ML25097A224
| ML25097A224 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland (SNM-1227) |
| Issue date: | 02/20/2025 |
| From: | Office of Nuclear Material Safety and Safeguards |
| To: | |
| Shared Package | |
| ML25097A221 | List: |
| References | |
| Download: ML25097A224 (1) | |
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RSI 1 - Environmental Report INFORMATION NEEDED:
A. The Environmental Report (ER) provided with the LAR states that there would be no changes in any effluent released off site without additional explanation. In addition, the ER proposes no changes to the environmental measurement and monitoring requirements.
Information Needed: Please discuss both radiological and non-radiological emissions associated with the LAR or provide an explanation why no additional effluents occur. This information will be used to evaluate impacts in an environmental review.
Framatome Response:
Radiological air emissions will continue to be monitored via the existing stacks. No new non-radiological constituents will require monitoring. Monitoring for NOx will be performed as it is in other areas where NOx is released. The following highlighted text is added to section 4.7 of the E06-24-002 (The ER supplement):
The proposed license amendment will not result in significant air quality impacts at the Framatome FFF. Radioactive air emissions will not be significantly different than they were with past processes in the SF Building. The addition of TRISO Fuel manufacturing will not produce new non-radioactive emissions that require monitoring.
Liquid effluent discharged to the municipal sewer will continue to be monitored for compliance with limits imposed on radiological and non-radiological constituents. The following highlighted text is added to section 4.5 of the E06-24-002 (The ER supplement):
The increases in plant enrichment and adding a TRISO based fuel line in the SF building will not significantly impact this effluent because the same Dry Conversion technology will be used in producing UOx feed to the TRISO process. The TRISO process does not produce any new liquid effluents. The elimination of legacy lagoon inventory processing has reduced the sewered effluent volume by approximately 15,000 gallons per day.
B. The ER states that all construction activities would be within the Specialty Fuel (SF) Building. Any equipment brought to the site would travel on the current roadway system and will be delivered by commercial sized/flatbed truck and that there would be no ground-dis Information Needed: Please provide an estimate for the change in traffic for facility construction and operation compared to the current activities.
Framatome Response:
The following highlighted text is added to section 4.2 of the E06-24-002 (The ER supplement):
The replacement of previous processes within the Specialty Fuels building with the addition of a TRISO fuel manufacturing capability will not have any significant traffic impact. The incremental impact of the proposed action will not significantly increase the current level of traffic due to personnel vehicles or material transport. Section 3.2 lists levels of traffic in the general area. A combined number of inbound and outbound trucks for Framatome is currently about 500 trucks per year. This amounts to less than two trucks per day. The delivery of new equipment to be installed in the SF building is expected to be less than 100 deliveries during the two year installation phase. The expected shipments of advanced reactor fuel to customers is expected to be less than 100 per year during the first 5 years of production. This anticipated increase will still average less than 2 trucks per day. Transportation routes will not change for operation of the proposed new process. The quantities and types of materials will not significantly change and there will be no additional entrances for construction.
C. The ER states that there will be no significant changes to public and occupational health and that Framatome currently conducts monitoring programs as outlined in the submittal. Framatome states that all results of the monitoring program comply with acceptable standards.
Information Needed: Please provide additional explanation why there will be no changes to a monitoring program due to adding a new process or provide information to support that the current monitoring program is sufficient. If this information is found outside of the ER, please make this information available for inclusion into an environmental evaluation.
Framatome Response:
The following highlighted text is added to section 4.13 of the E06-24-002 (The ER supplement):
The exposure pathways described here may be categorized into three general pathways that could affect the general public: direct irradiation; radioactive airborne effluents; and radioactive liquid effluents from the Framatome facility. Direct irradiation is measured by monitoring gamma radiation levels at the Framatome site boundary. Doses from airborne effluents are determined by monitoring stack emissions for each individual stack and doses from liquid effluents are determined by measuring concentrations of uranium in liquid effluent which includes uranium and Tc-99. Framatome also monitors groundwater at various locations on the site. No changes to the monitoring program will be made because no new air emission stacks nor liquid discharge points will be added and their will not be any new non-radioactive constituents that require monitoring.
D. The ER does not discuss the potential beneficial benefits to local socioeconomics.
Information Needed: Please provide, if appropriate, potential benefits to local socioeconomics including potential jobs and economic impacts.
Framatome Response:
This information is included in section 7.2 of the E06-24-002 (The ER supplement). The highlighted text is added to this section:
The average per capita income in Benton, County Washington in 2023 was $39,668. The average Framatome 2023 salary is $104,7292, which greatly exceeds the local per capita income. This demonstrates Framatomes' positive influence on the socioeconomics of Benton County. The addition of the TRISO based fuel processes will add <20 employees during equipment design and installation and testing and <20 employees during normal operations.
E. The LAR does not discuss whether the new process may generate additional non-radiological waste.
Information Needed: Please update the ER discussion of potential waste stream changes or if there are no new waste generated, please state that.
Framatome Response:
This information is included in sections 3.9.1 and 4.14 of the E06-24-002 (The ER supplement). The highlighted text is added to section 3.91:
Framatome processes currently generate liquid waste, solid waste, and airborne effluents. Solid waste includes obsolete equipment and hardware, used ventilation filters, used personal protective equipment, waste treatment residues/filter cakes, demolition debris, and miscellaneous combustible waste. No new waste categories (radiological or non-radiological) will be generated with the addition of TRISO fuel fabrication.
The highlighted text is added to section 4.14:
NRC staff evaluated the waste management environmental impacts associated with storage and/or transportation of Framatomes low-level radioactive and hazardous wastes as part of the license renewal review. Framatomes waste management program will not change for implementation of the new process as requested in the license amendment. No new waste categories (radiological or non-radiological) will be generated with the addition of TRISO fuel fabrication. The NRC Staff considered in their license renewal review: long-term disposal; on-site storage; and the applicants waste reduction strategies.