0.05 0.04 0.035 0.03 (2) Intermodal Transport by Truck Freight Handlers 2

2 2

2 2

Individual Dose / Shipment 100 100 100 100 100 Cumulative Annual Dose (man ren) 2 1.8

1. 6 1.4 1.3 (3) General Public - Onlookers 10 10 10 10 10 Individual Dose (aren) 1.3 1.3 1.3
1. 3 1.3 Cumulative Annual Dose (man-rem) 0.1 0.1 0.1 0.1 0.1 (4) General Public - Along route 300,000 300,000 300,000 300,000 300,000 Cumulative Population Dose
  • per mile (m2n-rem) 1.8E-5 1.8E-5 1.8E-5 1.8E-5 1.8E-5 Cumulative Annual Dose (man ren) 0.18 0.16 0.14 0.12 0.11
  • From "The Environmental Consequences of Higher Fuel Burnup," AIF/NESP-032, June 1985.

[7590-01]

mining and milling are mainly from exposure to Rn-222.

The regulations concerning Rn-222 concentrations in the air in work areas are strictly enforced to reduce occupational exposures, and the average occupational exposure per person is estimated on the basis of compliance with the regulations.

The exposure for uranium inilling covers employees only, not the general public, and is a small fraction of the permissible occupa-tional radiation dose levels given in the Commission's regulations cover-ing "Standards for Protection Against Radiation" in Part 20.

The occupa-tional exposure attributable to the entire uranium fuel cycle can be estimated by multiplying the total by 30 for the operating lifetime of the model reactor and then by the total number of operating nuclear power plants (103),

i 05/26/88 72 s

[7590-01)

SECTION II - REFERENCES 1.

NUREG-0116, Sections 2.6 and 4.6.

2.

"High-Level and Transuranic Radioactive Wastes:

Background Informa-tion Document for Final Rule," EPA 520/1 85-023, U.S. Environmental Protection Agency, August 1985.

3.

"Environmental Effects of the Uranium Fuel Cycle - A Review of Data for Technetium," Jill, J.E., R.W. Shor, and F.O. Hoffman, NUREG/

CR-3738, Oak Ridge National Laboratory, February 1985.

4.

NUREG-0116, p. 4-80 5.

"Radon Releases from Uranium Mining and Milling and their Calculated Health Effects," NUREG-0757, U.S. Nuclear Regulatory Commission, February 1981.

6.

"Update of Table S-3 Nonradiological Environmental Parameters for a Reference Light-Water Reactors," NUREG/CR-4964, Argonne National l

Laboratory, June 1987.

7.

WASH-1248, p. E-3.

i 8.

WASH-1248, p. S-24.

l 05/26/88 73 i

[7590-01) 9.

"Background Information Document--Standard for Radon-222 Emissions from Underground Uranium Mines," EPA 520/1-85-010 Environmental Protection Agency, April 1985.

10.

"Subpart W--National Emission Standard for Radon-222 Emissions from Licensed Uranium Mill Tailings," 40 CFR Part 61, Environmental Pro-tection Agency, 51 FR 34066, September 24, 1986.

11.

"Environmental Impact Statement for Remedial Action Standards for Inactive Uranium Processing Sites," EPA 520/4-82-013-1, Environ-mental Protection Agency, January 1983.

12.

NUREG-0116, p. 4-84,

13. WASH-1248, p. 34.

14.

NUREG-0216, p. H-17-18.

15.

NUREG-0116, p. 4-150.

16.

"Environmental Survey of Transportation of Radioactive Materials to and from Nuclear Power Plants," WASH-1238, U.S. Atomic Energy Commission, December 1972.

17.

"Supplement 1 to WASH-1238," NUREG-75/038, U.S. Nuclear Regulatory Commission, April 1975.

i 05/26/88 74

[7590-01) 18.

"Transportation of Radioactive Material by Air and Other Modes,"

NUREG-0170, U.S. Nuclear Regulatory Commission, December 1977.

l l

19.

"Shipping Container Response to Severe Highway and Railway Accidents, NUREG/CR-4829, U.S. Nuclear Regulatory Commission, February 1987.

20.

"The Environmental Consequences of Higher Fuel Burnup," AIF/NESP-032, Atomic Industrial Forum, June 1985.

i 21.

"The Use of Extended Burnup Fuel in Lightwater Power Reactors,"

NUREG/CR-5009, U.S. Nuclear Regulatory Commission, February 1988.

22.

NUREG-0216, p. I-2.

NOTE: All referenced documents are available for public inspection and copying for a fee in the Commission's Public Document Room at 1717 H Street NW., Washington, DC 20555.

l l

l 05/26/88 75

.o

[7590-01]

SECTION III.

POTENTIAL RADIATION DOSES, HEALTH EFFECTS, AND i

ENVIRONMENTAL IMPACTS In the Federal Register notice promulgating the final rule on Table S-3 (44 FR 45362, 8/2/79), the Commission noted that an impor-tant issue to be addressed in the narrative explaining Table S-3 is the question of the time period over which doses from long-lived radia ctive effluents should be evaluated.

The Commission also directed that the narrative address how the radiation dose commitments over extended periods of time might be evaluated and what the significance of such doses might be.

Since the present rulemaking adds values for long-term releases of technetium-99 and radon-222, these considerations are even more significant.

This rulemaking is concerned with estimating impacts on the environ-ment and on public health and safety, expressed in estimated numbers of potential or latent cancer cases and genetic effects.

The health effects on the total U.S. population resulting from the LWR fuel cycles are consid-ered generically in this appendix.

The exposure and risk to individuals are addressed in the safety analysis report and the environmental impact report, which are required for each fuel cycle facility and nuclear power l

reactor.

For purposes of this appendix, the radiation dose terminology will be that used in the proposed revisions to 10 CFR Part 20 (51 FR 1092, 1/9/87), so that there will be consistency in the definitions of dose i

related terms.

The units of dose used in this appendix are the tem and the millirem (one thousandth of a rem, or 1 arem).

The accepted inter-national system (SI) equivalent unit is the Sievert, which is 100 rem.

05/26/88 76 i

i

[7590-01]

The Commission believes that use of the more commonly used rem and millirem, or mrem, will be more readily understood by the public and is preferable in this narrative.

Definitions: (See Federal Register notice 51 FR 1092, January 9, 1987) 1.

"Dose" or "radiation dose" is a generic term which means absorbed dose, dose equivalent, committed dose equivalent, or committed effective dose equivalent; as explained in pertinent paragraphs of this section.

2.

"Absorbed dose" means the energy imparted by ionizing radiation per unit of mass of irradiated material at the location of interest.

3.

"Dose equivalent" means the product of absorbed dose, quality factor, and all other necessary modifying factors at the location of interest in tissue.

4.

"Committed dose equivalent" means the dose equivalent to organs or tissues of reference that will be received from an intake of radioac-tive material by an individual during the 50 year period following the intake.

5.

"Effective dose equivalent" is the sum of the products of the dose equivalent to the organ or tissue and the weighting factors appli-

)

cable to each of the body organs or tissues that are irradisted.

6.

"Committed effective dose equivalent" is the sum of the pro-ducts of the weighting factors applicable to each of the body organs and tissues that are irradiated and the committed dose equivalent.

7.

"Collective effective dose equivalent" or "environmental dose commitment" is the sum of the individual weighted dose equivalents j

received by a specific population from exposure to the given source of 05/26/88 77

[7590-01]

radiation.

For purposes of this appendix the populations considered are (1) a stable U.S. population of 300 million people for the next 150 years, (2) a world population of 4 billion people, (3) a future (after 150 years) world population of up to 10 billion people, and (4) a future (after 150 years) U.S. population of 3% of the world population.

8. "Occupational dose" means the dose received by an individual in a restricted area or in the course of employment in which the indivi-dual's assigned duties involve exposure to radiation and to radioactive material from licensed and unlicensed sources of radiation, whether in the possession of the licensee or other person.

Occupational dose does

.not include dose received from natural background, as a patient from medical practices, from voluntary participation in medical research programs, or as a member of the general public.

1 9.

"Public dose" or "dose to the public" means the dose received by the public from exposure to radiation and to radioactive material released by a licensee, or to another source of radiation either within i

a licensee's controlled area or in unrestricted areas.

It does not include occupational dose, or dose received from natural background, i

as a patient from medical practices, or from voluntary participation in medical research programs.

)

10.

"Exposure" means being exposed to ionizing radiation or to radioactive material.

11.

"Natural background exposure" means exposure to cosmic and terrestrial sources of naturally occurring radiation, including tech-nically enhanced radioactive material, such as plasterboard and ferti-lizer, but not including by product material or radioactive material specifically intended to be a radiation source.

05/26/88 78

[7598-@E]

Section III contains discussions and evaluations of radiation doses, j

environmental (population) dose ccamitment, and estimated health effects derived from these doses.

Section III.B contains a discussion of radia-tion doses, environmental dose commitments (EDC), and health effects estimated to result from release of radionuclide values given in Table S-3.

Table S-3 itself does not contain estimates of population dose or potential health effects.

These topics are presented and explained in Section III.A.

Section III.B contains a discussion of the period of time over which radioactive waste (disposed of in a repository) may represent a significant hazard, the estimated radioisotope releases (from the repository) that might occur over that period and the period of time for which calculations may provide meaningful information.

For purposes of this narrative, accuracy means the degree of conformity of the t.alculated dose to the true value of that dose.

Section III.C contains a discussion of estimated dose and health effects from long-lived radionuclide releases and an evaluation of their potential future impacts.

A.

Dose Commitments There are two types of population dose estimates considered in this narrative; they are the committed dose equivalent and the 150 year cumulative effective dose equivalent, which is called the environmental dose commitment (EDC).

To obtain the committed dose equivalent, the combined external and internal dose equivalent from the continued uptake of the pertinent radionuclide releases over a 1 year period are integrated for a 50 year period.

This accounts for the dose actually received over an individual's lifetime from radioactive material deposited in the body during that one year and the dose received from 05/26/88 79

?

[7590-01]

the radioactive material deposited in each of the previous years.

The j

EDC represents the sum of the 50 year dose commitments for each year of a specified period, for instance 100 years, following release of the given quantities of radioactivity, It includes the integrated dose from release of the radioactive material during the first year, including deposited and resuspended radioactive material, plus the total internal and external doses from uptake for the subsequent years, which for purposes of this narrative is an additional 49 years.

The determination of the dose and the dose equivalent is not trivial and is different for charged particles, gamma rays, and neutrons.

The energy levels, type, and density of the radiation must be known.

Depend-ing on how (geometry, accuracy) and when (temporal) the radioactivity is measured, the accuracy of the calculated dose may vary over a wide range, from about 110% at best to i many times 100% of the true value.

The pre-cision of dose estimation depends directly on the precision of radiation measurements, since other major factors in the calculations are fixed by

)

l convention (e.g., quality factor, radioactivity transfer within the j

environment, dose conversion factors).

The determination of dose may be fairly precise, because the models, environmental distribution data for radionuclides (transfer), and demographic assumptions are pretty well agreed upon and utilize data which are readily available. The accuracy of the determined dose, however, is probably not nearly so good.

Data are available to accurately predict (1 about 10%) the lifetime of some radionuclides, for instance uranium-238, for billions of years.

But the dispersion of radionuclides in the environment, their biological uptake, and their biological effects are less predictable, and thus less accurate, by many orders of magnitude.

The radiation values set forth in Table S-3, 05/26/88 80

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were selected to be conservative, that is to avoid underestimation of calculated doses in relation to the potential true values.

Since these values are source terms for dosimetry calculations, the calculated doses will be conservative (i.e., probably not underestimated).

The health effects of concern in this narrative are cancer mortality and genetic or heredity effects.

Opinions differ markedly on how to interpolate between the ab..nce of health effects at low levels of radia-tion or dose and the observed health effects at high levels of radiation or dose.

Some believe that available data best supports use of a linear model for estimating these effects, while others believe that other models provide better estimates.

The most important studies of radiation effects on humans are those of the Hiroshima and Nagasaki atomic bomb survivors.

Additional studies are under way to reassess these dose calcu-lations, which may provide better estimates of risk.

In spite of the lack of hard data, however, estimates of risk from exposure to low levels of radiation are reasonably well bounded.

For purposes of this narrative.

health effects are assumed to be directly and linearly related to dose levels no matter what the dose level.

Health effects are observable at high levels of radiation.

It is fairly well established that exposure to radiation doses over about 450 rem administered at very high dose rates will prove fatal, within about 30 days, to about half of the people exposed (LDso).

Clinical evidence of health effects may be observed down to about a dose level of 50 rem.

In order to estimate health effects at lower levels of radiation it is necessary to extrapolate through several orders of magnitude with l

little intervening confirming data or benchmarks.

For example, linear extrapolations are used from about 50 rem down to 5 rem, which is the i

05/26/88 81 g

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limit given in 10 CFR Part 20 for annual occupational exposure, or to 0.5 rem (500 millirem) which is the limit for exposure to an individual in an unrestricted area, or to 0.1 millirem which is the "de minimis" level suggested in the proposed Part 20 rulemaking (51 FR 1092, January 9, 1987).

In general, as the dose gets smaller and smaller and as the future time period gets longer and longer, the statistical error band for the calculated dose gets wider and wider, as will be shown later, and the degree of accuracy becomes less and less.

It should be noted here that the significant figures used in this narrative and shown in Taole S-3 are not intended to indicate that cal-culations are accurate or precise to the degree indicated.

The signifi-cant figures and the number of decimal points are used primarily to be consistent with previous rulemakings and published data.

Due to the many unknowns, assumptions, and long-term estimations used in the calcula-tional models, the degree of accuracy (in the sense of conformity to a true value) cannot be determined with certainty.

In this discussion, the environmental models used to calculate the transport of released radioactivity to man and to estimate the potential somatic and genetic health effects are updated versions of the models discussed in the GESHO hearings [1].

The models are also described in Appendix C of NUREG-0216.

Basically, the models account for the dispel sion of radioactivity released into the environment, the bioaccumulation in food pathways, the uptake by man, and the calculated dose resulting from that uptake.

In practice, it is highly unlikely the EDC for very long-lived nuclides, such as 1-129 (17-million year half-life) can be predicted with any reasonable degree of accuracy to the end of even one radioactive half-life.

There is no way to establish factually the many 05/26/88 82

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o variables that affect such estimates (e.g., the growth of human popula-tions, response to low levels of radiation, technological advances, the environmental behavior of radionuclides, unpredictable catastrophic climatic and geologic changes).

For regulatory purposes conservative values must be assumed for estimating health and safety impacts to insure that these effects are not underestimated, but a reasonable upper bound must also be established in order that regulations can be implemented.

NRC, EPA, and other agencies use a truncated EDC, which gives the collective effective dose equivalent over a limited period when radiation exposure is greatest, rather than over the entire period of radioactivity.

In GESMO [2), the length of the truncated EDC was 40 years and was applied to an assumed U.S. population of 250 million people.

Thus, 50 year population doses were calculated for each year of the 40 year exposure period and summed (i.e., the total length of time covered was 40 + 50, or 90 years).

For purposes of this narrative the calculations have been extended to cover a 100 year period, as recommended by the S-3 Hearing Board.

Since each year's exposure is calculated for 50 years, the total time covered by the 100 year EDC is actually 150 years.

For the overall fuel cycles, the collective effective dose equivalent (EDC) is projected to be 750 person-rem per RRY for an assumed stable U.S. population of 300 million people.

It should be noted that for tritium (H-3) and krypton-85 (Kr-85)

(two major short-term (about 100 years or less) dose contributors) there is little difference between a 40 year EDC and a ISO year EDC, since about 90% of both nuclides will decay within the first 40 years.

The same is true, but to a greater degree, of the shorter-lived radionuclides 05/26/88 83

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released from the fuel cycle activities, such as cobalt-60 (5 year half-life), iodine-131 (8-day half-life) and ruthenium-106 (1 year half-life).

To a lesser extent, radioactive decay reduces the quantity remaining after 40 years for other important but longer lived radionuclides, such as strontium-90 (29 year half-life) and cesium-137 (30 year half life).

For these reasons, increasing the length of the EDC from 40 to 100 years results in much less than a doubling of the estimated dose commitment and, thus, potential health effects.

A further extension of the EDC from 100 to 1,000 years would increase the collective effective dose equiva-lent, and thus tha risk, by less than 10% in many cases.

This increase

.is considerably less than the uncertainty associated with estimating and calculating these radiation doses.

Nevertheless for very long-lived radioisotopes an EDC does continue to increase with time.

Calculated health effects would also continue to increase, for instance for C-14 and I-129 and for the special case of 3.8-day half-life Rn-222 that continues to be formed by the radioactive decay of the long-lived parents in the residual mill tailings.

The predominant amount of Rn-222 will be released from these tailings piles.

The length of time that the Rn-222 will emanate is dependent on the residual radium-226 (Ra-226) left in the i

tailings after the uranium has been removed and purified.

The mathemati-cal equivalent of calculating the total Rn-222 created over the radio-nuclides's lifetime is to calculate its release for the average lifetime l

of its precursor.

The average lifetime of a radionuclide is its half-life divided by the natural log of 2, which is 0.69315.

The average lifetime of Ra-226 is 1600 years divided by 0.69315, or about 2300 years.

In develop-ing its regulations on standards for radon-222 emissions from licensed uranium mill tailings, EPA based the Rn-222 emission rate un the Ra-226 05/26/88 84

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concentration in the tailings.

Thus, a reasonable time frame over which to evaluate Rn-222 emissions from a tailings pile would be about 2300 years.

The uranium which has been purified at a mill does not re-lease significant quantities of radon-222 until after thousands of years have elapsed because the Rn-222 is formed from radium-226 with a 1600 year half-life.

Radium-226 is formed very slowly by radioactive decay of radioisotopes derived from U-238, which has a half-life of over 4 billion years.

In the area of health effects, it is probable that even the 40 year EDC calculated for previous Table S-3 hearings overestimates radiation exposures.

As mentioned previously, health effects models used for this narrative assume a linear extrapolation from health effects observed at high doses and dose rates to potential effects at low doses and low dose rates.

In addition, the assumption is made that there is no dose below which health effects cannot occur.

It is believed that such modeling, although useful for regulatory purposes, tends to overestimate the actual effects of exposure to low levels of low-linear-energy-transfer (low-LET) ionizing radiation (e.g., X-ray).

Many animal and cellular studies indicate reduced somatic and genetic effects as the doses and dose rates are reduced, but the evidence is not yet accepted as conclusive.

Some scientist.s believe that, at low doses and low dose rates, the effects per unit of radiation dose may actually decline due to cellular repair and other mechanisms.

These reductions are not taken into account in the model used to calculate health effects for the Table S-3 releases.

Reports by the major radiation protection organizations [3-8] also indicate that the linear extrapolation hypothesis probably overestimates i

rather than underestimates the risk from low levels of radiation and 05/26/88 85

[7590-01) o low-LET radiation. They suggest that such estimates be regarded as upper limits of risk (6).

In this regard, beyond mining and milling, the major population dose from the uranium fuel cycle results from exposure to very low radiation doses and low-LET radiation.

In general, the controversy about whether the risks related to high-LET radiation are understated pertains to the effects from exposure to neutrons and alpha particles.

This type of radiation is not significant with respect to the back end of the LWR fuel cycles, because the high-LET radiation that results mainly from the transuranium elements (TRU) contributes less than about 0.4% of the total potential health effects attributable to the back end of the LWR fuel cycles.

Health risk estimators are shown in Table 4.

The cancer mortality risk estimates are based on the "absolute risk" model described in the 1972 report of the National Academy of Science's Advisory Committee on the Biological Effects of Ionizing Radiation (BEIR I).

Values for cancer mortality risk range from 125 to over 250 deaths per 1 million-person rem.

Estimates of risk could be higher if the "relative risk" model were used, along with the assumption that risk prevails for the duration of life.

Use of the "relative risk" model would produce risk values up to about four times greater than those used in this narrative for exposure of the total body.

The staff regards the use of the "rela-l tive risk" model values as a reasonable upper limit to the range of un-l certainties.

The number of nonfatal cancers could be 1.5 to 2 times the number of potential fatal cancers, according to the 1980 report of the National Academy of Science's Advisory Committee in the Biological Effects of Ionizing Radiation (BEIR III).

It should be pointed out that all such 05/26/88 86

[7590-01) e estimates are "potential," because the actual risks could be much lower and, at least for low levels of radiation and low-LET, could include zero.

In addition, health effects, either carcinogenic or genetic, produced by radiation are not unique. They also occur in populations that are not exposed to man-made radiation sources.

This absence of uniqueness makes it impossible to determine whether or not any particular incident may have been the cause of a health effect.

Table 4*

Health effects estimators (To be updated using risk estimators from BIER IV)

Total Body Dose:

135 cancer deaths per million person-rem 258 genetic effects per million person-rem Thyroid Dose:

13.4 cancer deaths per million person-rem Lung Dose:

22.2 cancer deaths per million person-rem Bone Oose:

6.9 cancer deaths per million person-ram l

  • Data taken from Table IV J(B)-1, NUREG-0216, Appendix C, pg.

C-22.

l Values for genetic risk estimators range from 60 to 1500 potential cases for all forms of genetic disorders per million person-rems (3).

The value of 258 chosen for this evaluation is equal to the sum of the geometric means of the risks from different types of genetic defects.

These values for risk estimators are consistent with the recommendations of major nrganizations on radiation protection, such as the National Academy of Sciences [4), the International Commission on Radiological Protection [5), the National Council on Radiation Protection and Measure-ment [6), and the United Nations Scientific Committee on the Effects of Atomic Radiation (8).

05/26/88 87

,,n

[7590-01) e The natural incidence for cancer has been taken from the data of the American Cancer Society, or calculated using the same dose response models used to calculate other fuel cycles impacts.

In the case of calculations, the incidence is based on cancer mortality levels from background levels of radiation.

The calculated incidence should always be less than the actual levels, since factors other than radiation are known to induce cancers and other health effects.

Many studies have shown that cancer deaths and genetic abnormalities are indistinguishable whether they result from exposure to radiation related to man-made pro-jects or they result from any other cause.

When values are quoted for cancer incidence, the incidence is for carrrr mortality, rather than cancer induction, since mortality is a well defined quantity for which a great deal of information is available.

The staff's estimate of poten-tial radiological impacts from the LWR uranium fuel cycles, including reprocessing and radioactive waste managerrert, are shown in Table 5.

Table 5 U.S. Population dose and health effects from LWR fuel cycles Total Body (person-rem /RRY):

550 (100 year EDC)

Risk Equivalentt (person-rem /RRY):

850 (100 year EOC)

Fatal cancers /RRY:

0.1 Genetic Effects /RRY:

0.1 tIncludes dose commitments to other organs as well as whole body dose commitments.

As explained in the proposed rule revising part 20 (51 FR 1092, 1/9/86, at section III) ICRP Publication 26 introduced the terms "effec-tive dose equivalent" and "committed effective dose equivalent" to 05/26/88 88

[7590-01) describe concepts that would permit combing doses received from external and internal radiation exposure.

This method assigns each organ a weight-ing factor that is proportional to the estimated risk to that organ per unit of dese relative to the estimate of risk per unit of dose for a uniform whole body exposure.

By using assigned risk estimators, it is possible to estimate the whole body committed dose equivalent.

The collective effective dose equivalent to the estimated U.S population from the entire LWR fuel cycle is estimated to be about 100 person-rem per RRY fuel replacement.

The 100 year EDC would be about 650 person-rem per RRY.

The significan e of radiction exposure and the subsequent risk from the LWR fuel cycles may be evaluated by comparison with background radia-tion exposure, with the hazard of uranium and related radionuclides in an ore body, with risks from practical alternative electrical power sources, and with nonradiation risks common to living in a modern society.

It is assumed that some method must be chosen to supply the equivalent electric power produced by a RRY fuel replacement.

The principal alternative available to supply the electrical power is a coal-fired plant, and this is the one shown in Table S-3A and discussed in the narrative.

Compar-ison of the impacts from energy conservation and from other alternative power sources cannot be undertaken in this short narrative, but the impacts of these alternatives are not trivial.

More detailed information can be found in the specific references.

Comparisons are made, in this appendix, with natur61 background radiation 1 p als, with hazards asso-ciated with uranium ore bodies, with commensurate risks from a similar model coal-fired plant, and with the natural occurrence of concers and 05/26/86 89

[7590-01) genetic abncemalities.

Due to the uncertainties inherent in calculations of health effects, it is not possible to establish absolute numerical risk values for public health and safety.

However, these discussions show that the risk to public health and safety from the effects of the LWR fuel :ycle is reasonable.

The use of natural background radiation as the starting point for evaluating radiation exposures has precedence in.he recommendations and i

practice of the Federal Rad ation Council, National Council on Radiation Protection and Measurements, and the United Nations Scientific Committeo on the Effects of Atomic (adiation. [3-8] Everyone is exposed to natural

. background radiation.

The average natural background radiation exposure for the continental U.S. is about 100 mrem per person per year, not considering doses from natural radon emissions.

In practice, the natural background varies frcm about 75 mrem per person per year along parts of the southeastern Atlantic and Gulf coasts to greater than 200 mrem per person per year for the higher elevations such as the Colorado Plateau.

These variations are due principally to changes in the elevation, with commensurate reduction of atmospheric shielding of cosmic rays, cnd the abundance of naturally occue"ing radionuclides in the environment.

Living habits may also alter the natural background exposure received.

For example, the recent trend towards energy conservation has resulted in de-creased ventilation rates in homes.

This has caused a significant increase in the levels of radon present in the air inside houses in some cases.

The estimated dose from radioactive releases from all LWR fuel cycle activities per RRY is about 2E-8* reni per person per RRY.

The BEIR III

  • 2E-8 is equivalent to 2x10.s.

This notation is used to show very small numbers.

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report notes that airline passengers on an average flight lasting 1.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> at an altitude of about 31,500 feet will receive a cosmic ray dose of 0.28 mrem [4].

While this is a very small amount, it is over 10,000 times more radiation exposure than one would get from the combined activ-ities of the LWR fuel cycles.

Another way to address the question of time over which the spent fuel in the repository represents a significant hazard is to assess the net potential impact of its disposal relative to impacts if the uranium in the RRY fuel replacement (fresh fuel) had remained in the ore body.

For this assessment it is assumed that an engineered system, including waste form, packaging, and the repository, can be expected to confine I

radioactive waste materials at least as well as an isolated ore body.

This assumption is believed to be reasonable, because ore deposits oc. cur in various geologic settings, are in contact with groundwater, are in contact with soils with only moderate retardation of solute movement, and i

have varying ion travel distances to the biosphere.

A repository, on the' other hand, will be located in a hydrogeologic setting purposely selected to have no known or prospective contact with circulating groundwater, high retardation of solute movement, and large ion travel distances to l

the biosphere.

In addition, the repository system, including waste form and packaging, will have engineered features that are intended to prevent the release of radionuclides.

The time period over which spent fuel or HLW might be considered significant hazard could be to compare a hypo-thetical dilution index of radionuclides associated with uranium in an ore body.

The EPA, in a final rule entitled "Environwntal Standards for the Management and Disposal of Spent Nuclear Fuel, High-Level and Tran-suranic Radioactive Wastes," indicates that primary standards for 05/26/88 91

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aisposal are long-term containment requirements that limit projected releases of radioactivity to the accessible environment for 10,000 years after disposal, and that these release limits should insure that risks to future generations from disposal of these wastes will be no greater than the risks that would have existed if the uranium ore used to create the wastes had not been mined to begin with.

A factor referred to as "the dilution index" can be calculated on the basis of the amount of water required to dilute the concentration of these radionuclides to the limits specified in 10 CFR Part 20.

This comparison is not intended to endorse Part 20 limits, merely to use them for comparative purposes.

From Figure 3 it can be seen that fission products dominate the dilution index up to about 200 years from the time spent fuel is discharged from the reactor.

Between 200 years ard about 50,000 years, the transuranic radionuclides and their daughters dominate the dilutic.

idex, and beyond 100,000 years uranium and its daughters dominat However, in HLW, after reprocessing, the uranium and plutonium content would be reduced by over 90% compared to spent fuel.

From Figure 4 it can be seen that the growth of the uranium daughters, radium, and lead such as would be found in an ore body dominate for aged ur radiated uranium fuel for about 100,000 years.

The dilution index for both spent fuel, or HLW, and unirradiated uranium fuel are about the same, both being dominated by uranium and its daughters.

Thus, without considera-tion of dispersion or retardation relative to groundwater transport time, at about 100,000 years the dilution index of the waste in a repository is about the same as that for aged unitradiated uranium fuel, as might be found in an ore body.

Plutonium and americium would be expected to have long delay times during transport from the repository to the biosphere, 05/26/88 92 h

l

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j t

Figure 3 i

05/26/88 93

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Figure 4 05/26/88 94

[7590-01) due to sorbtion and low groundwater flow.

Thus, the dilution index for these materials in the waste is expected to be about the same as aged unirradiated uranium after about 10,000 years.

There is a need to establish some level of radiation below which it is not necessary to extend regulatory actions.

Such a level has been proposed by the Commission in revisions to 10 CFR Part 20 (51 FR 1092, 1/9/87 at section XVIII) and would be set at 0.1 millirem per year.

This level, also called a "de minimis" level, could be calculated to result in risks that are so low as to be considered insignificant when compared to risks that are encountered under normal living conditions.

Levels of radiation this low would be indistinguishable from fluctuations in back-ground radiation.

If an individual receives a radiation dose equivalent to 0.1 millirem per year every year for a lifetime, the calculated risk of the use of cancer death or genetic effect induced by this much radia-tion is less than 1 in 1 million.

The Commission believes that this is a reasonable lower limit for cutting off calculations of radiation dose and' dose commitment for regulatory purposes.

This cut off level has not been used for calculating estimated radiation dose and health effects in this narrative, because a "de minimis" level has not yet been adopted.

Effects of the use of a "de minimis" level would be to limit the size of popula-tions and reduce the time over which collective doses would be considered.

l The following example illustrates the magnitude of fuel cycle effects on the U.S. population (assumed to be 300 million).

If three light-water reactor power plants were to be operated for their lifetime (30 years), the estimated EDC for carcinogenic impacts would be about 590,000 person-rem and the genetically significant dose commitment would be about 500,000 person-rem.

This is calculated to have a potential 05/26/88 95

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effect of causing about 8 additional (above the number normally expected to occur) cancer deaths and 13 additional genetic effects over the period of the EDC.

Some further perspective can be gained by comparing such estimates with "normal" cancer mortality for the same population.

Assum-ing that future population characteristics (population, age distribution, cancer susceptibility) and competing risks of mortality remain the same as today, projections are about 6 million cancer deaths from causes other than radiation related to generation of electricity from nuclear reactors.

Assuming that the normal occurrence of genetic effects remains constant, 1

projections are about 3.2 million additional genetic effects under the same circumstances.

In a report prepared for the NRC (NUREG-0252, "The Environmental 1

Effects of Using Coal for Generating Electricity," Argonne National Laboratory, June 1977), the deaths caused by air pollution in the vicin-ity of a 1,000-MWe coal-fired plant were estimated to range from 0.2 to 3.4 per year over 25 years of plant operation for a rural plant site or from 1 to 20 per year for an urban site.

The range of the estimates was the result of differences in pollution caused by various types of coal.

The comparable estimate for operation of the LWR fuel cycles considered here is loss than 0.1 deaths per year.

Assuming the effects, that is deaths attributable to the model reactor, to be spread over the total U.S. population, this is less than half the lowest estimate for coal and I

only 0 4% of the highest estimate.

Not only are the risks from the fuel cycle small in comparison to natural background risks, but they are also small in comparison to the risks of coal-fired power plants, which is the principal alternative electric power source available in the U.S.

05/26/88 96

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Using the lifetime risk estimate of 135 cancer deaths per million person-rem and averaging the 650 risk equivalent person-rem per RRY over the estimated U.S. population, the staff calculates that the average lifetime individual risk of cancer mortality from radioactivity released from the LWR fuel cycles is probably not greater than about 1.4 chances per million per RRY.

The average lifetime risk per person of cancer mortality from radioactivity released from the LWR fuel cycles of all the currently operating and projected nuclear reactors, if they all operated for 30 years, is estimated to be less than 2 chances in a million.

Assuming one RRY supplies electrical power for approximately a million persons (about 0.8 gigawatts) and that all of the cancer risk is borne only by these users, the average lifetime risk to this population group would be less than 1 chance in a million per RRY.

P Currently, the number of U.S. nuclear power reactors operating or under construction totals 125 and will provide a nuclear generating capa-city in the United States of about 115,000 megawatts.

The estimated potential upper-limit health effect risk fro:n radioactivity released to the environment from the LVR fuel cycles, from all currently operating or planned nuclear reactors in the United States, is shown in Table 6.

For the currently projected U.S. nuclear power industry, the poten-tial upper limit for cancer mortality risk estimated for the 100 year EDC and a 10,000 year EDC are about 6E-4 percent and about 7E-4 percent, respectively, of the potential occurrence of natural cancer mortality in the U.S. population over equivalent periods of time.

The incremental difference in U.S. population dose due to the projected growth of nuclear power would average less than 1 mrem per person per RRY. According to 05/26/88 97

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Table 6 Estimated fuel cycle risks of cancer and genetic effects 100-Year EDC*

10,000-Year EDC2 Incidence Incidence Cancer of Genetic Cancer of Genetic Mortality Effects Mortality Effects Fuel Cycle Health Effect Risk, All Reactors Currently Operating or Under Construction 330 520 440 780 Natural Occurrence 2 6E+7 3.2E+7 6E+9 3.2E+9 (300 million population)

Percent Increase 6E-4 2E-3 7E-6 2E-5 (Over Natural)

  • Environmental Dose Commitment.

1 Increase results primarily from long-life C-14 and I-129 effluents.

2The natural occurrence is based on the current incidence of actual cancer fatalities (about 20%, American Cancer Society, 1978), the current inci-dence of genetic ill health (about 11% per generation, BIER III), and a conservative life expectancy of 100 years.

the BEIR Committee, radiation levels of 100 mrem per year or less can be regarded as comparable to other risks that are often ignored by the public.

B.

Potential Long-term Effects of Waste Disposal NUREG-0116 and NUREG-0216 contain data on potential long-term risks from escape of radionuclides from a repository [10] and from low-level waste disposal operations [11], but no entries were made in Table S-3 for these potential releases because they are tco small too affect the signi-ficant figure of the calculated values.

The staff has raviewed the long-term effects of low-leval radioactive waste (LlW), transuranium element (TRU), high-level waste (HLW) disposal, or spent fuel disposal.

The 05/26/88 98

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potential health effects resulting from long-term releases of low-level waste have been addressed in NUREG-0216 [12], and no additional consid-eration of the potential effects of disposal of these types of wastes is believed to be necessary in this narrative.

Further, the disposal of LLW was also addressed in promulgating 10 CFR Part 61, "Licensing Require-Icents for Land Disposal of Radioactive Waste" (47 FR 57446, 12/27/82).

This rule was supported by an environmental impact statement, NUREG-0945, which demonstrates that LLW can be disposed of safely and without signi-ficant environmental impacts.

In developing the estimates for Table S-3,

)

it has been assumed that TRU wastes will be disposed of in a repository 1

along with HLW or spent fuel.

There is no separate value for TRU waste, because it is included in the values labeled "TRU and high-level wastes" in the Table.

The wastes from the once-through and uranium only fuel cycles that will be disposed of in federal repositories differ from one another in several ways as discussed below:

)

Waste Form - The dominant amount of radioactive waste from the once-through fuel cycle is in the form of spent fuel assemblies with the j

fission products, TRU, and actinides contained in the UO2 matrix.

High-level waste from the uranium-only fuel cycle will be solidi-fied, probably in the form of a glass or ceramic material having properties engineered to reduce mobility of the radionuclides to meet the limits specified in 10 CFR part 60.

These properties cannot be described in detail at this time, because the waste form has not yet been specified.

But the wastes will probably be incorporated into some form of glass or ceramic matrix which is insoluble in water and 05/26/88 99

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is encased in corrosion-resistant metal.

For purposes of this dis-cussion, the various forms of solid waste have been assumed to have radionuclide retention properties adequate to meet NRC and EPA regu-lations.

Radionuclide Content - The spent fuel contains the nonvolatile fission products, TRU, and HLW produced in the course of its irra-diation, as well as all the residual uranium and plutonium. The solidified HLW will contain the nonvolatile fission products, TRU, and only small amounts of uranium and plutonium.

The main differ-ence between the spent fuel and HLW is that the HLW will contain less than 5% of the uranium and plutonium originally present in the spent fuel.

Thus, on a comparative basis, since all other nuclides are present in about equal amounts in both wastes, the spent fuel represents a greater long-term risk because of its larger uranium and plutonium content.

For waste placed in a repository system to reach the biosphare, one of two types of events must occur.

The first involves essentially common-place occurrences and requires that (1) water infiltrate the repository, (2) the waste container corrode, and (3) radionuclides be lea:hed from the waste form.

Long-lived radionuclides may eventually reach the bio-sphere by migration of the radionuclides, probably by movement with groundwater, to a discharge point at the surface.

This type of event could expose man to radioactive materials via food chains or other environ-mental pathways.

The second type of event involves unusual occurrences, such as disruption of the repository by man-made or natural events, that 05/26/88 100

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release radionuclides directly to the biosphere.

Sites for a repository will be selected in areas where the probability that a natural event would disturb the repository is extremely low and will be located away from identified natural resources to minimize the probability that man would inadverter,tly disturb the repository.

In the event that water does infil-trate the repository, it would take a long time for leached radionuclides to be transported to the biosphere by groundwater movement.

Hovement of groundwater is itself slow, and retarding mechanisms such as ion exchange increase the travel time for most radionuclides such that it might take tens to hundreds of thousands of years for them to reach the biosphere

[14].

In this period of time, most radioactive material will have decayed to very low levels.

On the other hand C-14, Tc-99, and I-129 have a combination of low retardation by ion exchange and long radioactive half-lives.

Thus, if these radionuclides were leached from wastes, they could reach the biosphere in significant quantities.

However, in developing the source terms for Table S-3, it was assumed that C-14 and I-129 were relea:ed to the biosphere before the waste was sent to the repository.

While not the actual case with respect to the disposal of spent fuel or HLW, this assumption mets an upper limit to potential impacts, because it assumes that 100% of the C-14 and I-129 are released, and at their max-imum radioactivity.

The potential long-term effects of waste repositories could be interpreted as follows:

1.

In releases by natural processes there is pro,bably a long delay (10,000 or 100,000 years) between the time the nuclide (or its parent) leaves the repository and the time it reaches the biosphere.

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[7590-01) 1 The radiation impacts of the pertinent radionuclides from spent fuel or HLW are greater than those of aged, unirradiated uranium for only about 10,000 years.

Given the number of conservative assumptions related to the models for calculating releases and the small poten-tial net impact after 10,000 years, the staff believes that cal-culating releases beyond 10,000 years provides little meaningful information.

2.

For man-made disturbances that could result in direct releases to the human environment (for example, drilling into a repository),

spent fuel would have a significantly greater net potential hazard than unirradiated uranium for as long as 100,000 years.

The impacts from the disturbance would depend on the time and nature of the action causing the release.

C.

Oose Commitments and Health Effects from Long-Lived Radionuclides The Commission directed the staff to discuss the time period over which dose commitments should be evaluated, how the dose commitment evaluations over extended periods of time might be evaluated, and what their significance might be.

In Section III A, it was shown that a 100 year EDC was adequate to provide the total dose commitment from most isotopes.

Long-term evaluations are necessary if an EDC is to be deter-mined to completion, although the effective rate decreases with time.

It should be also noted that the reliability decreases with the dose or dose rate and the longth of time.

The estimated curie releases for these isotopes are shown in Table 7.

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[7590-01) l Table 7 Radioactive Releases for Carbon-14, l

Iodine-129, and Technetium-99 Carbon-14 24 Ci/RRY Iodine-129 1.3 Ci/RRY Technetium-99 507 Ci/RRY l

NOTE:

Carbon-14 and I-129 are presumed to be l

emitted as volatile materials, prior to disposal l

in a repository.

Tc-99 is presumed to be l

released from a Federal repository at 10 5 of this quantity per year.

l Technetium can exist in several chemical forms.

Under the condi-tions expected for groundwaters not in contact with air, it would

'probably be in the dioxide or related hydrated form.

These forms are very insoluble so the concentration of technetium in the migrating groundwater should be low.

However, the oxidation conditions are dif-ficult to predict, so technetium has been considered to be present as the pertechnetate oxyanion, which is more soluble.

All of the Tc-99 is assumed to migrate to the bioshere.

Technetium-99 could be leached from the waste repository and reach the biosphere dissolved in water.

Standards issued by EPA in its regulations limit annual releases from the reposi-tory to 10 5 of the quantity of the radionuclide present.

For Tc-99, this would be 0.005 Ci/RRY/ year.

The staff has assumed that all of the Tc-99 moves in the groundwater without reduction by precipitation, adsorp-tion, or other mechanisms.

Since Tc-99 half-life is over 200,000 years and its sorption is very low, there is no apparent mechanism for a sig-nificantly delayed release.

However, its potential dose is not large enough, compared to potential doses from Rn-222, C-14, I-129, to affect the significant figure for estimated health effects.

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long-term impacts have been calculated using the same methods as for the short term, because no better method has been found.

The 150 year EDC covers the maximum impact to any person presently living and lesser impacts to the succeeding generations who might be exposed for their entire lives but at lower levels of radiation.

As shown in Tables 8 and 9, the cumulative impacts from long-lived radionuclides calculated over a 250,000 year period, increase only by about 2 to 3 times beyond the impacts for the first 100 years.

Over the entire period the calculated cumulative impacts total 0.07 additional cancer deaths over the assumed total U.S. population.

Results of these assessments cannot be proved in the usual demonstrative sense, even for the short-tern estimates.

Inter-pretation of these estimated values is subject to the confidence level of the data and models, to individual interpretations of what constitute an accep W

>f risk, and to the circumstances under which comparisons are rr 1.

Calculation of Dose To calculate an EDC one must (a) predict the population at risk, (b) model the time-dependent behavior of each radionuclide and its trans-fer into the environment, (c) predict the response of the population to the radiation exposure, and (d) estimate the resulting health effects, which for purposes of this narrative are cancer mortality and genetic

effects, a.

Population at Risk In considering population at risk over time periods of thousands of years, assumptions that cover a wide range of hypothetical conditions 05/26/88 104

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1 must be made.

Predictions based on geologic history indicate that several catastrophes could occur.

For instance as many as 10 ice ages could occur over 250,000 years [15].

Large fluctuations in population could be expected from such catastrophes.

The staff has assumed a stable world population of up to 10 billion for the first 10,000 years, with periodic variations of population of from 2 billion to 10 billion as a function of time beyond 100,000 years.

The U.S. population is assumed to be 3% of the world population, b.

Model of Radionuclide Behavior (1) Carbon-14 The GESMO and Table S-3 hearing records do not contain a model that adequately predicts the behavior of C-14 in the environment over long time periods.

The GESMO computer code model (RABGAD) can be adapted to estimate the collective dose to the U.S. population from the initial passage of C-14, i.e., before it mixes in the world's carbon pool.

A modification of the C-14 model developed by Killough [16] was used to obtain long-term dose.

(2) Iodine-129 Appendix C of NUREG-0216 provides a model for estimating long-term population doses from I-129.

The GESMO model (RABGAD) can be used for estimating the collective dose to the U.S. population from the initial passage of I-129 prior to mixing in the world pool of stable iodine.

The model assumed for the Table S-3 hearings results in 7.1 E-12 rem per year per curie released to each person in the world after mixing occurs.

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The dose rate will decline at least in direct proportion to the radio-logical half-life of about 17 million years.

Although removal mechanisms probably exist that would result in an environmental half-life of much less, the environmental half-life is taken to be the radiological half-life.

(3) Tritium (H-3) need a discussion (4) R a do n-2,2_2 need a discussion l

(5) Technetium-99 Technetium-99 is not evaluated because its total dose contribution is negligible (i.e., its dose is not large enough to effect the significant figure) compared to Rn-222, C-14, and I-129.

In calculating the health effects resulting from these radiation exposures, the staff used the health effects estimators described in Table 4.

1 2.

Numerical Estimates of Collective Doses and Health Effects The models described above, with the assumptions delineated for population and population response to exposure, have been used to calcu-late long-term dose commitments resulting from C-14. I-129 Rn-222, and Tc-99.

These radionuclides account for over 99% of the potential total dose from the entire LWR uranium fpel cycles.

Thus, the other radionu-clides are not discussed in this narra.ive.

In fact Tc-99 does not 05/26/88 106

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contribute significantly when compared to Rn-222 or C-14.

The values for a 250,000 year are given in Table 10.

It can be seen from Table 8 that integrating C-14 collective effective dose equivalent (EDC) over 10,000' years encompasses rost (over 99%) of the total person-rem dose from this nuclide. These data indicate that exposure of the assumed population integrated to infinite time is less than 3-4 times the first-pass exposure.

About 0.001 additional cancer deaths per RRY in the U.S.

population might occur from C-14 calculated over this period.

An addi-tional cumulative total of about 0.1 generic defects per RRY could be expected.

According to the statistics of the American Cancer Society, Table 8 U.S. population dose commitments and potential health effects for 24 Ci/RRY release of C-14 from the fuel cycle Time Cumulative person-rem Cumulative cancer Cumulative genetic (years) and cumulative genet-mortality defects ically significant dose (organ-rem)

{

l 100 130*

0.02 0.03 1,000 170 0.02 0.04 l

10,000 380 0.05 0.10 100,000 430 0.06 0.11 250,000 430 0.06 0.11

  • First Pass Dose = 114 person rem (total body risk equivalent) or organ-rem.

1 i

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Table 9 U.S. population dose commitments and potential health effects for 1.3 Ci/RRY release of I-129 from an HLW repository Time Cumulative person-rem Cumulative genetically significant (years)

(total body risk population dose (organ-rem) equivalent)*

100 40**

4.4t 1,000 40 4.4 10,000 43 4.7 100,000 55 6.0 250,000 76 8.4 Cumulative Cancer Mortality Cumulative Genetic Effects 100 0.0054 0.0011 1,000 0.0054 0.0011 10,000 0.0058 0.0012 100,000 0.0074 0.0015 250,000 0.01 0.0022

  • Total body dose equivalent is the sum of the total body dose and each organ dose multiplied by the ratio of the mortality risk per organ-rem to the mortality risk per person-rem (total body).
    • First pass dose = 31 person-rem whole body risk equivalent.

tFirst pass organ dose 4.4 organ-rem (gonads).

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Table 10 World population dose commitments for release of hydrogen-3, carbon-14, krypton-85, and iodine-129 Quantity released Cumulative person-Cumulative cancer Radionuclide (Ci) rem (total body risk-mortality equivalent)*

Tritium 18,000 200 0.027 Carbon-14 24 10,600 1.4 Krypton-85 400,000 440 0.059 Iodine-129 1.3 1,250 0.17 TOTAL 12,490 1.66

  • For a 250,000 year time period.

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Table 11 U.S. population dose commitments and potential health effects for Ci/RRY release of Rn-222 l

Time Cumulative person-rem Cumulative genetically significant (years)

(total body risk population dose (organ-rem) equivalent)*

100 1000 (Data to be provided under contract with 10,000 Oak Ridge National Laboratory.

Table to be completed prior to publication of the 100,000 proposed rule.)

250,000 Cumulative Cancer Mortality Cumulative Genetic Effects 100 j

1000 10,000 100,000 250,000

  • Total body dose equivaler.t is the sum of the total body dose and each organ dose multiplied by the ratio of the mortality risk per organ-rem to the mortality risk per person-rem (total body).
    • First pass dose = 31 person-rem whole body risk equivalent.

tFirst pass organ dose 4.4 organ-rem (gonads),

i i

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i l

Table 12 U.S. population dose commitment and potential health effects for 0.225 Ci/RRY release of Tc-99 when spent fuel is recycled i

Tin,e Cumulative person-rem Cumulative genetically significant (years)

(total body risk population dose (organ-rem) equivalent)*

100 1000 (Data to be provided under contract with 10,000 Oak Ridge National Laboratory.

Table to be completed prior to publication of the 100,000 proposed rule.)

250,000 Cumulative Cancer Mortality Cumulative Genetic Effects 100 1000 10,000 100,000 E50,000

  • Total body dose equivalent is the sum of the total body dose and each organ dose multiplied by the ratio of the mortality risk per organ-rem to the mortality risk per person-rem (total body).
    • First pass dose = 31 person-rem whole body risk equivalent.

tFirst pass organ dor,e 4.4 organ-rem (gonads).

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4 about 472,000 people will die from cancer in the United States in 1988

[18].

This cancer mortality may be compared with the calculated cumula-tive cancer mortality of 0.06 which is attributed to C-14 over the next l

250,000 years.

From this, the cumulative impact cf C-14 over this period is found to be about IE-5 percent of the normal incidence for a single year.

Based on this, the staff concludes that impacts from the LWR fuel j

cycles are not significant, even when compared to a single year's normal incidence.

It can be seen from Table 9 that the dose commitments from I-129 continue to increase with time, even beyond 250,000 years.

There are

. about 0.01 additional cumulative cancer deaths per RRY from exposure of the assumed total U.S. population for this period.

Since the model does not incorporate any removal mechaaism other than radioactive decay, the calculations of health effects could theoretically be extended to 200 million years or more to integrate the entire dose.

This has not been done, because the results would be meaningless and could be misleading due to the lack of accuracy.

The prediction of the radioactivity is fairly accurate.

But the predictions of radionuclide environmental transfer and population distribution, which are required to determine health effects, could vary over many orders of magnitude.

Discuss Tc-99 & Rn-222 data in Tables 11 and 12 (To be aaded by Oak Ridge National Laboratory under contract now in progress.)

3.

World Population Exposure The radionuclides from the fuel cycle that have the potential for exposing world populations are carbon (C-14), tritium (H-3), 1-129, and Kr-85.

Mathematical models have been published for estimating the 05/26/88 112

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1 long-term population doses from C-14 and I-129.

The world population collective effective dose equivalent (EDC) from these radionuclides are presented in Table 10.

The time period considered was 250,000 years.

The calculations for H-3 and Kr-85 assumed instantaneous mixing of the radionuclides with the global water pool and the atmosphere respectively.

The removal mechanism was assumed to by radioactive decay only.

Carbon-14 and I-129 were modeled as described earlier.

Radon-222 and Tc-99 were eliminated from consideration, be:ause no mechanism for global distribu-tion could be visualized.

The data in Table 10 illustrate the contribution made by each radionuclide to the global collective effective dose equivalent.

It can be seen that C-14 and I-129 produce over 95% of the total dose over the 250,000 years.

The contributions from H-3 and Kr-85 are small, despite the large curie quantities involved, because of their relatively short radioactive half-lives.

More than 99% of the collective dose from these two radionuclides is delivered in the first 100 years.

The total addi-tional cumulative cancer mortalities per RRY is about 1.7 for a 250,000-i year exposure to the estimated world population, j

i 4.

The Significance of Long-Term Dose As previously shown, the staff made theoretical calculations of the collective effective dose equivalent (E00) and health effects from C-14, Rn-222, Tc-99, H-3, Kr-85, and I-129 for time periods of up to 250,000 years.

These calculations utilize a series of assumptions based increas-ingly upon conjecture, with little factual foundation, as time periods increase. They have been made in a very conservative manner in order to present an upper bound to the estimated health and safety impacts.

One 05/26/88 113

[7590-01) can postulate a population at risk, changes in we'ther patterns and climate, changes in fossil fuel supplies, and other natural phenomena over the next 100 years or longer.

These postulations would us'e current knowledge as a basis.

The reliability and accuracy of these predictions will vary, in some cases drattically, as the time period varies.

Further, changes in any cf these factors would have a significant effect upon postulated conditions and, thus, affect the validity of calculated doses and related health effects.

There is even greater potential for changes that could occur over longer periods of time, for instance variations in climate, continental drift, massive erosion.

As previously discussed, one comparison of potential health effects from the LWR fuel cycles is to that from background radiation.

The collective exposure of the assumed United States and world populations to natural background radiation over the next 250,000 years has been esti-mated to be approximately 3E+12 and 1E+14 person-rem, respectively.

The collective U.S. population doses attributed to Rn-22, C-14, and I-129 over the same period of time are about 500 person-rem.

The total col-1ective effective dose equivalent (EDC) to the world population from C-14 and I-129 is approximately 12,000 person-rem for the 250,000 years.

This indicates that the total collective effective dose equivalent (EDC) from long-lived radionuclides is about IE-8 percent of the natural back-ground exposure to the world population.

For any given year of reactor operation, the benefits are experienced during that year only.

However, the same is true of the benefits from any other method of generating electricity.

The potential impacts resulting from that year of reactor operation must be considered over thousands of 05/26/88 114

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years, if NEPA requirements are to be fully evaluated.

Competing tech-nologies could therefore appear to be advantageous, since many of the impacts will apparently be experienced during the same time period as the benefits.

The rationale for this argument is questionable for rieveral reasons.

The currently available practical alternatives to nuclear derived electric p wer involve the burning of fossil fuels.

One obvious severe impact from the use of fossil fuel is the elimination of valuable, limited, and nonrenewable natural resources, which will deprive future generations of their use.

Burning fossil fuel contributes to the green-house effect, due to the release of carbon dioxide.

Pelease of carbon dioxide in large quantities could affect future generations by changing the world climate.

These effects have been evaluated more thoroughly in recent years, but predicted effects vary over a large range and work is continuing.

Another impact from use of fossil fuels, especially use of coal with large sulphur content, is the potential effects of acid rain.

The initiation and distribution of acid rain is not yet well understood, but long-term effects are already being observed.

Shortages of natural resources that provide a source of energy could lead to national and global disruptions, which would certainly affect future generations.

The use of coal and oil as fuel reduces the finite available supply of these materials that could otherwise be used as feedstocks for many valuable commodities such as plastics, textile fibers, and many chemical compounds.

5.

Conclusions The Commission has sponsored many research projects and studies to establish reasonable values, for Table S-3, has conducted hearings and rulemaking proceedings, and has been involved in extensive litigation 05/26/88 115

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regarding Table S-3.

Thus, the source terms, derivations, and evclua-tions of the potential environmental and radiation impacts have been extensively ventilated, both by the NRC staff and by the public.

As a result of these discussions, many of the original values have been revised over the years. The U.S. Suprome Court has reviewed two cases involving Table S-3 rulemaking and has upheld Commission procedures both times.

Because the impact values shown in Table S-3 are qualitatively different it is not possible to simply add all of these values together to get a total environmental impact.

For instance, land uses and water uses have environmental or socioeconomic effects, while chemical and radiation releases have health and safety effects.

The assigned values are empirical to the extent that the calculated values would be different under different sets of assumed operating and environmental conditions.

Sensitivity analyses such as those presented in AIF/NESP-032 [19] show that the values in Table S-3 are not underestimated.

It is possible that the summation of a number of small impacts could produce a significant total effect.

The staff has investigated this possi-bility and compared each impact of the LWR fuel cycles and their summa-tion to the corresponding impacts from a model nuclear and coal fired power plant.

It is estimated that the impacts of the fuel cycles range from less than 1% to almost 30% of the impacts attributable to the model nuclear reactor or to the model coal fired power plant.

The staff con-cludes that adding the environmental impacts of the uranium fuel cycles to the impacts of the nuclear reactor will not significantly increase the total impacts and are probably less than the impacts from a similar capacity coal-fired plant.

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The discussions in the previous sections have pointed out many places where, in developing the values in Table S-3, the staff has carefully avoided underestimating the source terms.

Models used for calculating doses from which health effects are derived have also been constructed to avoid dose underestimation.

The lack of factual evidence on which to base estimates of short-term dose calculations and the resulting diffi-culty of long-term dose predictions have been discussed.

All of these considerations lead the Commissioa to conclude that the impact values in Table S-3 are reasonable, and certainly are not underestimated.

Based on all of the above information, especially that discussed in section III.C, the records of this and other rulemaking proceedings, and the discussed court decisions, the Commission finos that the valuas shown in Table S-3, if used in the manner prescribed in its regulations, comply with the requirements of the Atomic Energy Act of 1954, as amended, including NEPA requirements.

The Commission further finds that the environmental impacts of the LWR uranium fuel cycles are not significant, 1

either in relation to impacts from the model nuclear power reactor or to practical alternative electric power sources, and shhl1 not be considered in NEPA analyses for individual nuclear power reactor license proceedings.

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SECTION III - REFERENCES 1.

Docket No. RM-50-5, Generic Environmental Statement on Mixed Oxide Fuel (GESMO).

Hearing transcripts for January 19, 25, and 26, 1977.

2.

NUREG-0002, Chapter IV-J.

3.

Advisory Committee on the Biological Effo.ts of Ionizing Radiations (BEIR IV), "The Effs.ts on Populations of Exposure to Low Levels of Ionizing Radiation," National Academy of Sciences / National Research Council, February 1988.

4.

Advisory Committee on the Biological Effects of Ionizing Radiations (BEIR III), "The Effects on Populations of Exposure to Low Levels of Ionizing f:adiation," Nationil Academy of Sciences / National Research Council, July 1980.

5.

l International Commission on Radiological Protection, ICRP, R com-f mendations of the International Commission on Radiological Protec-I

{

tion," ICRP Publication 26, January 1977.

l 6.

National Council on Radiation Protection and Measurements, NCRP, "Review of the Current State of Radiation Protection Philosophy,"

l PCRP Report No. 43, January 1975.

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7.

National Council on Radiatien Protection and Measurements, NCRP, "Influence of Dose and Its Distribution in Time on Dose-Respnse Relationships for Low-LET Radiations," NCRP Report No. 64, April 1980.

S.

United Natior.s Scientific Committee on the Effects of Atomic Radia-tion, UNSCEAR, "Ionizing Radiation:

Sources and Biological Effects,"

1982.

9.

Ibid., Chapter IV-J, Appendix B, page IV-J (B)-1.

10.

NUREG-0116, page 4-94 ff.

11.

NUREG-0216, Appendix H, page H-16 ff.

12.

Ibid.

l 13.

NUREG-0116, Tables 4-23 and 4.24 (the hearing record established that these tables overstated potential dose by a factor of about 10,000).

1 14.

Oak Ridge National Laboratory, "Siting of Fuel Reprocessing Plants 4

l and Waste Management Facilities," ORNL-4451, July 1970.

15

Norwine, J., "A Question of Climate:

Hot or Cold?," Environment, 19, #8, p. 7, Nov.1977, Mitchell, J.M., Jr., "Carbon Dioxide and 05/26/88 119 l

_. - -