ML20207F017
| ML20207F017 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 08/05/1988 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TAC-07441, TAC-7441, NUDOCS 8808180200 | |
| Download: ML20207F017 (12) | |
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David W. Cockfield Vice President, Nuclear August 5, 1988 Trojan Nuclear Plant Dockot 50-344 License NPF-1 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
Dear Sir:
Addendum to Licenso Chanto Application 165 (TAC No. 07441)
Refe.ence:
Letter to NRC Document Control Desk from D. W. Cockfield, PCE "License Chango Application (LCA) 165, Fuel Enrichment Specification" dated March 1, 1988 LCA 165, Fuel Enrichment Specification, was submitted by the referenced lotter. As recycsted. Portland General Electric (PGE) has reviewed the environmental considerations associated with an incroaco in nuclear fuel enrichment. The results of this review of the Trojan Environmental Report and the Final Environmental Statement are provided in Attachment 1.
It is concluded that changing the fuel enrichment specification and increasing the allowablo fuel burnup li' nit as proposed in LCA 165, has no effect on the conclusions of the Trojan Environmental Report, nor thoso of the Final Environmental Statement. is a replacement Figure 3 (Pago 10 of 10) for the attachment to LCA 165.
One data point was inadvertently ornitted from the figure that accompanied the original submittal. This replacement figure was provided to the Project Manager for Trojan in March 1988.
If you have further questions, please contact A. R. Ankrum at (503) 226-8126.
Sincerely, Attachments for$b o
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Mr. John B. Martin
$og, Regional Administrator, Region V g
U.S. Nuclear Regulatory Commission Od Mr. Bill Dixon gg' State of Oregon 0)q Der,rtment of Energy f
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0 gg Mr. R. C. Barr C)Q. Q.
NRC Resident Inspector I
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Trojen Nuclear Plant Document Control Derk Dockst 50-344 Argust 5, 1988 License NPF-1 Pago 1 of 10 ADDENDUM TO LICENSE CHANGE APPLICATION 165 ENVIRONMENTAL EVALUATION SUKMARY Introduction In License Chango Application (LCA) 165(1), Portland General Electric Company (PCE) stated that deleting the fuel enrichment limit and increas-ing tho allowable onrichment for the new fuel storage racks to 4.5 weight percent from 3.5 weight percent does not involvo an unreviewed environ-mental question.
This addendum to LCA 165 provides additional support for that conclusion.
Evaluation of the environmental aspects of an increase in fuel enrichment includes review of the changos associated with the increased enrichment and review of documents that describe the environmental impact of the Trojan Nuclear Plant. Higher enrichment fuel supports higher fuel burnup, thus higher fuel burnup concerns are an integral part of this evaluation.
In addition to the summary description of the environmental impact described in the Trojan Environmental Report (2) and the Final Environmental Statement (FES)(3), this review providos discussion of generic assessments, including a recent assessment of the use of extended burnup fuel (4).
The outline of this review identifies the applicablo sections of regu-lations for the environmental aspects of LCA 165.
The requirements of the applicable sections are described and the rolovant category of environmental evaluation is identified.
Requirements in Appendix B of the Trojan Nuclear Plant operating license specify the need to determino if an unroviewed environmental question exists.
This determination is based on the offects of the change on the Trojan Environmental Report and the Final Environmental Statement.
Finally, the impact of increased enrichment is summarized in a conclusion based on the applicable environmental review requirements.
Regulations Related to Environmental Impact of Increased Puel Enrichment The regulations that apply to environmental concerns are included in Title 10, Code of Federal Regulations Part 51 (10 CFR 51), "Environ-mental Protection Regulations for Domectic Licensing and Related Regulatory Functions".
The eppropriate sections are discussed individually below:
Section 51.12 - Application of Sub-Part to Ongoing Environmental Work.
This cection indicates that updatos to existing environmental reports need not be filed with the NRC as a result of the modifications to Part 51 that were promulgated on March 12, 1984. This does not apply
Trojan Nuclear Plant Document Control Desk Docket 50-344 August 5, 1988 License NPF-1 Page 2 of 10 to ongoing environmental work performed by the NRC subsequent to that date. This section is applicable to Trojan in that no changes to existing documents are needed, unless it is detor...ined by the NRC that the change in LCA 165 involves a need for revision to the Trojan Environmental Roport.
Section 51.14 - Definitions.
The definition of interest in this part is the "categorical exclu-sion", which is defined as "a category of actions which do not individually or cumulatively have a significant effect on the human environment and which the Commission has found to have no such offect in accordance with the procedures set out in Section 51.22, and for which, thereforo, neither an environmental assessment, nor an environmental impact statement is required".
Section 51.20 - Critoria For, and Identification of, Licensing and Regulatory Actions Requiring Environmental Impact Statements.
This section identifies 13 different items which require an environ-mental impact statement.
Primarily, these items are major actiona such as licensing a nuclear power plant or issuing renewals for large facilities. The change to fuel enrichment does not fall into any of these categories, with the exception of Item 13.
Item 13 requires an environmental impact statement for "any other action which the Com-mission determines is a major commission action which significantly affects the quality of the human environment".
It further states that as provided in Section 51.22(b), the Commission, in special circumstances, may prepare an environmental impact statement on an action covered by a categorical exclusion.
This section does not require an environmental impact statement for LCA 165, but reserves the right of the Commission to requiro one.
Section 51.21 - Critorion for and Identification of Licensing and Regulatory Actions Requiring Environmental Assessments.
This section states that "all licensing and regulatory actions sub-joct to this sub-part require an environmental ascessment except those identified in Section 51.20(b), as requiring an environmental 1
impact statement and those identified in Section 51.22(c) as cate-gorical exclusions".
As discussed below, the fuel enrichment change is covered by a categorical exclusion.
It is recognized that t.he Commission may, in special circumstances, prepare an environmental assessment on an action covered by a categorical exclusion.
Trojen Nuclear Plent Document Control D2sk Dockst 50-344 August 5, 1988 Licenso NPF-1 Pago 3 of 10 Section 51.22 - Critorion For, and Identification of, Licensing and Regulatory Actions Eligible for Categorical Exclusion.
This item states that the actions oligible for categorical a.
exclusion shall moet the criterion of an action which tha Com-mission, by rule or regulation, has declared to be a categorical exclusion after first finding that the category of actions does not individually or cumulatively have a significant effect on the human environment.
b.
Except in special circumstances as determined by the Commission upon its own initiative or upon request of any interested person, an environmental assessment or an environment impact statement is not required for any action within a category of actions includod on the list of categorical exclusions set up in Paragraph 3 below.
The following categorios of actions are categorical exclusions:
c.
The section lists 18 different categorical exclusions; of these, tho exclusion that appears applicable to the change in fuel enrichment for the Trojan Nuclear Plant is Item 9.
Item 9 states, "Issuance of an amendment to a permit or license for a reactor pursuant to Part' 50 of this chapter (10 CFR 50) which changes a requirement with respect to installation or use rf a facility component located within the restricted area, as defined in 10 CFR Part 20 of this chaptor, or which changes an inspection or surveillanco requiremont, provided that:
(i) tho amendment involved no significant hazards consideration, (ii) there is no significant chango in the types or significant increase in tho amounts of any offluents that may be released offsito, and (iii) there is no significant increase in individual or cumu-lativo occupational radiation exposure".
The chango in fuel enrichment is applicable to this section because:
1.
The fuel is a facility component located within a restricted area of the Plant, because it is special nuclear material.
The fuel is in a shipping container whenover it is outside the rostricted area.
2.
The three provisions of this section are mot by this change as follows:
(1) A "no significant hazards" consideration was provided in the original submittal of LCA 165; (2) As iden-tified in Reference 4 there is no significant change to the types or significant increase in the amount of any offluent that may be released offsito, as described in Reference 4.
This is based on maintaining the same fuel reliability which has been borno out by past experience, and by maintaining Reactor Coolant System radionuclido concentrations within
Trojen Nuclear Plcnt Documsnt Control Dzsk Dockst 50-344 August 5, 1988 Licenso NPF-1 Pago 4 of 10 existing Technical Specification limits; and (3) There is no significant increaso in tho individual or cumulative occu-pational radiation exposure, primarily because of the reduced fuel handling requirements. These items are discussed more completely in Referenco 4.
Section 51.25 - Determination to Prepare' Environmental Impact Statement or Environmental Assessment; Eligibility for Categorical Exclusion.
This section directs the appropriate NRC staff director to determine the category of environmental report needed.
It is not the licen-see's responsibility to carry out this section. The information provided herein supports the conclusion that a categorical exclusion applies to LCA 165.
Section 51.41 - Requirement to Submit Environmental Information.
This section specifically allows the Commission to request submittal of environmental information if desired.
Section 51.51 - Uranium Fuel Cycle Environmental Data - Table S-3.
This section is not applicable, because the construction permit date of the Trojan Nuclear Plant is prior to tho date specified in the regulation; thas, tha information was not required as part of Trojan's environmental report. Nonetheless, the effect of increased enrichment and burnup beyond the values of 4.0 weight percent and 33 Cigawatt Days por Motric Tonno Uranium (Gwd/MtU) reported in the S-3 Table have been evaluated. As concluded by the NRC staff (5)
"the NRC staff concludes that the environmental impact is summarized in Table S-3 of 10 CFR 51.51 and in Table S-4 of 10 CFR 51.52 for a burnup level of 33 Cwd/MtU are conservative and bound the corres-ponding impacts for burnup levels up to 60 Cwd/MtU and Uranium-235 enrichments up to five percent by weight". Thus, it is concluded that the S-3 Table bounds the impact of an enrichment increase to 4.5 weight percent at the Trojan Nuclear Plant.
Section 51.52 - Environmental Effects of Transportation uf Fuel and Waste - Table S-4.
This section is not applicable to Trojan because Trojan's environ-mental report was complated before the date required in this sec-tion. As was concluded above in Section 51.51, the environmental impact of the change in LCA 165 is bounded by the environmental impact described in the S-4 Table.
Section 51.53 - Supplement to an Environmental Report.
Part (a) of this section discusses when a supplement to an environ-mental report is required at the operating license stage.
It states, f
Trojan Nuclear Plant Document Control Desk Docket 50-344 August 5, 1988 Licenso NPF-1 Pago 5 of 10 "Unioss the applicant requests the renewal of an operating license or unless otherwise required by the Commission, tho applicant for an operating licenso for a nuclear power reactor shall submit this report only in connection with tne first licensing action autuorizing full power operation".
Because of this, no further report is required unless specifically requested by the Commission.
Section 51.95 - Supplocent to Final Environmental Impact Statement.
Paragraph (a) of this section states that a new final environmental impact statement is not nooded after the original final environmental impact statomont has been submitted, unless otherwise determined by the Commission. Thus, this section does not require submittal of a new final environmental impact statement.
Summary - Review of 10 CFR Part 51 The sections of 10 CFR Part 51 have been reviewed to determino which apply to LCA 165 concerning increased fuel enrichment for the Trojan Nuclear Plant. This change is covered by the categorical exclusion in Section 51.22, Item (c)(9). Unless otherwiso required by the Commission, no changes or supplomonts to the existing documents are needed.
Trojan Requirement for Environmental Evaluation
)
Environmental review requirements are outlined in Appendix B to the Trojan Operating License, "Environmental Protection Plan - (Non-Radio-logical) Technical Specifications".
Section 3.1 of that document describes the critoria for determining whether prior NRC approval is j
needed for a change affecting the environment.
Prior approval is required when "a proposed change, test, or experiment is deemed to involvo an unroviewed environmental question if it concerns (1) a matter t
which may result in a significant increase in any adverso environmental impact previously evaluated in the final environmental statement (FES),
as modified by staff's testimony to the Atomic Safety and Licensing Board, supplements to the FES, environmental impact appraisals, or in any decisions of the Atomic Safety and Licensing Board; (2) a significant change in the types or a significant increase in the amounts of effluents or licensed power level (in accordance with 10 CFR 51.5(b)] (sic); or
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(3) a matter not previously reviewed and evaluated in the documents specified in (1) of this subsection which may have significant adverso 1
environmental impact".
Fundamental to the environmental evaluation is a definition of the word "significant".
For this evaluation, "significant" is defined by whether the conclusions of the relevant environmental documonts would need to be changed. A second fundamental consideration is that the Appendix B requirements for non-radiological concerms for fuel of higher enrichment are coupled with higher fuel burnup.
The non-radiological effects of fuel usago at Trojan are related to the land and resource requirements j
Trojan Nuclear Plant Document Control Desk Docket 50-344 August 5, 1988 License NPF-1 Page 6 of 10 for uranium mining, milling, and conversion, and the potential effects on heat loads from operation of the Plant.
Increased fuel enrichment and burnup are not significant changes from an environmental standpoint, because the operations associated with mining, milling, and conversion are reduced by about 5 percent (Reference 4).
This change is in the beneficial direction and tho amount of change is small.
The other non-radiological concern is that regarding heat removal requirements.
However, since the primary source of decay heat is from short-lived fission products and the rato of production of fission products is the same, there are no significant changes in this area.
The existing heat-discharge limits will be retained. Thus, it is concluded that the non-radiological consequences of an increase in fuel enrichment are not significant.
Other Related Documents for Environmental Review.
The Trojan Environmental Report and Final Environmental Statement (References 2 and 3) were reviewed primarily for radiological concerns.
These items are discussed below following the format of the reports.
Trojan Ensaronmental Report The Trojan environmental report deals with the assessment of operation, construction, and other activities associated with the Trojan site.
These include human activities, hydrology, geology, meteorology, and effects on biology and other features of the area. The significant areas which may be affected by an increase in fuel enrichment are in Section 3 describing the Plant; in Section 5 describing the effects of normal Plant operation; and in Section 6 describing the environmental effects of accidents.
In addition, the affected sections include Section 7 on unavoidable adverse effects of Plant construction and operation, Section 9 on long-term effects of Plant construction and operation, and Section 10 on resources committed in Plant construction and operation.
Those sections are discussed below.
Section 3 describes the Plant and associated equipment needed to generate electricity.
The description is relatively general and does not specif-ically describe the fuel design or assumed fuel burnup. The offect of higher burnup fuel is relevant in the description of the requirements for the radioactive waste systems described in Section 3.6 and the heat dis-sipation systems described in Section 3.5.
As was discussed earlier, the heat rate from higher burnup fuoi is only moderately affected by increased enrichment /burnup, thus no changes to this section need be mado.
Seccion 3.6 describes a number of parameters related to the con-centration of fission products in the Reactor Coolant System and other Plant systems.
The basis for this data states that the reactor coolant activity was based on 0.2 porcent fuel rod defects. This level of fuel defects was based on Plant operating experience at that timo. As is described in Reference 4, the fuel defect rate is not expected to increase due to high enrichment.
However, the release rates of certain A
Trojan Nuclear Plant Document Control Desk Docket 50-344 August 5, 1988 Licenso NPF-1 Pago 7 of 10 fission products are expected to be somewhat greater.
Thus, there is a modest increase in the potential radiological consequences associated with higher burnup fuel.
However, the fuel failuro rate is expoeted to remain within the 0.2 percent limit.
Note that the level of fuel defects assumed in the Final Safety Analysis Report (FSAR) is 1 percent; the 0.2 percent number is not used in any analysis for the accident conse-quences of radiological releases because the Plant accident analysis for radiological releases is based on worst-case conditions. Thus, the effect of high enrichment fuel will be bounded by the results reported in the FSAR. The environmental report concluded that the results with 0.2 porcent fuel defects are acceptable; the presence of FSAR analysos that conclude acceptable results with I porcent fuel defects provides further confirmation of the environmental report conclusions.
Section 5 on the environmental offects of Plant eperation was also based on a fuel failuro rate of 0.2 percent.
No mention is made of the fuel burnup or enrichment, and the radionuclide concentration is predicted for a variety cf substancos.
Based on the effects of higher enrichment and burnup noted in Referenco 4, significant change in theso values is not anticipated.
Section 6 on environmental effects of accidents describes a variety of accidents which are categorized as Class 1 through 9, depending on the severity and location of the radiclogical release. This system has since been outmoded and is not used in tae FSAR.
However, as a baselino for these evaluations, the environmental report assumed the samo 0.2 percent equivalent fuel defect level, based on Plant operating experience.
In addition, the amount of release due to a dropped fuel assembly (Class 6 and 7 accidents) assumed one row of rods was damaged in ono fuel assembly.
These assumptions are not consistent with the FSAR analysis, which assumes a full assembly of damaged rods for the dropped assembly acci-dents, and assumos 1 percent fuel defects for other events. The FSAR analysis shows acceptable results with a higher level of fuel failure, which bound the results of the environmental report.
Since the FSAR is acceptable and bounds both the environmental report and higher burnup fuel ef fects; the results that would occur from higher burnup rema3n acceptabic.
Section 7 discusses unavoidable adverso effects of Plant operation.
Effects related to fuel enrichment are not discussed.
Section 9, describing long-term offects at the Plant, is primarily con-corned with decommissioning and removal of spent fuel. The enrichment specification change does not affect the statements in this section.
Section 10 describes the resources committed in Plant construction and operation an6 identifies the average annual consumption of uranium as about 28.1 metric tons. It states that the spent fuel will be reprocessed and the uranium and plutonium recovered for reuse. These statements have been overcomo by events.
It should be pointed out that the increased
Trojan Nucioar Plant Dccument Control Desk Docket 50-344 August 5, 1988 Licenso NpF-1 page 8 of 10 utilization of high enrichment fuel will permit a reduced uranium con-sumption compared to lower enrichment fuel on a once-through fuel cycle.
Thus, there is a modest benefit in the area of resources committed for Plant operation.
Final Environmental Statement. Effects of Plant Operation The final environmental statement was prepared by the NRC to discuss the effects of operation of the Trojan Nuclear plant. The notable differ-ences betwoon this document and the Trojan environmental report are that the radiological source term was based on 0.25 percent failed fuoi rods.
The general areas described include the same areas as the environmental report, including the effects of Plant construction, operation, and the use of resources.
It should be noted that the different amount of failed fuel is not described, and that the calculated annual release of radio-active material does not correspond to those values reported in the Trojan environmental report.
The basis for these changes are not fully describod, and it is not clear on what basis this change was mado.
Nono-tholess, these effects are bounded by the FSAR reported data, and the results of high enrichment and high burnup fuci remain bounded by the current analysis. An additional area described in the final environ-mental statement concerns transportation of new fuel to the reactor and spent fuel from the reactor.
In this area, the effect of highor enrich-ment fuel is to cause a reduced number of fuel transportation shipments with a slightly increased risk in each shipment.
Tne effect of trans-portation, as described in Reference 4, is a modest increase in the overall risk. Note that the shipment of now fuoi involves a very low risk, and there will be a not reduction in risk due to the use of fewer fuel assemblics.
It is difficult to ascertain the risks associated with transportation of spent fuel.
Since there have been long delays associated with a spent nuclear fuel repository, the risks associated with the transfer of spent fuel will be much lower than have been predicted, owing to the longer decay time at each reactor site before these fuel assemblies are shipped.
Use of fewer assemblies with higher burnup will extend the time before shipments are needed.
Reference 4 predicts decreased effects from trans-portation of spent high enrichment fuel. However, in Reference 4, the results of a transportation accident described show increased effects with higher burnup fuel. Overall, the effect of transportation of higher enrichment fuel is not significant(5)
The effects of accidents described in the final environmental statement are summarized in Table VI-2.
As previously noted, these are based on 0.25 percent fuel failures (except for loss of coolant accidents). The values are low and consistently less than that allowed by 10 CFR 20.
Thus, margin is available to account for increased environmental effects.
The increased onrichment and burnup do not contribute to significant adverso environmental effects and are acceptable,
Trojan Nucioar Plant Document Control Desk Dockot 50-344 August 5, 1988 Licenso NPF-1 Page 9 of 10 Conclusion The use of higher enrichment fusi is enmeshed with higher burnup.
Extended fuel burnup programs were initiated in the mid-1970s by all major reactor vendors and the U.S. government (through what is now tho Departmont of Energy), with the intent of enhancing fuel rollability and economy.
These goals woro mot, as concluded in the abstract for Refer-ence 4 describing the effects of an increaso in burnup from 33 Cwd/MtU to 60 Cwd/Mtu.
It is recognized that these conclusions are applicable to Trojan, and that the changes associated with LCA 165 do not adverso'y affect the environment.
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Page 10 of 10 REFERENCES 1.
Letter to USNRC from D. W. Cockfield, PGE, "License Change Appli-l cation 165", dated March 1, 1988.
2.
Trojan Nuclear Plant Environmental Report, PGE, through Amendment 1, dated November 22, 1971.
3.
Final Environmental Statement Related to Operation of Trojan Nuclear Plant UC Atomic Energy Commission, dated August 1973.
4.
NUREG/CR 5009, "Assessment of the Use of Extended Burnup Fuel in Light Water Power Reactors", Prepared by D. A. Baker, et al, Pacific Northwnst Laboratory for the USNRC, Published February 1988.
5.
Federal Register Volume 53 No. 39, Monday, February 29, 1988, Pago 6040, "Extended Burnup Fuel Use in Commercial LWRs; Environ-mental Assessment and Finding of No Significant Impact."
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