ML20211D218

Notation Vote Approving with Comments SECY-99-202, Changes to Requirements for Environmental Review for Renewal of Nuclear Power Plant Operating Licenses (10CFR51), Final Rule

ML20211D218
Person / Time
Issue date:	08/20/1999
From:	Mcgaffigan E NRC COMMISSION (OCM)
To:	Vietticook A NRC OFFICE OF THE SECRETARY (SECY)
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ML20211D168	List: ML20211D165 ML20211D194 ML20211D213 ML20211D218 ML20211D225
References
SECY-99-202-C, NUDOCS 9908260198
Download: ML20211D218 (36)

Text

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A F F I R M A T I O N VOTE RESPONSE SHEET TO: Annette Vietti-Cook, Secretary FROM: COMMISSIONER MCGAFFIGAN

SUBJECT:

SECY-99-202 - FINAL RULE " CHANGES TO REQUIREMENTS FOR ENVIRONMENTAL REVIEW FOR RENEWAL OF NUCLEAR POWER PLANT OPERATING LICENSES (10 CFR PART 51)"

Approved Disapproved Abstain Not Participating COMMENTS:

See attached comments and edits.

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CommisalonerMcGaMFgan's Comments on SECY-99 202 I approve publicabon of the final rule amending 10 CFR Part 51 environmental protection requwements for nuclear power plant license renewal and the release of NUREG-1437, Volume 1, Addendum 1 subject to the following comments and edits.

The following text should be inserted at the bottom of page 41 of the Federal Rensster notice

, (FRN) and at the bottom of page 50 of the Addendum (it should appear as the last paragraph to the response on the sabotage comment):

, "On June 22,1999, the Nevada Attomey General filed a petition with the Commission which requested the NRC to amend regulations goveming safeguards for shipments of -

spent nuclear fuel against sabotage and terronom and to initiate a comprehensive assessment. In particular, the petition indicated that NRC should factor into its regulations the changing nature of threats posed by domestic terronsts, the increased -

availability of advanced weaponry and the greater vulnerability of larger shipping casks traveling across the country. If, as a result of reviewing this pohtion, the NRC reaches conclusions that are inconsistent with the results or assumptions in the present rulemaking, the Commission will nood to revisit the analysis presented here."

The <6am===1 in the first full paragraph on page 26 of the Addendum regsrding the '5-year cooling per!od" for spent fuel should be enhanced to point out that 5 years is an extremely conservative estimate. For example, there is c!most 40,000 tons of spent fuel in storage now, some of which has been in storage for decades. At the earliest, if Yuccc Mour'.ain were found suitable and if DOE were successful in obtaining an NRC license, it will be at least 11 years from now until Yucca Mountain would be ready to accept spent fuel for storage. It would take many years to work off the backlog of stored spent fuel much less the spent fuel that will be generated in the intervening years.

Additional suggested edits to the FRNs, Addendum, and the draft press release are indicated on the attached pages I also concur with Commissioner Memfield's suggested edits to the Congressional letters. Where I have suggested edits to either the FRN or Addendum, the staff should ensure that conforming changes are made to ensure consistency between the documents, particularly the " comment and response" sections.

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.a the Addendum.. The State of Utah also submitted exteneve comments 3mit focused on concoms with the scope and thoroughness of the supporting analyse in Addendum 1, includog the lack of conadoration of the proposed Private Fuel Storage Facility at Skull Valley, Utah.

Industry comments focused on clarifications in the rule language.

The written comments have been summarized and grouped into issue categones. As a result of the NRC staff's review of all written comments, some modifications and clarificatons have been incorporated into Addendum 1-notably, the use of more conservative assumptions '

in the analyses and a fuller + *- ":s of those analyses. In addition, the rule language has ,

been edited for clarification. The NRC staff has also prepared responses, given below, to the leeues raised by the commentors.

Issue 1-Public Notice Comment: The titles of the notices pubhohed in the Federal,7+f::::were inaccurate and misleading h= they do not clearly indicate the subject matter of the proposed rule and Addendum 1 that addresses transportation of spent nuclear fuel.

g; W mWt.'s itREddoe(", O tto phL itt#koAeQaM P:- ---e:,The NRC that the titles property reflect the regulatory action being y taken. As required by NRC tions,8 a notice of the proposed rule and a Notice of Avallebility of Addendum 1 published in the FederaIRegefer(64 FR 9884 and 64 FR 9889, February 26,1999).j titles define the subject matter of the regulation to be affected; the title of the proposed rule is " Changes to Requirements for Environmental Review for Renewal of Nuclear Power Plant Operating Licenses." The title of the Notice of Availability is 8

10 CFR 2.804,." Notice of proposed rulemaking" and 10 CFR 51.117, ' Draft environmentalimpact statement-notice of availability." j 11 i

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" Changes to Requirements for Environmental Review for Renewal of Nuclear Power Plant Operating Licenses, Availability of Supplemental Environmentalimpact Statement." Addendum 1 supplements specific sections of NUREG-1437, Genenc Environmental /mpact Statement for 1

Licenne Renewal of Nuclear Piants (May 1996). This limited function is indicated by the title of )

Addendum 1,' Genenc Environmentalimpact Statement for License Renewal of Nuclear Plants:

I A4ain Report Section 6.3-Transportation,' Table 9.1 ' Summary of findngs on NEPA Jesues for hcenne nonewal of nucioar powerpiants,' Draft Report for Comment.

The rule change and the supporting Addendum 1 affect only the plant-specific environmental analysis required to be submitted in the Environmental Report of an applicant for the renewal of a nuclear power plant operating license and the plant-specific supplemental ermronmental impact statement prepared by the NRC. Even though the analysis in Addendum 1 focuses on spent-fuel shipments converging on the proposed reposstory at Yucca' Mountain, Nevada, that analysis and the resulting rule affect only the review requirements for renewal of an individual nuclear power plant operating license. It is not intended that Addendum 1 or the revised rule support any other regulatory decison by the NRC.

N Y W lasue fe--Communications Comment NRC failed to consult with Nevada State agencies, Nevada local ocwornments, and with Nevada irdan Tribes. .

Response: As discussed above, a rariety of organizations and govemment agencias  ;

aubmitted substantive comments in response to the proposed rule. The NRC has considered 12

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a these comments and, in many cases, altered its analyms as a result of this input. Prior to issuance of the proposed rule for comment, however, the NRC did not seek any pre-publication input from Nevada state agencies, Nevada local Govemments, and Nevada' indian Tribes for the following reasons. First, the rule involves a narrow aspect of the environmental review of individual nuclear power plant license renewal decisions, which is a regulatory decision 00ii-;'2:/ separate from the regulatory requirements that will guide the NRC licensing review of a HLW repository and from the decision process leading to a DOE site recommendation on Yucca Mountain, Nevada, the site DOE currently has under sturiy. This rule amends the December 18,1996, rule with roepect to two questions not adequately answered:

1. Are the current environrnental impact values in Table S-4, based on several destinations, still reasonable to incorporate in a license renewal review that assumes a single destinatio1 for spent fuel at Yucca Mountain, Nevada?

2. Are the current environmental impact values in Table S-4 (which are based on fuel enriched to no greater than 4 percent, the average level of irradiation of spent fuel no't exceeding 33,000 mwd /MTU, and shipment no less than 90 days after discharge from

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the reactor) still reasonable to incorporate in a license renewal review of plants that may use fuel enriched up to 5 percent and potentially ship spent fuel with a bumup of up to 62,000 mwd /MTU?

The amendment has no direct regulatory impact on any entity within Nevada. The

% of Yucca Mountain for the generic evaluation of transportation impacts was made because that site is currently the only one under consideration for a high-level-waste (HLW)

. I repository. Before HLW is actually transported to Yucca Mountain, Nevada, the State, local Govemments, Indian Tribes, and the public :" : itse opportunity to on site- X l i

(ouibe. 6y 13

hc4wweab}m N specific transportation impacts DOE draft EIS for atthe Yucca ,

t Mountain sityda au We med14ne_ h a 1Bo dq )%+4- pu ed. %;$ o Au sT G, 6% ' Ch+ t * # w we yee . gov .

Aieo the for and scope of the current rule amendment were identified within the context of a preceding nJiemaking that specified the plant-specihc content of the environmental review of applications for the renewal of individual nuclear power pisnt operating licenses. The prewous final rule was published in the Fociera/ Registerfirst on June 5,1996 (61 FR 28467),

and again with minor modifications on December 18,1996 (61 FR 66537). The Commission stated in the December Federal Registernotice, "as part of its efforts to develop regulatory I

guidance for this rule, the Commission will consider whether furiher changes to the rule are desirable to generically address: (1) The issue of cumulative transportation impacts and (2) the imphcstions that the use of higher bum-up fuel have for the conclusions in Table S-4. After consideration of these issues, the Commission wm determine whether the issue of transportation impacts should be changed to Category 1." l lasue 3-Transportation Analysis Comment: NRC failed to consult relevant Yucca Mountain transportation risk and impact studies.

C;-xi.e: The publications cited by commentors have been renewed for information that may be of direct use within the limited focus and purpose of the current rule. Most of the information in these documents was found to be potentially more relevant to a detailed site-specific review of Yucca Mountain than to the generic analysis for this rule. That information has been brought to the attenten of those organizational units withm the NRC responsible for t

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activities relating to DOE's study on the Yucca Mountam site so they cu appropnately conexler '

the information in any future prelicensing activities involvmg Yucca Mountain. Specific to the current rule, the demographic data used as inputs to the RADTRAN computer code, which was used to generate the impact analysis in Addendum 1 were more current than data used in many of the studies cited by the commentors.

Comment: NRC failed to consult the full spectrum of transportation mode and route scenarios.

Response: The purpose of this rule and amanciatad analysis is to reach conclusions regan$ng the Rely environmental impact of license renewal. As noted atxwe, this amendment is an addition to generic assessments of license renewal environmental impacts already codified in the Commission's regulations at 10 CFR Part 51, Subpart A, Appendix B. It is not an environmental impact statement for a repoenory at Yucca Mountam for which DOE !s responsible and, as such, does not delve into the expansive range of different transportation modes and route scenarios that would be considered in the context of a decision on Yucca Mountain as the W aite for the facility itself. Instead, the NRC has sought to determine a conservative estimate of the likely impacts from transporting fuel and waste generated, during the license renewal term, in the vicinity of a potential repository. In doing so, the NRC considered only those transportation modes and route scenarios that would likely result in the greatest impacts. For the proposed rule, the NRC .;# in consultation with DC6 X c::: :.. .: . ;,v, staff- determined that truck shipments through densely populated areas of Clark County, Nevada, would have the highest potential impacts among the altamative transportation scenarios and modes that would receive serious consideration in decisions 15

Response: The analysis encompasses members of the public residing, working, or '

institutionally confined at locations near shipping routes by assuming that the resident population along the transportation routes is exposed to every shipment. The text of Sect. 2.3 of Addendum 1, has been revised to state this assumption and its effects on the rowsed analysis more clearly. In addition, more conservative assumptions of truck speed have been used in the revised RADTRAN analysis thus extending the exposure time to individuals along the transportation route. These assumptions further ensure that members of the public cited by

' the commentors would be ern;v.i----- d by the dose and risk assessments. As expected, the use of these more conservative saeumptions leads to higher estimaten of radiation dose to the compared to natural ybd and ob-cl public. However, these revised does estimates are X w.( belu segl IAh fw m A 4 sources of radiation exposure.

,g, (gy, a Several commentors indicated that Addendum 1 should focus on unique and location-specific circumstances of the transportation routes and population centers. However, the -

analysis in Addendum 1 is genenc and was designed to support only the limited scope of the decision regarding this rule change. The NRC believes that the routes chosen represent a conservative analysis due to the higher number of people who live along these routes, h- the purposb of this rule is to prwide a generic analysis for the limited purpose of determining the likely impact of transportaSon during the license renewal term, the large erd /M effort required for the identificatkm of specific population locations and traffic circumstances is not warranted within the context of the cummt rule. Although the comments raise valid issues, those concems should be recobed within the context of studying, and meldng decisions concoming, the suitability of the candidate repository site at Yucca Mountain and regulatory requirements goveming transportation of spent fuel.

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. t Comment: There was insufficient consideration of radiological risks resultog from traffic gridkx* incidents.

Response: Trafhe gridlock incidents are not specifically analyzed in NUREG-1437 because of the limited scope and genonc nature of the analysis (see response to comment on consideration of rioks to members of the public, above) o a limited extent, the incorporation more conservative assumphons of truck speed into the revised RADTRAN analysis compensates for an analysis of traffic gridlock by allowng for increased exposure time at any given point during transport. As noted earlier, these revised assumptions lead to higher but still small does estimates.3 addition, the routes used in the analysis in Addendum 1 were deliberately chosen to maximize estimated done. Actual routes would be less likely to have significant areas where trafnc gridlock occurs. The selection of the actual routes, for example, would comply with the U.S. Department of Transportation's Federal Highway Administration regulations (49 CFR Part 397, Subpart D) that require minimizing the time in transit (i.e., avo6dmg penods of great traffe conoestion) for routing radioeceve shipments.

wa F. ._";?the revised RADTRAN analysis includes approsomately two hours of stationary l C

I time in Clark County (during a 100 to 140 mile trip depending upon the route) for each truck '

{ shipment; and traffe gridlock could be one of the reasons for the truck being stationary. ,

Comment: There was insumcient consideration of routme transportation radiological risks to vehicle inspectors and escorts.

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under study by DOE to T reposto - , rather than several destinations. Table S-4 does not 4

consider non-commercial power reactor shipments of fuel and waste. Nevertheless, a

<*aamaian of the cumulative impacts of transportog spent fuel, HLW, and low-level waste thmugh southem Nevada has been added to Addendum 1 (Section 2.4). To estimate the potential cumulative effects of DOE shipments of LLW to the Nevada Test Site as well as shipments of HLW to a possible repository, the NRC staff used information published in DOE's Waste Management Programmatic EIS (DOE /EIS-0200-F) May 1997. To ensure that cumulative impacts are not underestimated, the NRC staff selected attematives in the EIS that led to the highest numbers of shipments to the Nevada Test Site and Yucca Mountain. The re suits of the analysis indicate that the cumulative doses and expectod cancer fatalities resulting from the civilen SNF and the DOE shipments are small compared to the risk of cancer from other causes.

Comment: Commentors stated that cumulative impacts along the Wasatch Front must be considered.

Response: The State of Utah maintains that a study similar to the one conducted for Las Vegas and Clark County must be conducted for the cumulative liripacts along the Wasatch Front that would originate from the proposed Private Fuel Storage Facility to be located at Skull Valley, Utah. Such an analysis is beyond the scope of this generic rulemaking because the CommW directed that cumulative impacts attributed to transportation be analyzed only in the yk.idty of Yucca Mountain. However, the NRC is currently reviewmg a site-specific application for construction and operation of the proposed Private Fuel Storage Facility at Skull Valley in a separate regulatory action. A site-specific study of the cumulative impacts of 22

traasportation is part of that review. The study will be reported in a draft Environmental impact Statement to be published for public comment. Its avM 1% di be ao41ced k he-Fidud (l %I skv . L i.

Issue 5-Legal Requirements ' _

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Comment: NRC failed to conduct a legally sufficient risk assessment. Use of a model

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such as RADTRAN is not in and of itself sufficient to meet the requirements of the National .

Environmen5d Policy Act. The NRC must consider consequences of low-probability, high-consequence accidents not included in RADTRAN, including unique local conditions, unforeseen events, sabotage, and human error in cask design. The NRC should adopt the comprehensive risk assessment approach for SNF and HLW transportation described in Golding and White, Gurdelines on the Scope, Content, and Use of Comprehensive Risk Assessmentin the Management of High-LevelNuclear Waste Transportation (1990).

Response: See the response above regarding consideration of severe accident risk (Iow probability, high consequence accidents) during transportation.

The NRC's regulatory program will continue to ensure that the risk of severe transportation accidents are minimized. Physical security for spent fuel transportation is ' I regulated under 10 CFR 73.37. Tne regulatory philosophy is designed to reduce the threat potential to shipments and to facilitate response to incidents and recovery ol packages that ,

might be diverted in transit. Although the analysis supporting the current rule does not account for 'he potential for human error, activities related to the design, fabrication, maintenance, and  ;

use of transportation packages are conducted under an NRC-approved Quality Assurance Program. This helps to provide consistency in performance and helps reduce the incidence of 3  !

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y human error. WhNe a location-specific transportation risk assessment is a n the DOE EIS for the decisions relating to a possible Yucca Mountain repc Liy, the NRC staff behoves that the anatyais conducted for this rulemaking provkles an adequate consideration of the impacts from license renewal. Further, through its' regulatory, licensing, and certification functions, the NRC has tried to ensure that transportation of SNF is performed safely with minimum risk to the pubhc, and that vehicle crashes while trer@ng SNF do not result in severe accidents. Similarly, DOE is expected to ensure tnat the routes and procedures chosen for SNF transport to the repository prowde ' ample protection of the public health snd safety and the NRC reviews and approves the selected routes.

The analysis in Addendum 1 shows that even with conservative assumptions, the cumulative radiological and non-radiological accident risks of SNF transport in Clark County are smaN. However, there are a number of opportunities to further reduce human health Iinpechi.

These include transporting SNF by rail rather than by truck. This would reduce human health effects by reducing the number of shipments and the likeuhood of accidents. In addition, .

shipping SNF via the proposed beltway would reduce health impacts compared to shipping via the current interstate highway system. The implementation of such mitigative measures must await future decisions that fan well outside of the scope of this rulemaking. In addition, for the I

purposeriof individual Econse renewal rule decisions, no plant specific mitigation measures were found appropriate for addressing the impacts identified in the Addendum. The NRC staff 6

y notes that DOEhaddress# , transportation impacts, mitigation measures, and attemative transportation modes in its EIS for the proposed repository at Yucca Mountain.

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leeue 7-Mgher Bumup Fuel -

Comment: There was insufhcient consideration of extended fuel bumup issues.

Response: Section 3 of Addendum 1 addresses the issues associated with extended fuel bumup in detail. The NRC staff's analysis of higher bumup examined the issues of radiation doses due to higher dose rates dunng shipment, higher radiation doses in the event of transportation accidents, and the potential for a criticality in the very unlikely event that high

' bumup fuel geometry is altered during a transportation accident.

' The analysis done by the NRC staff concluded that higher bumup fuel would likely i

cause higher does rates dunng transportation and thatdose rates folloung transportation accidents with radiological releases would also increase. However, despite the increased dose rates the potential impacts on the transport crews and the affected members of the public would 4 still be acceptably small. The analysis of the potential for wi^uc.W follomng a change in fuel geometry as the result of a transportation accident determined that such an event was not a concom.

Issue 8-Environmental Justice Comment: NRC fared to consider Environmental Justice.

Response: The analysis suggests that the routes through downtown I.ms Vegas, Nevada may run through areas containing a higher proportion of low-income and minority groups than the beltway routes. However, as reamanariin Sections 2.3 and 2.4 Addendum, the radiological i

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these impacts do not occur at the plant site during license renewal, the NRC has considered them here pursuant to its NEPA responsibilities.

Future EISs prepared by other agencies on proposed actions in the waste management arena (e.g., any recommendation by DOE on approval of the Yucca Mountain site for development of a repository) will undoubtedly address some of the same impacts covered by' the analysis described in this notice. Some of these other impact statements are anticipated to be more detailed given their purpose and the availability of additional information in the future.

This, however, does not diminish the adequacy of the NRC's action. This analysis is sufficient for the purpose it serves and it provides the Commission with the information needed to weigh of I the likely environmental impacts SNF transportation for individual license renewals applications X l and reach informed decisions regarding the acceptability of these applications. The rule does not, however, dictate any particular result for future actions taken with regard to a waste repository or other waste management matters. Specifically, any generic conclusions by the Commission concoming the cumulative environmentalimpacts of transportation associsted with nuclear power plants would la no way affect any DOE decision concemeng the suitabiiMy of Yucca Mountain or any consideration that DOE may give to transportation impacts in making .

that decision.

Comment: Addendum 1 is not meaningful to the.public. For example, it is impossible to determine if the spent fuel isotope inventory shown in the sample pages of the RADTRAN printout matches the fuel considered in the Addendum.

Response: in p,WE.g Addendum 1, the NRC staff has attempted to write to a broad and diverse audience as much as possible. The NRC staff acknowledges that this rulemaking ,

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measures must await future decisions that fall well outside of the scope of this rulemaking. In addlion, for the purposes of individual hcense renewal rule decisions, no plant specific mitigation measures were found appmpriate for addressing the impacts identified in the Addendum. The NRC staff notes that ddressMtion impacts, metigation A

measures, and altamative transportation modes in its EIS for the proposed achon to develop a e

repository at Yucca Mountain.

Cc,T . wit Addendum 1 does not mention that the proposed repository which is the destina6 for shipments of spent nucisar fuel is in Nye County.

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A statement noting that the proposed Yucca Mountain repository is in Nye County has been added to Addendum 1. 4 i

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Comment: No statements of baseline conditions are given in Addendum 1. i Response: Addendum 1 uses background and natural radiation levels as the baseline conditions against which dose estimates can be compared. Both are p. :::Ti.d in Addendum 1

. and are based in large part on information pubbshed by the National Council on Radiatkm Protection and Measurements.

G Comment The analysis in Addendum 1 is limited to human health effects. Other '

potensel impacts should be considered.

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Commission has consdered a reasonable estimate of impacts and not included remote and speculat!ve scenarios that do not add to our regulatory decmion (see also response to comment on severe accidents, above).

In the Erd,n; described in Addendum 1 the NRC staff uses dose rates that reflect the applicable regulatory limit rather than average dose rates. Even with these very conservative assumptions for dose rates, transportation modes, transportation routes, and a number of other

- factors, radiation impacts on the transport crews and the general public were not only found to V

.be within all regulatory limits but small as well and there was no need to the assumptions. )(

Throughout Addendum 1 the NRC staff h=aan the assumptions that were made and where applicable the empirical data used to support those assumptions is referenced. With respect to making judgements about the shipment of spent fuel the NRC staff has the benefit of data from over 40 years of experience in shipping SNF in this country as well as overseas.

Comment: High level waste management and transportation should not be a generic issue and Yucca Mountain should not be used for the study as DOE is behind and it is not an y approved site for SNF. N'

." :;-: -6: Given that the potenbal environmental impacts of the transportation of SNF resultng frorn heense renewal are similar for all nuclear power plants who seek to renew their operating licenses, and that the NRC staff's ard, contained in Addendum 1 concludes that the impacts are likely to be small, the Commission feels it is appropriate to raciassify the issue as a Category 1 issue. Use of Yucca Mountain, Nevada for purposes of the staff's analysis, as the destination of the SNF is appropriate as it is the only site presently under study. It must be e ,C'?--j that this generic environmental impact statement is required to make use of the 37

'(759041-P]

l NUCLEAR REGULATORY COMMISSION j 10 CFR Part 51 -  ;

RIN 3150-AG05 .

. j Changes to Requirements for Envronmental Review for Renewal of Nuclear g

Power Plant Operating Uconses, vadability of Supplemental Environmental Impact Statement k klude %s.* dane of Ceshuk TrMyrd*bh Gr ets, assd AGENCY: Nuclear Regulatory Commission.

l ACTION: Notice of availability.  ;

i SUhMARY: The Nuclear Regulatory Commission (NRC) is announcmg the completion and ,

i availability of NURE'G-1437, Vol.1, Addendum 1, " Generic Environmental impact Statement I for License Renewal of Nuclear Plants: Main Report Section 6.3-Transportanon,' Table 9.1 l

' Summary of findings on NEPA issues for license renewal of nuclear power plants,' Final l Report" (August 1999).

ADDRESSES: Copies of NUREG-1437, Vol.1, Addendum 1 may be obtamed by writing to the i Supenntendent of Documents, U.S. Govemment Pnnting Office, P.O. Box 37082, Washington,  ;

- DC 20402-9328. Copies are aino available from the National Technical Information Semce, 5285 Port Royal Road, Springfield, Virginia 22161. A copy of the document is also available for i

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Supplemental Analysesfor Cumane EnvironmentalImpm . .

i of the proposed repository due to the renewal of a nuci r power plant operating license.

Section 2.3 presents the results of those analyses, n 2.4 discusses impacts of y.

additional ra Jioactive waste shipments, and Section 2.5 presents a summary of SNF transport impacts. Finally, Section 2.6 examines the potential for environmentaljustice issues related to radioactive waste transport in Clark County, Nevada.

2.1 BACKGROUND

ON THE PROPOSED HLW REPOStrORY The Nuclear Waste Policy Act of 1982 WWPA) gave the U.S. Departmer$t of Energy the responsibility for finding a site for dispo.al of commercial SNF and other high-level weste, and for building and operating an underground di.posal facility called a geologic repository.

In 1987, Congress amended the NWPA and directed DOE to study only Yucca Mountain, Nevada, to decide whether it is suitable for a repository for high-level nuclear waste. Under the NWPA, DOE has been studying Yucca Mountain for 15 years as a potential geologic l repc.avry forthe 6,.pceltian of the nation's spent nuclear fuel and high-level radioactive waste. Mcnver, a number of decisions remain to be made before Yucca Mountain could

' ever be cor.eidered for development of a repository; any one of these decisions can stop the  !

approval process. The Secretary of Energy plans to make a decision in 2001 on whether to j recommend the site to the President for development as a repository. If DOE finds the *

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Yucca Mountain site suitable and recommends the site, then the President must decide whether to recommend the site to Congress. If the President recommends the site and il Nevada submits a notice of disapproval, then Congress must decide whether to allow the )

recommendation of the President to take effect. Only if the decisions remaining to be made ultimately support development of a repository at Yucca Mountain, then DOE would submit a license application to the C. If the repository is licensed, than SNF and HLW would be shipped to the site ly -

NRC-certified transportation packages. K 2.2 APPROACH TO ANALYSIS

' The staff's overall approach was to use NRC's current knowledge base and transportation experience, to develop assumptions that reasonably estimate and bound the risks  !

associated with the increased number of spent fuel transports that might occur if license i renewal of nuclear power plants were to occur. These assumptions are generic in nature, meaning they could be applied to any licensed nuclear power plant. The NRC staff made a l

e number of ' conservative' assumptions, which means that the assumptions would lead to an ,

overestimate of what the NRC staff believes to be the actualimpacts. Examples of where -

the NRC staff believes conservative assumptions have been used appear later in this section. The goal is for the results to be used by a license renewal applicant as it would any j, other Category 1 issue.  ;

in accordance with the NWPA, DOE is required to prepare an erwironmental impact  !

statement (EIS) for Yucca Mountain. The EIS will consider the proposal to construct, operate, and eventually, close a repository at Yucca Mountain. See DOE Notice of Intent (60 j FR 40164). DOE is expected to maaa== national and regional (i.e., within the State of  ;

Nevada) transportation options that cover the full range of operating conditions relevant to 1

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g'- c'Amalysas'f prCasnadsewEau

. , - ' Impacts. . .

.boE r ec.41 ics ueet it doh EIS 4 Wo-dq g3;c, em r ue petiod b iba'q o^ Avps+ 1 ~.1, l' tit - 1 potential to human health and the environment.' in its response to public scoping comments, DOE indicated that its draft EIS transportation analysis would include both truck and raN transport, and use Department of Transportation routing regulations and representative routes and actual route characteristics. Thus, DOE's expected transportation analyses wHI be detailed; however, DOE does not plan to complete its final EIS until 2000.

Y This analysis aims to address the cumuistive impacts of SNF heisportation to a HLW renository from a generic perspective.7 Because Congress, at this time, has directed DOE to shiy only Yucca Mountain for the proposed repository, the NRC staff began with the assumption that aN SNF would be transported through Clark County, Nevada (i.e., the Las Vegas area) en route to the repository. This assumption is conservative in several ways.

Finst, current law would not allow more than 70,000 metric tons of heavy metal (MTHM), with an estimated -63,000 MTHM of that total being from commercial SNF, to be diapnaari of at Yucca Mountain. Nevertheless, the NRC staff used essmates of quantities of SNF that would need to be rearnaad of that are considerably larger than the 83,000 MTHM for the purpose of evaluating the entire inventory of SNF perd rari by nucisar power plants. Second, there are other routes to Yucca Mountain rather than through Clark County, but none, of the other routes would encounter as high a population as found in Clark County. The NRC staff also adopted this assumption because-whether Yucca Mountain or another site is selected for a repository- estimates of transportation impacts are maximized in the case where all SNF is transported through a major metropolitan area. The NRC staff believes it important to emphasize that, while conservative, the assumphon may not be at aN representative or reaisatic.

Transport ition to Yucca Mountain or another repository site may make heavy use of rail transportatron, for example, because raN transport is expected to be less costly than truck transport. The overaN radiological impacts of rail as compared to highway shipments may be lower, in part, this is har==a of the higher capacity of rail cars which aNow fewer shipments and har=== population densities along most rail routes are typically lower than along the interstate highways _ that trucks would use to transport SNF. Additionally, when non-radiological accident rates between truck and rail shipments are normalized for payload size and mileage, the accident rate for rail shipments is about 3 percent of the comparable accident rate for truck shipments (Dyer and Reich 1993). Evaluation of cumulative impacts in the vicinity of Las Vegas carried out in this analysis, therefore, i.pc:: e an upper bound because it assumes aN SNF would move by leg.' did truck rather than by rail or by a combination of raN and truck to reach the repository.s Further, to ensure that the impacts estimated here are conservative, the NRC staff assumed that shipments would be by legal-

• DOE's Nollos of intent incBestes that its enelyses of impacts of regional trenopostolion leeues wil include (a) technical feeshety, (b) N impacts, (c) land use and ecomes impacts, and (d) impacts of constructing and operating a rei spur, a hoewy haul route, and/or a trenelerlocaly, e0 FR 40168.

7 After DOE's publication of the Anal EIS for Yucca Mountain, the Commiecion wNI consider whether the infonnealon contained theseln would be considered new and signlReent in the conted of docesons related to the renomal of nuclear power plant operating Booness such that some addhional action may be required.

• The NRC eleti did not consider conservalho analyses that would be outside the reasonabio range of esauruptons, e.g., routing shipments on indirect routes through doneely populated erees. While the NRC staff did mehe many conservalho assumphons, coneselent whh U.S. Department of Trenoportellon regulations for highuey route controted quenWies of nucieer enelonels (49 CFR 307.101), the NRC stall eseumed that the tsucia would be routed on interstate highways to the maximum pammaMa adent.

NUREG-1437, Mrl=d=n 1 6

m

% ' ^ 'Analys:sfor Canulartve Ee;,- ^ ! Impacts. . .

weight trucks rather than heavy-haul trucks because fewer shipments would be required if heavy-haul trucks were used.

To immine the effects of license renewal, the NRC staff used two estimates of SNF that would be transported to the repository. The first was based on the assumption that no nuclear plants have their licenses renewed, and the second was based on the assumption that all existing nuclear plants would operate for the full duration of a 20-year license renewal period. This means that the amount of SNF shipped for the heense renewal case was assumed to be 50 percent greater than the amount of SNF for the no-license renewal case. t

' The assumption used for the license renewal estimate is consavative b-ma some plant owners have already dacidad not to request renewal.of plant operating licenses. i l

As noted above, the NWPA prohibits DOE from accepting more than 70,000 MTHM of HLW t at the Yucca Mountain repository, only 63,000 MTHM of which would be SNF. Based on this limit, DOE solimates on the order of 37,800 truck shipments of SNF to Yucca Mountam, assuming au SNF travels by truck in !=-Z z'in casks (K. Sidpper, Yucca Mountain Site Office, personal communication to D. P. Cleary, NRC, July 11,1997). For this analysis, the NRC staff assumed that au current and committed SNF, about 84,000 MTHM, would be ,

diapanad of at Yucca Mountain. [The Nuclear Waste Technical Review Board (1997) made a very similar estimate of current and committed SNF.] Using DOE's estimated number of '

shipments and the total arnount of SNF leads to an estimate of the order of 50,000 truck t

shipments without license renewal. Assuming aN plants renew their licenses and operate for '

'an additional 20 years, the estimate isp(the order of 75,000 truck shipments.'

on )(

The analysis used the RADTRAN computer code (Sec6on 2.2.3) to estimate the radiation doses to the people of Clark County and to transpor1ation workers. The route and population donelly numbers used by RADTRAN computer code were generated by the HIGHWAY computcc code and modified by the NRC staff to account for par % growth *

(Section 2.2.1). The human health implication of the radiciogical exposures were estimated

- by use of BEIR V N-elsk factors (Section 2.2.3). The risk of non-resSological accidents were estimated by using U.S. Department of Transportation statistics (Section 2.3.2).

j

(

2.2.1 Transportation and Route Soonerlos l

I

' The HIGHWAY computer code (Johnson et. al.1993) was used to select routes. The  ;

HIGHWAY computer code models the U.S. highway system. Its data base includes aN interstates, most U.S. highways, and many State, county, or local roadways. It represents about 380,000 km [240,000 miles) of roadway. Several different routing options are available in the highway program, including probable commercial routes, routes on the interstate highway system, toutes that bypass major urban areas, and preferred routes designated by .- '

the states. Addisonal detailed routing analysis can be pavormed by blocking individual or -

sets of highway segments or intersections contained in the data base, a feature the NRC sten uttland to analyze the downtown routes.

• Athough these esemstee =,e the 70,000 MTHM Emit for the Aret repositoryin the NWPA, mey repsesent consenetwo assumptione (i.e overestimaise) that muid deAne an upper bound of potential impacto for a repoellery at Yucco Mountain.

' \

7 NUREG-1437, Awarh== 1 }

. 4'

1

- * '-,; ' r' Analysesfor Cumadanve EnvinmmentalImpacu. . .

highways are particularly congested. While there are a number of ways to reduce the magnitude of such exposures, the NRC staff introduced two additional conservative assumptions into the RADTRAN computer code .r J,J., to account for these concems.

First, the NRC staff assumed that the trucks would travel at lower speeds than is typical for interstate highway travoi; 55 mph in rural areas,25 mph in suburban areas, and 15 mph in urban areas. Second, the NRC staff assumed that tne trucks made stops at a rate of 0.011 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> /km of travel. Because each truck traveled at least 165.8 km (104 mi), every tnd was assumed to stop for at least 1.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (100 minutes). Further, the NRC staff assumed that for the entire stop period,30 members of the public were located 20 m (66 feet) from the truck, and that all members of the transport crew contmuod to receive 2 mrom/ hour during the stop. As a p .dic.l matter, the NRC staff believe that these conditions would seldom be exceeded for an individual shipment, and that typical shipments would move at normal highway speeds throughout the urban and suburban areas, and that shorter, less frequent stops would be the norm.

Each truck shipment of multiple fuel assemblies was modeled as a single package with a homogeneous distribution of the radiological mve itory. Both point- and line-source approximations were used radiation source. The characteristic based(known dimenmon uponinthe distancecomputer the RADTRAN between the exposed code as the variable PKGSIZ) is the largest linear dimension of the configuration and is used in the line.cource approximation to emientata total dose; 5 m [16.5 ft] was the assumed lengt i source. Reennaa transport casks are designed to absorb,most neutron radiation and 3 AoT t=-- C&. = * ^-, is absorbed by the air _in short "-P. the radiation dose to the %M public from the casks was assumed to consist entirely of gamma radiation for calculaten of h the incident-free does. M-For reinases of radioactive material resulting from postulated accdonts, the RADTRAN c~nputer code uses a dispersibility category to determine the fractions of the total inventory that are aerosolized and respirable. The analysis reflects the depersibility category for each lootope and considered the release fractions based on the type of package as a function of accident severity.

Accident risks include acute fatalities and latent risk of fatal cancer (from chronic exposure) for both the current and future generations. The accedent risk (expected value of dose from accidents) is the summation of the products of estimated does for each accident seventy category and the sesociated probatulity of occurrence for the category. To provide a conservative estimate of potential accident effects, the NRC staff assumed high bumup fuel (82,000 mwd /MTU). Table 2 lists the characterishes of SNF assumed for the accident analysis.

Radiation exposures are reported as collective dose to a population (person-Sv [ person-rem]) and the does to the maximally exposed individual (mSv [mrom]). Health risks from

. exposure to radiation are reported as estimated lifebme risk of fatal cancer (LRFC) resulting from incident-free transportation of SNF and from highway accidents involving potential radiation reloness. Expected fatallbes from truck accidents not involving radiation releases are also reported. I A National Academy of Sciences report (NAS 1990, Table 4-2), commonly called the BEIR V report, gives estimates of the number of cancer deaths expected to occur from a continuous exposure of 10 mSv/ year [1 rem / year] above background from age 18 until age 65. This 13 NURBG-1437, Addendum 1

i o

h;'- _-! Analyses)br Caudative Envic--- _ T' impacts. . .

Irving more than 0.8 km [0.5 mile) from the route is negligible. Thus, the affected population was assumed to be residents of and visitors to Clark County, Nevada within 0.8 km (0.5 mile) of the route astiumed to be followed by the trucks transporting SNF.

2.3 ' CUMULATfVE HEALTH RISKS OF SPENT FUEL TRANSPORTATION

- Health risks ==aari=* art with SNF transport include both those mamariated with radiation exposure and the nonradiological risks assocated with the assumed movement of trucks carrying SNF through the Clark County, Nevada area (i.e., traffic accidents).

2.3.1 Radiological Rieka Radiation exposure can occur in two waye--exposure to radiation emitted by the SNF cask dunng routine (incident-free) transport and exposures in the event of an accident that leads

- to release of radioactive material. For incident-free transportation, the NRC staff used the

~ RADTRAN computer code to calculate total body doses to the transport crew and the general public. The rarentinn source is chcracterized for the RADTRAN computer code by the radiation does rate at 1 m from the package surface.

Potential radiological accident effects include both acute fatalities resulting from very high raremeian exposure (that might occur in the unlikely event of failure of an SNF shipping container or cask), and the LRFC resulting from radiation exposure that occur some time after the pan'd=*ari accident. Accident risk is estimated by summing the product of estimated does and the manneintari probability of occurrence for each of the accident-severity categories analyzed by the RADTRAN computer code.

The cumulative radation exposure estimated by the NRC staff is providd in Table 3. The correspondng transportation health risks are provided in Table 4. Radiation doses to the populadon and transport crews were converted to LRFC using the risk coefficient suggested

. by the National Acadesmy of Sciences (ICRP 1991; NAS 1990). It is important to note that LRFC figures represent cumulative health risks to the entire population awpamari to radiation from the shipments. More simply put, the LRFC figures represent the additional number of ,

total potential fatalities assumed within the Clark County population due to the shipment of all of the SNF over the entire life of the . . Table 4 shows that, using the bounding assumptions for this study, between ! and 3 excess fatal cancers are predicted. The of x

incident-free and accident risks is 2.5B2 LRFC for the southem route using the beltwo , w h e. K other scenarios have lower estimated riels. e # ic IN-vYwp 6 ba yp S h J+e bei -

To put this risk into perspective, the average incidence of lifetime fatal cancer in the U.S. is fM^

about 0.25 [25 percent). Assuming -a Clark County population of about 1,600,000 and an average life awpar*=ncy of 70 years, this lifetime incidence of fatal cancer would correspond 4o A 47 to about 5,700 LRFC/ year. Also, in the Clark CourWy area, the average radiation exposures reps.Wq resulting from cosmic and naturally occuning terrtstrial gamma radiation are 0.75 to 0.77 mSv/ year [75 to 77 mrom/ year]." Assuming a Clark County population of about

• This outdoor done rete estimate wee provided by H. L Beck (H. l Beck, Director, Environmental Sciences Divleion, Environmental Measurements 1.aboratory, U.S. Department of Energy, New York, personal communicedlon via elocaronic meR to A. K. Roscidem. NRC, RociarHie, ": /.c4 Nov. 4,19e8) and bened on estensive background radation measuromonte summedaad, in part, in NCRP Report No. 94, 8Va-o of the 15 NUREG-1437, Ahath=n 1 II .ame r-i -

m.. - - - --, . . -. -- -

--....a -

4

D'

. . F;;'-_ ' Analysesfor Quenninnive Environunenalimpacts. . .

living more than 0.8 km [0.5 mile) from the route'is negligible. Thus, the affected population was assumed to be residents of and visitors to Clark County, Nevada within 0.8 km (0.5 mile]

of the routa amoumed to be followed by the trucks transporting SNF.

2.3 CUMULATIVE HEALTH RISKS OF SPENT FUEL TRANSPORTATION ,

Health risks mamar4=ted with SNF transport include both those naarw4=tari with radiation exposure and the nonradiological risks associated with the assumed movement of trucks carrying SNF through the Clark County, Nevada area (i.e., traffe accidents).

2.3.1 Radiologloal Rieka Radiation exposure can occur in two wayo-exposure to radiation emitted by the SNF cask during routine (incident-free) tmnoport and exposures in the event of an accident that leads to release of rarenar*ive matenal. For incident-free transportation, the NRC staff used the RADTRAN computer code to e marudata total body doses to the transport crew and the general public. The radiation source is characterized for the RADTRAN computer code by the radiation does rate at 1 m from the package surface.

Potential radiological accident effects include both acute fatalities resulting from very high radation exposure (that might occur in the unlikely event of failure of an SNF shipping container or cask), and the LRFC resulting frorn radiation exposure that occur some time after the paahd=*=d accident. Accident risk is estimated by summing the product of estimated does and the mamar4= tad probability of occurrence for each of the accident-seventy categories analyzed by the RADTRAN computer code.

The cumulative mdiation exposure estimated by the NRC staff is provided in Table 3. The corresponding transportation health risks are provided in Table 4. Parention doses to the population and transport crews were converted to LRFC usmg the risk coefficient suggested by the National Academy of Sciences (ICRP 1991; NAS 1990). It is important to note that LRFC figures represent cumulative health risks to the entire populeton exposed to radiation fmm the shipments. More simply put, the LRFC figures represent the additional number of total potential fatalities amoumed within the Clark County population due to the shipment of all of the SNF over the entire life of thezepository. Table 4 shows that, using the bounding K aneumptions for this study, betweenT and 3 excess fatal cancers are prodcted. The of incident-free and accident risks is 2.5B2 LRFC for the southem route using the , ver u c X other scenarios have lower estrnated rielai. eebia- lih- ,

V Yaapa< W y ip S dke of-Fe 4nn - l To put this risk into perspective, the average incidence of lifetune fatal cancer in the U.S. is FM about 0.25 [25 percent]. Assuming a Clark County population of about 1,600,000 and an average life espectancy of 70 years, this lifetime incidence of fatal cancer would correspond 4o A GQ to about 5,700 LRFC/ year. Also, in the Clark County area, the average radiation exposures reps %

resulting from cosmic and natundy occurring terrestrial gamma radiation are 0.75 to 0.77 mSv/ year [75 to 77 mrom/ year)." Assuming a Clark County poptdation of a'sout

• This outdoor dose rose sommate wee provkied by H. L Beck (H. L Beck, Dwector, Envuonmental Sciences Division, Environmental Meenwomente t.aboratory, U.S. Depenment of Energy, New York, personal communicahon via electronic men to A. K. Roecklein, NRC, Rockville, Maryland., Nov. 4,'190s) and beood on essensive background redletion measuremente summertaed, in part, in NCRP Report No. 94, Eaposure of the 15 NUREG-1437, Adriandu n 1

% '- ' Analyses)hr Cumulaan Enwonnunaal impacu. . .

derincAdee %sf

~

The hypeth"3; maximally avpamari indindual wo7uld C;; 0.40 mSv [40 mrem) for the K duration of shipments, about 0.16 percent of the average 70-year dose from background sources." The maximally exposed individual radiation does is based on a hypothetical indudual member of the public located in the open (i.e., without the shielding offered by )

buildings or vehicles) 30 m [98 ft) from the highway during the entire duration of shipments (a l very conservative assumption)cThis dose is the estimated risk from incident-free transport.

- The above estimates of radiation dose are consistent with the doses reported in 10 CFR Part l 51, Table S-4. Table S 4 reports estimates of 0.04 person-Sv [4 person-rem) por reactor

- year for transportation workers, and 0.03 person-Sv [3 person-rem] per reactor year for the general p@lic. Assuming that 100 nuclear power plants operate for 60 years, Table S leads to estimated occupabonal and general public doses of 240 person-Sv

[24,000 person-rom) and 180 person-Sv [18,000 person-rom) for transportation workers and the general public, i--;+ ";fi. Comparing these does estimates with the highest conceponding doses in Table 3 shows that the eshmated cumulative does to the general public from incident-free transportation of all SNF through the !.as Vegas area is less than 25 percent of the cumulative. dose from all fuel arxl waste transportation calculated from Table S-4. In light of the many conservative assumptions made in this analysis, the NRC

. staff concludes that the radiological impacts of the shipment of SNF are small and are mecaf*=hly addressed using the generic impacts methodology of Tab!s S-4 for individual nuclear power plant operating license renewal purposes.

2.3.2 Nonradiological Rieka The NRC staff assessed the impacts of nonradiological truck accidents that may occur during the transport of SNF to the repository. A nonradiological accident is a truck accident in which the property damage, injuries or fatalities are caused by the force of the impact; no

~

rolesse of or exposure to radiological matennis occurs as a result of the truck accident. Data on national accident statstics have been compiled from a number of sources by the U.S.

Department of Transportation (DOT), Bureau of Transportanon Statistics, between 1975 and 1995. Since 1990, data have been t'aumetari on the number of accidents, injuries, and fatalities per 100 million truck 4ntes (DOT 1999). Based upon the accedent rate data from 1990 to 1996, the avocage rate of large truck accidents is 145 per 100 million truck-km [233 por 100 million truck-miles), the average rate of injury is 13 por 100 million truck-km [21 per 100 million truck-mlies), and the average fatality is 0.26 per 100 million truck-krn [0.42 per 100 million truck-miles). On the bass of these statistice--elong with the . HIGHWAY computer code route data-the awpar*ari number of nonradiological accidents, injuries, and fatalities is enled=*ari as shown in Table 5 for shipments during the 40-year (without license renewal)

' and 60-year (with license renewal) repository operations period. Over a 40- or 60-year

" The bachyound redelion does is assumed to be 3.6 mSWyear [300 nwerrvycer), the current estimate given ser everage backpound redemon does in om u.s. Tre venue le bened upon the tomoung assumpeans

, from the Netonal Counou on Rededon Protecton and Measurements as summenaed in Eisenbud and Geseu (1997). Dosee oro ghen in rnSWyear.

cosmic redenen that seenhoe tio earti at see level 0.27 Redsilon isom 9:e netsel elements in Sie earth 0.28 Redon goe in Sie home 9som geoimd soumes 2.00 Modston in fin human truly Dom food and water 0.30 Ausage w.edical easianum 0.25 to 0.56 consumer psoduals (e.g, amate deseolore) 0.10 NUREG.1437, Addendum i 18 1

o

.~

w e3 as ,,gy ,,,ja , ( ,

y,,;,,,,,,,,; y,p,,, , ,

the radological effects of these shipments, the NRC staff assumed that each DOE SNF, ,

HLW or LLW shipment was equal to a shipment of commercial SNF. For the radological impacts of LLW, the assumption is very conservative because, as indicated by DOE's estimate of 1 mmm/ hour (0.01 mSvMour) at 1 m. LLW is generally much less radioactive )

than SNF. For non-radiological efferas, the NRC staff assumed that each shipment would have the same effect regardioes of what material was being transported.

i Using highest doses and cancer risks in Tables 3 and 4 and the assumptions above, the NRC staff estimated the doses and LRCFs for shipment of DOE radioactive waste through '

Clark County. As shown by Tables 6 and 7, the cumulative doses and expected cancer fatalities continue to be small compared to the risk of cancer from other causes.

1 The non-radiological cumulative effects of radioactive waste shipment through Clark County are dominated by the very large number of LLW shipments. All SNF and DOE radioactive weste and SNF shipments through Clark County would total to more than 374,000 shipments, almost 5 tunes as many as SNF shipments with license renewal. Thus, between -

125 and 250 non-sadiological truck accidents can be expected during the 374,000 shipments of radioactive wastes through Clark County. The expected number of aceiriant fatalities is between 0.22 and 0.46 for all shipments of radiological waste over all the years the shipments would occur. Assuming these shipments occurred over a 40-year period, between 3 and 6 traffic accidents involving trucks transporting all types of rarilaar4ive waste matenals would be expected in an average year, and there would be a very small chance that a fatality would result in any one year.

{

pos d N M g 2.5

SUMMARY

OF SNFTRANSPORTIMP% F h f= of As shown in Table 4, the estimated LRFC to result from radiation p4N exposure related to transportation SNF in Clark l between 1.6 and 2.6 (including Qg<

the risk dL to potential maririants . For comparison, it is estimated that there would be about 5700 LRd G for each yearpclae causes unrelated to SNF transport.

% fY )

Non-radiological truck-vehicle accidents are possible as a result of trenoporting SNF through Clark County. The probability of a fatality is estimated to be less than 0.000 under all scenarios. For license renewal, the combined radological and.non-radological risk to the general public is estimated to be between about 2.3 and 2.6 fatalities over the pourse of SNF X transport through Clark County, including incident-free and accident risks. Wit mut license renewal, the estimated is between about 1.5 and 1.8 fatalities. V uu.

The above analysis shows that, even with conservative assumptions, the cumulative i radiologimi and accident risks of SNF transport in Clark County are small it also shows that allemative assumptions are bounded by this analysis and would result in even smaller human health impacts. Transporting SNF by rail rather than by truck would reduce human health effects by reducing the number of shipments and the likelihood of accidents. Shipping SNF via the proposed beltway would reduce health impacts compared to shipping via the current interstate highway system. In addition, shipping SNF via the proposed beltway would reduce health impacts compared to shipping via the current interstate highway system. The implementation of spch mitigative measures must await future decisions that fall well outside of the scope of this rulemaking. DOE will address transportation impacts, mitigation measures, and altamative transportation modes in its EIS for the proposed repository at

. . Yucca Mountain.

21 NUREG-1437, A& Ism a=1

- ~

.W '- ' Analyses)6r Cunudarw Eminmnwnullmpaas. . .

'.2.8 ENVIROlGAENTALJUSTICE Environmentaljustice refers to a Federal policy in which Federal actions should not result in disproportionately high and adverse environmental impactiron low-income or minonty populations. Executive Order 12898 (59 FR 7629) directs Federal executive agencies to consider environmentaljustice under NEPA. Although the Executive Order does not apply to the NRC, an independent agency, the NRC has stated that it will comply with the. Executive ,

Order. -

(em wh s eeiclut-sc&os -

As explained endier, only people within 0.8 km (0.5 mile) of the soute followed by1he trucks transporting SNF would receive any appreciable radiation dosejConsequently, the NRC staff examined available data on ic; bwie and minority populations within that distance along transportation routes to determine if there was reason to suspect that SNF transport impacts might fag f ,-c- =ilur ' 's on ic bsrs or rninority groups. To this end, the NRC staff examined the racial, ethnic and population charactenstics of Clark County as a'whole and the same characteristics of the transportation routes.

Table 8 describes the overaN racial and ethnic characteristics for the population groups in Clark County (Bureau of the Census.1990)." ,

Nevada is one of the fastest growing states in the U.S., with Clark County growing faster than any other Nevada county. The 1990 census listed 741,459 people as limng in the county (Census Bureau Database C90STF1 A; http1/ venus. census.govkew,s.4ockup/929978369, acemanad June 21,1999). Clark counya projected 1999 population was 1,337,400, and the projected 2004 population is 1,656,840 (Nevada State Demographer June 1,1998). Las i Vegas accounted for most of the County's growth. In July 1998, an estimated j 448,244 persons resided in Las Vegas, a 6 percent increase since July 1997. In addition to residerns, Las Vegas has many visitors staying in hotels.  ;

Tatne 9 reports the percentage of ethnic and racial groups living within 0.5 mile (0.8 km) of the nr++^ -, routes. These data were assembled using an Oak Rid 9e National Laboratory computer program that integrates Map-info

• with the Census Bureau. data available on CD-ROM (U.S. Census Database C90STF1 A,1990).1990 data were used to

- be consistent with the population doneity estimates used in the HIGHWAY computer code.

Table 9 shows that only for the route from the northeast through downtown would the fraction of a minority within the 0.8 km (0.5-mile) comdor ac$acent to the route be significantly higher than the county average. >

j l

1 4

• Per Olhos of Management and Budget 1998 Dimethe No.15, to Census Dumeu uses four race -

categosies (Whts, Black, American Inden and Aleeke nethe, Asian and PaciSc leiender) and two othmolly estegodes. Hispanic and ;-. ""^; & (Bureau of the Census 1900).

23 NUREG-1437, AMa=rh== 1 j

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, . ,'- : " Analyser)br Cammadane Emironsimisslinipscer. . .

exceed 33,000 megawatt-days per matric ton, and no irradiated fuel assemtdy is shippL untu at least 90 days after it is discharged from the reactor." These two limiting conditions have been am thnx.Jh nuclear power plant hoense amendments pennitting incrementalincreases in the bumup of fuel. During the 1990s, the NRC has reviewed and

.'J. Virgilio, NRC, to N. J. Liparulo, Westinghouse Elactric Ce,pei.i;06, " Acce Referencing of Topical Report WCAP-12488, 'Westmghouse Fuel Critoria Evaluation Procoes," dated July 27,1994; FCF-BAW 10186P-A, " Extended Bumup Evaluation," June 12,1997; and Memorandum from T. E. Collins to B. W. Sheron, ' Waiver of CRGR Review of EnF-85-74(P), Revision 0, Supplements 1 and 2 Safety Evaluation," dated February 9, 1998). Approved everage bumup for the peak rod now ranges from 50,000 to 62,000 MWdNTU. The higher bumup levels are associated with uranium-235 enrichment levels of up to 5 percent by weight. Thus, it is likely that at the time of a submittal of a heense renewal appbcation, many nuclear power plants wiR be operating at higher fuel bumup and wiu be using higher enrichment fuel.

Further, the assumed minsnum time for shipping spent fuel of 90 days after discharge from the reactor was bened on the assumption that the spent fuel would be shipped to a iy,ic :- ' is factity. F ,,,c-n " ,g spent fuel is currently not a reasonable assumpton.

Cunently, the reasonable assumption is that spent fuel will be shipped to an interim storage facNity or to an ultimate repository and would have been discharged from the reactor at least f 5 years % in fact, the current practice of NRC issuing certificates of compliance for casks used for idupment'of power reactor fuel is to specify 5 years as the minimum cooling Period.  ; ,,_e e fs q ar V0 p w 4et.

g ud h p b rads.b & & 9" O !"'" % >

Rarman many power plants are now operating with higher enriched fuel irradiated to

~K higher bumup because of public concems about transportation impacts of higher bumup SNF, the NRC staff examined recent technical literature on, and performed additional analyses of the characteristics of higher bumup SNF. The analyses summarized below address two questions: the extent to which higher bumup SNF might have greater incident-free transportation impacts than opent fuel with the charactenstics aneumed for Table S-4, whether accidents invoMng higher bumup SNF might have unacceptable impacts, and whether arv*tants involving higher bumup SNF might cause criticality during a transportation accident.

For incident-free transportation, the principal concem is whether, because of its different radiological cowp: ?': i, higher bumup fuel would require more shipments and larger transportation impacts than predicted by Table S-4. Quantification of the radiation omissions for reactor fusis is a complex process. However, there are several insights that allow for scahng of the rariinar*6ve emissions from one bumup level to another. For the gamma-ray sources, the scaling due to bumup is a linear relationship, i.e. a doubling of the bumup yields, a doubling of the gamma-ray emissions and, typically, a doubNng of the dose rate due to gamma rays. .The scaling for neutrons is not linear. Neutron emissions increase as the I fourth power of the bumup ratios given the same initial enrichments; that is, doubbng bumup increases the neutron eminaions rate about sixteen tones. In practica, however, higher bumup fuels require higher initial enrichments, such that neutron emissions typically increase as the equare or cube of thebumup ratios. For example, ancy.;. by Parks et al. (1987)

NUREG.1437, ki&=when 1 26 I

Su,5-! -! Analysesfor Cunudative EnvinmmentalImpacts. . .

showed that for a 35,000 mwd /MTU and a 60,000 mwd /MTU (bumup ratio 1.71) the neutron emissions ratio is 4.28 (less than the third power of the bumup ratio).

The increase in the total radiation dose rate due to higher bumup is complicated because the total dose rate is the sum of the gamma-ray and neutmn done rates. For nominal bumups, g d q

the dose rates at the surface and2-m frorrlthe surface are approximately 90 percent gamma-rays and JO percent neutrons]Indeed, Westfall et al. (1990) found that for a OO transportation cask mat was designed for use in DOE spent fuel applications, the calc total does rate at 2 m for 60,000 mwd /MTU SNF was 2.19 times larger than for 35,000 mwd /MTU SNF. Thus, the total dose from a full cask of 60,000 mwd /MTU SNF would be #gy about twice as large as the dose from a full cask of 35,000 mwd /MTU SNF. Assuming an c3 additionalincrease in mammum bumup to 62,000 mwd /MTU would not invalidate that assumption gwen the small increase in bumup from 60,000 mwd /MTU.

The most obvious-way to compensate for a doubling of the 2-m dose rate would:be to M O*- y the cask payload. This would increase the numberof shipments required, but is unlikely to be pursued because of the economic and other pressures to minimize spent fuel transportation activities. In addition, under.this scenano, a cask would be partially loaded (i.e.

dorated) with the remaining locations in the basket left empty. However, because the cask would have to be certified for higher bumup to carry even a partial load, the license submittal could easily analyze the use of inserts, which would drastically reduce the extemal doses with less impact on cask capacity.

There are, however, less costly ways to accommodate higher bumup fuels. Broadhead et. al.

(1992) showed that by using a modified basket and by deratmg the cask 15 percent (an 18-assembly ps/, sed vs a 21-assembly payload) a cask with 5-year-cooled 60,000 mwd /MTU spent fuel had a lower dose rate than a 21-assembly cask containing.35,000 mwd /MTU fuel j that 'ad cooled 5 years. While the dose rates of higher-bumup fuels decline more slowly than 35,000 mwd /MTU fuel, Broadhead et al. also showed that increasing cooling times from 5 to 15 years compensates for an increase in bumup from 35,000 to 60,000 mwd /MTU.

That is, a cask designed for 5-year-cooled 35,000 mwd /MTU spent fuel should be capable of accommodating 15-year-old 60,000 mwd /MTU spent fuel without dorating. 'Thus, where on-site storage of SNF is not too costly, transportation costs and impacts can be minimized by allowing higher bumup SNF to cool 15 years before disposal.

The above two scenanos present cases where the high bumup fuela can be placed into standard casks with littia or no cask dorating, while meeting radiation limits outside of the cask. Under these scenarios, the actual number of trips to a repc.hy would be decrossed because the numberof spent fuel assemblies required for gwen amount of power would be smaller with higher bumup fuel. There are other scorurios in which the number of required trips is reduced by."blendog" of cask loadings, in which higher-burnup fuel assemblies are i placed in the middle of the cask, while lower bumup assemblies are place near the edge of the cask cavity region to absorts radiation from the inner assemblies. While this soscario appears feasible, it has not yet been approved by NRC. A totally new cask specifically designed for high-bumup fuel is another possibility. It would only be conjecture to riamaa the resu3s of such a cask design effort, but the modified cask basket described in Broadhead et al. indicates that'such a design could have little impact on the cask payload.

27 NUREG-1437, AMearbm I

u

?;'- ::AnalysisforC 'm M- nsalimpacts. .

analysis compensates for an analysis of traffic gridlock by allowing for increased exposure time at any ghen point during transport. As rioted earlier, these revised assumptions lead to higher but stui amall does estimates.

4 in addition, the routes used in the analysis in Addendum 1 wers ? "'+ ^ "; chosen to maximize estimated dose. Actual routes would be less likely to have significant areas.where traffic gridlock occurs; The selection of the actual routes, for exampia,.would comply with the U.S. Department of Transportation's Federal Highway Administration regulations (49 CFR Part 397, Subpart D) that require minimizing the time in tranet (i.e., avoiding periods of great traffic congestion) for routing rariametive shipments.

Finnby, the revised RADTRAN time in Clark County (during a 100 to 140 approximately two hours of stadonary x trip depending upon the route) for each truck shipment; and traffic grksock could be one the reasons for the truck being stationary.

ts,nsNdivdag Comment: There was insufficient consideration of routine transportation radiological risks to vweie inspectors and socorts.

E:;-: s: The RADTRAN analysis in the revised Addendum 1 uses the regulatory dose rate limit of. 02 mSv/ hour (2 mram/ hour) for the vehicle crew. In addition, a diarmalan of potential doses to socorts has been included in Addendum 1, Section 2.2.3. In the W ,0.,

both the escorts and drivers are assumed to be exposed to the regulatory limit, although the dose to the esco 1s would r=all=*icauy be less than that to the drivers. Even with these more-conservative assumptions, the estimated dose and risk to the crew are aman and below regulatory limits.

The risk to vehicle inspectors would be encompassed by the addition of stationary time for the transport truck in Clark County (see response to comment about traffic gridiock, a:, ave). Again, the estimated does and risk are increased by the use of rr.are conservative assumpeans; but they remain smas and below reguistory limits.

Comment: There was insufficiert consideration of severe trw--;-: " -. accident risks.

I:;+we: The Commission has evaluated the potential radiological hazards of severe transportation accidents involving truck and raR spent nuclear fuel (SNF) shipmenta (NUREG/CR-4829, " Shipping Container Response to Severs Highway and Railway Accident Conditions

• February 1g87, commonly referred to as the model study). The model study evaluated SNF shipping casks certilled to NRC standards against thermal and mechanical forces generated in actual truck and rah accidents. This evaluation included an assessment of cask performance for a number of severe transportation accidents, includmg the Cakiscott Tunnel fire. The modal study concluded that there would be no release in 994 of 1,000 real accidents, and that a substantiaNy lower fraction of arweidants could result in any mgnificant release. These results when combmed with the probability of a severe accident involving a shipment of SNF, demonstrate that the overaH risk associated with severe accidents of SNF shipping casks is vesy low. The results of the modal study were factored.into the analysis for this rulemaking, as an input to the RADTRAN computer code.. Additional analyses were performed to address the possible impacts of ~ accidents involvmg higher bumup fuel.

The consequences mamanlatari with an individual SNF shipment have an upper bound, based on the amount of material in the pedage, the availabetty of mechanisms to disperse the rareannelve contents, the loca6ons and number of receptors, and post-event intervention 39 NUREG.1437, AMendmn 1

, Supplemental Analysesfor Cumulative EnvironmensalImpacts. . .

than would occur. Further, this upper bound in transit might reasonably be. expected to be less than that at the origin or destination points (where more SNF would be stored), and some events themselves might be expected to have greater consequences than the damage they cause to the SNF cask. The NRC recognizes that there are some conceivable events (not necessanly traditional ' transportation accidents'), that might be hypothesized to occur u

y. a SNF cask while in transport. Even though these events 1unghfhave an extremely low probability of occurring, they might result in high consequences if they were to occur. The NRC considers these events to be remote and speculative and thus, does not call for detailed consideration. Because the NRC considers risk to be the product of the probability of an event and its resultant consequences, events with such low probability of occurring have a negligible contribution to the overall risk. In addition, as the probabilities of the events become very low, the value of insights to be gained, for use in regulatory deemions, is not apparent.

Comment: The etudy underestimates Clark County's residential population and growth rate. In addition, the study does not account for the large nonresident population, resulting in underestimates of risk and impacts.

Response: In keeping v;ith the generic nature and limited intent of the analysis, the original analysis used best available data <and best estimates of existing population and i population growth rates. In response to commentors' concems and to reflect the potentially {

large population growth rate of Clark County, the.NRC staff has incorporated higher population estimates into the analysis to provide conservative (higher than best estimate) assessments of potential impacts. However, as indicated by the comment, the task of estimating the impacts on the area population is more complex than assuming a population growth rate. Both the rate of growth of the population and changes in location of the population within the county are important. As stated in Addendum 1, populations within a half mile of the transportation route are the most affected by the transpc-tation activities.

Therefore, in order to ensure that the size of the affected population is conservative, the NRC staff's analysis not only increases over time the existing population densities along the assumed transportation routes, but also forecasts increased iscuential, business, and transient / tourist populations in the areas of likely development.

Issue 4-Cumulative impacts Comment:- NRC failed to consider cumulative impacts of all spent fuel, HLW, and low-level-waste shipments.

Response: Table S-4 shows the environmental impacts of transportation of fuel and i waste directly attributable to one nuclear power plant. The current rulemaking was narrowly focused on the question of whether the impact values given in Table S-4 would be different with spent. fuel shipments converging on one destination, Yucca Mountain - the candriate site under study by DOE for a repository , rather than several desbnations. Table S-4 i does not consider non commercial power reactor shipments of fuel and waste. Nevertheless, a docussion of the cumulative impacts of transporting opent fuel, HLW, and low-level waste i through southem Nevada has been added to Addendum 1 (Sechon 2.4).. To estimate the potential cumulative effects of DOE shipments of LLW to the Nevada Test Site as well as shipments of HLW to a possible repository, the NRC staff used information published in DOE's WC.e Management Programmatic EIS (DOE /EIS-02005) May 1997. To ensure that cumulative impacts are not underestimated, the NRC staff selected altematives in the EIS NUREG-1437, Addendum 1 40

~-

s F;;'- ^- ' Analysesfor Cumlative Eu m' impacts. . .

lesue 7--Nigher Bumup Fuel Comment: There was insufficient consideration of extended fuel bumup issues.

. Response: Section 3 of Addendum 1 addresses the

===aci=W with extended fuel

- bumup in detail. Tha NRC s,taff's ar.dy.:. of higher exarmned the issues of radiation X doses due to higher dose rates during shipment, higher radiation doses in the event of transportation accidents, and the i-:^ c.^d' for a wa ;;;iin the very unilkely event that high bumup fuel geometry is altered during a transportation accident.

4 A.rmy kh y d -

The analysis done by the NRC staff that higher bumup fuel would likely cause higher does rates during transportation and does rates following transportation soddents with radiological releases would sieo However, despite the increased does rates y the potensal impacts on the transport crews and the affected members of the pubhc would be stNI be acceptably smaN. The analysis of the potential for wi'J w;;;y following a change in fuel geometry as the result of a transportation accident determined that such an event was L

not a concem.

issue 8-Environmental Justics Comment: NRC failed to consider Environmental Justice.

E::;-: ,ee: The analysis suggests that the routes through downtown t.as Vegas, Nevada may run through areas containmg a higher p upu,^Ju.i of ic: '.,uu,,,e and mmonty groups than the beltway routes. However, as discussed in Sections 2.3 and 2.4 Addendum, the radiological and nonradiologicalimpacts of transportation of SNF are smau. in addition, these amas impacts are dispersed throughout the entire routes and do not appear to fan disproportionately in any one area. Based on the analysis performed the NRC staff

^'

concludes the overaR impacts of timi-;-  !:-i of SNF will not likely be '----:-;-:-^Jur^";

high or adversa for any minority or ic: 'c.uve,e population.

Issu e 0 F ,ulatoryText Comment: Several suggestions for clarifying the regulatory ' ya text sepa were offered.dm ca at Response:-The. rule has been revised to make it clear that the environmentalimpact values in Table S-4 (10 CFR 51.52) may be used to account for the environmental effects of l transportation of fuel and waste to and from a nuclear power plant Yucca y, Mountain, Nevada, is under consideration as a HLW repository. If, in the future, Yucca ' q Mountain is removed from consideration as a HLW repository, the Commission wiu evaluate whether the generic analysis performed for the current rule is applicable to other sites that are considered. If fuel enrichment greater than 5 percent Uranium-235 andfuel bumup of greater than 62,000 MWdNTU are approved by the Commission, the Commission win consider a rulemaking to aseems the continuing generic applicabtity of Table-S-4 to environmental reviews for license renewal.

Comment: The addibon to the rule of local transportation impacts associated with-continued operation of a plant dunng the license renewal period needs further clarification in the rule language and in the Supplementary information.

I 43 NUREG-1437, Mdand== 1

~ .

l

~ . ..

sa' =' Analysesfor Ommiative Envinamentalimpacts. . .

P::;-x,.e: if the proposed SNF storage facility is bconsed and built, sorae SNF may go through Clark County on the way to SkuN Vatey, Utah. The NRC staff has not analyzed this paanihla impact because it is not clear at this time that the proposed SkuN Valley facility wid be licensed or that the SNF would go through Las Vegas if the facility were built. In addition, SNF from Catfornia makes up only a small fraction of the SNF that would be shipped. The NRC staff concludes that the conservative assumptions used in the analysis more than compensate for minor changes in transportation plans that may develop for that fraction of the total SNF.

Comment: The NRC should prowde affected parties with some statement of the regulatory effect of the interrelationships between the numerous other similar analyses.  !

Response: As a general matter, the National Environmental Policy Act (NEPA) requires  !

all. Federal agencies to perform an environmental rewow for certam actions they propose to  ;

conduct. In the context of nuclear waste management, several agencies have regulatory ,

and operational r=;-Fr ~r:: which may involve various proposed actions that, in tum, l require the preparation of environmentalimpact statements (EISs).. Inevitably, there may be a degree of overlap in the types of impacts reacunaad in these various EISs. However, the analysis 6:':-;+1 by the NRC for the purposes of bconse renewal is not binding on future actions and amaariated environmental impact analyses.

The NRC proposed action that has triggered the preparation of this rulemaking and the maaaciated analysis of environmental impact is the agency's responsibuity to review applications for the renewal of nuclear power plant licenses. In light of the decrete purpose j of this rulemaking, The NRC has sought to gauge the impacts of license renewal given the '

informabon cunently available on those impacts including the transportation of spent fuel.

Even though these impacts do not occur at the plant site during license renewal, the NRC has considered them here pursuant to its NEPA ;i==--Fu~f::. ,

fof Future EISs prepared by other agencies on yr ,-:::4 O-,e in the waste management i

l arena (e.g., any recommendation by DOE on the Yucca Mountain site for development of airepository) will urwir= *darey some of the same unpacts covered by l the analysis described in this notice. Some of other impact statements are anticipated i to be more detaued given their purpose and the a of additionalinformation in the i future. This, however, does not diminish the adeq cy of the NRC's action. This analysis is sufficient for the purpose it serves ar'd it provides Commission with the information needed to weigh the Ikely environmental lii,ph.i.vNF transportation for individual license reneweis appbcations and reach informed decolons regarding the acceptatulity of these applications. The rule does not, however, dictate any particular result for future acbons taken with regard to a waste repository or other waste management matters. Specifically, any generic sh by the Commission concoming the cumulative environmental  ;

I impacts of transportation ===acia**d with nuclear power plants would in no way affect any DOE decision concoming the suitabitty of Yucca Mountain or any conssderation that DOE j may give to transportation impacts in making that deceion.

Comment: Addendum 1 is not meaningful to the public. For example, it is impossible to )

determine if the spent fuelisotope inventory shown in the sample pages of the RADTRAN pnntout matches the fuel considered in the Addendum. l l

45 NUREG-1437, AWadum 1 I

(.

~.,  ? ;; '- _

• AnalyusJiw Camdame Ennronnmuelimpacts. . .

Comment: Report failed to. provide conditions for informed consent which requires disclosure to those affected, their understandng , and voluntary acceptance.

Resprees: NRC regulations already contain values that the NRC considers to be accepMne environmental impacts from the shipment of SNF and other radcactive waste. In Addendum 1 the NRC staff is, in part, ensuring that the overall impacts of the transportation l of the additional SNF thett will be generated as the result of nuclear power plant license I renewal are bounded, given the.l'est informaten the NRC staff has at this time, by those values previously found acceptable. The values epocihed in the regulations are supported by analysis and were adopted into3the regulations only after providing opportunity for public comment as part of the NRC's rulemeldng process. As such, the NRC has followed all i applicable legal requirements and appropriately carried out its responsitzlity to consider the environmental impacts of its license renewal decision.

Comment: The NRC staff uses "flawer adence as evidenced by factors indudmg a 7::N-% definition of risk which fails to account for severe accidents, use of misleading if not falso average radation does rates, mamputation of dose rate data to obtain acceptable results and lack of empirical data especially that applicable to transportation of SNF.

Response: The decision before the Commission is whether the impacts of heense renewal are so severe that they should preclude the option of liconee renewal. As such, the Commission has considered a reasonable ashmate of impacts and not included remote and apadaWe scenarios that do not add to our regulatory r4adaiari (soa also response to comment on severe accidents, above).

In the analyses described in Addendum 1 the NRC staff uses does rates that reflect the applicable regulatory limit rather than average dose rates. Even with these very conservative assumptions for does rates, transportation modes, transportation routes, and a number of other factora, redation impacts on the transport crews and the general pubic were not only 4 found to be within all regulatory limits but small as well and there was no need to apet the assumptions. J Throughout Addendum 1 the NRC staff riimmamaa the assumptions that were made and where applicable the empirical data used to support those assumptions is referenced. With eospect.to maldng Judgements about the shipment of spent fuel the NRC staff has the benefit of data from over 40 years of exponence in shipping SNF in this country as well as overseas.

Comment: High level waste management and transportation should not be a generic issue and Yucca Mountain should not be used for the study as DOE is behind and it is not an f approved site for SNF. tgAae

. Response: Given that the potential environmentalimpacts of the transportation of SNF resulting from license renewal are similar for all nuclear power plants who seek to renew their operating liooness, and that the NRC staff's analysis contained in Addendum 1 concludes that the impacts are likely to be small, the Commission feels it is appropriate to recieselfy the issue as a Category 1 issue. Use of Yucca Mountain, Nevada for purposes of

.the staff's analysis, as the destination of the SNF is appropriate as it is the only site presently under study, it must be wf '=+1 that this genonc envronmental impact statem9nt is required to make use of the best information available and at this time the assumphon that Yucca Mountain is the doetmation is reasonable for purposes of the staff's analysis, if in the

~ ~

NUltBG 1437, Addendum 1 48

l s . S;;'- "' Analys:sfor Cunudative Eavirmamenaalimpacu . .

future, conditions change, the assumphon made for this ar.f,2 may need to be reevninnemet Comment: Need to consider the intennodal option being considered by Congress for Caliente, Nevada.

Response: The shipment of SNF by rail to Caliente and then transferring it to truck for shipment to Yucca Mountain is one of many options under consideration by DOE. Rather than speculate on which transportation option or opbons will ultimately aslected, the.NRC sta# has chosen a mode and routes to Yucca Mountain which in its j will have the X

]

greatest potential environmentalimpactadh pyre wd.e h d.kg.h .qsu

• bMJ g

M r.Je., i Comment: The analyms needs to address the impacts of above ground nuclear weapons testing being done at the Nevada Test Site.

Response: For the purposes of considenng the environmental impacts of license renewel, there does not appear to be a relevant connechon between transportation 'iivicts, from civilian SNF and defense related weapons testing at the Nevada test site.

Comment: The analysis relies on assumptions that are 25-30 years old and that have a i number of problems including omission of important radionuclides (lodine-129, Chlorine-36 and Cobalt-60), unrealistic RADTRAN assumptions including inadequete consideration of severe accidents, ouetart assumphons from NUREG-0170 and WASH-1238 including the failure to consider the degradation of cladding during extended dry storage, and failure to consider the rail-heavy haul truck option.

1 Response: With regard to the radionuclides, as indicated in Table 2 et Addendum 1, Cobalt-80 is considered. While both lodine-129 and Chionne-38 are long lived, neither is a significant contributor to overall does. lodine-129 has a very low specific activity and Chlorine-36 is a beta emitter.

The leeue of the severity of accidents considered in the NRC staff's. analysis was-addressed in an earlier response to comment. The assumptions that are used. in the NRC 1 staff's analysis have been penodically renewed and found adequate. The hypothetical I accident conditions of 10 CFR 71.73 have been evaluated against actual conditions  !

encountered in highway and. railway accidents and were found to be bounding as documented in NUREG/CR-4829, February 1987, " Shipping Container E ;+,ee to Severe Highway and Railway Accident Conditions." As noted in Table 3 of Addendum 1, the version I of RADTRAN used is igw4atart to March 1999.

Section 3 of Addendum 1 does consider the poemble effect of.ciaddag degradation on criticanty in the context of increased bumup. That analysis would be equaNy applicable to any cladcAng degradation that might occur during prolonged dry storage of the SNF,.

Wah regard to what is asserted to be inadequate consideration at the potential radiological impacts of the rail-heavy haul truck option, the NRC staff has analyzed the radiological impacts of the truck mode along vanous routes through and around Las Vegas and concludes that they are the limiting soonanos. The largest doses in the incident-tree contations are now to the public. If the rail-heavy haul transport scenario was atinpaart a 49 NUREG-1437, Mand =n 1

. . . I

VLD G:\DPR\PART51 July 30,1999 (3:15PM)

OPA DRAFT i (Source: SECY )

NRC AntENDS ENWRONRCENTAL REWEWS TO RENEWNUCLEAR POWER PLANTOPERA7MG LJCENSES To inctuoi ceAsocettobrJ OF Lefrn h 7ttMseostmnd w+cr.s f The Nuclear Regulatory Commission is amending its regulations goveming environmental reviews of applications for renewal of nuclear power plant licenses.

The amendment to Part 51 of the NRC's regulations would make two changes:

(1) It eliminates the requirement that indMdual license renewal applications address one specific type of environmental impact caused by spent nuclear fuel generated by the plant during the term of the renewed license - the impact of moving that fuel from a specific plant to a permanent high level-waste repository, such as the one proposed at Yucca Mountain, Nevada. The amendment also accounts for the environmental impacts of transporting fuel with higher uranium enrichment and higher "bumup," which provides more power production per metric ton of fuel than has previously been the case.

~3 9 (2) It adds n' requirement that a license renewal application address the impact of transportation on local services in the. vicinity of the plant during the license renewal term.

Regarding the first change, new studies have given the NRC confidence that the fucA ^5 ut s.

X.~ expected environmental impact of transporting spent fuel from all plant sites to a can 4

.be handed generically - that is, in a way that applies to the whole nuclear industry, rather than focusing on each specific site at the time its license renewal application is undergoing NRC review new =h ream, which also deal with the use of more highly enriched fuel and higher burnup fuel, are described in a final addendum to the generic environmental impact statement for license renewal which is also bemg issued. Ramm more nucitar poWor plants are beginning to use fuel with higher enrichment and higher bumup, it was necessary for NRC to evaluate this change at these higher levels. The NRC believes it likely that many plants seelong license renewal will be following that practice.

The second change is consistent with tlw findings in NUREG-1437,"Genonc Erwisonmental impact Statement for License Renewal of Nuclear Plants," issued in May 1996, to address local traffic impacts attributable to continued operation of the plant during the liesnee renewal term. Thl- issue was identified in the NUREG document for inclusion in the rule, but was inadvertently omitted from the 1996 version.

Although the public comment period on the proposed rule officially ended on April 27, in response to concems raised about the length of the 60-day comment period, NRC considered comments received as late as July in preparing the final rule.

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