ML25196A438
| ML25196A438 | |
| Person / Time | |
|---|---|
| Issue date: | 11/17/1976 |
| From: | Moeller D Advisory Committee on Reactor Safeguards |
| To: | Rowden M NRC/Chairman |
| References | |
| Download: ML25196A438 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, D. C. 20555 Honorable Marcus A. Rowden Chairman November 17, 1976 U.S. Nuclear Regulatory Commission Washington, OC 20555
SUBJECT:
REPORI' ON THE FINAL GENERIC ENVIRONMENTAL STATEMENr ON THE USE OF RECYCLE PIDI'OtIUM IN MIXED OXIDE FUEL IN LIGHT WATER COOLED REACTORS -
HEALTH, SAFETY AND ENVIRONMEN'.l'
Dear Mr.. Rowden:
In response to the letter of January 13, 1976, fran Chairman Anders, the Advisory Conmittee on Reactor Safeguards corrpleted, at its 199th meeting, November 11-13, 1976, a partial review of the Final Generic Environmental Statement on the Use of Recycle Plutonium in Mixed Oxide Fuel in Light Water Cooled Reactors - Health, Safety and Environment (NUREG-0002).
This subject was also considered at meetings of the Environmental Sub-conmittee with the NRC Staff in Washington, D.C., on April 21, Jl.llle 11, and November 5 and 6, 1976.
In the course of its review, the Committee has noted several areas which appear to be in need of greater discussion and evaluation. These are enumerated below.
Nature and Evaluation of Environmental Releases of Plutonimn and Other Transuran1cs The major difference in the use of mixed oxide fuel in conmercial nuclear power plants will be the greater quantities of plutonimn and other trans-uranic nuclides which must be handled at various steps in the fuel cycle.
NUREG-0002 states that airborne releases of these nuclides will be a primary factor in determining the associated impact on the environment and the neighboring populations, but fails to include quantitative estimates of such releases. The Committee reconmends that such infor-mation be provided.
For airborne releases from mixed oxide fuel fabrication plants, assmiqr tions made by the NRC Staff lead them to an estimated maximum annual dose rate to the bone of an individual living at the site boundary of 0.171 rem.
Because this dose rate is large in comparison to the "As Low As Reasonably Achievable" (ALARA) regulatory requirements for conmercial nuclear power stations (and potentially for other facilities within the fuel cycle), the Conmittee anticipates that future licensing specifica-tions may require substantially improved effluent control systems for 2679
Honorable Marcus November 17 9 1976 mixed oxide fuel fabrication plants. The Camnittee also notes, however, that this dose rate ~stimate would have been much lower if most of the airborne plutonium releases for such plants had been assl.Dlled to have been in an insoluble state. The Camnittee believes that it would be helpful if the existing report could be supplemented by sensitivity studies to indicate ha,, assumptions on the chemical form of this nuclide affect dose rate estimates. To the extent possible, the Cormnittee suggests that data used in reaching conclusions regarding the impact of plutonium recycle be based on realistic assumptions.
The AI.ARA Criterion and Assumed State of Nuclear Technology In line with the attention being directed by the NRC Staff to the AI.ARA criterion, the Camnittee expected that the projection of conditions from 1975 through 2000 would include reasonable assumptions on changes in manufacturing and operating practices and on inprovements in the state of the art of process control, radiation control, and environmental control which might evolve during this period. It is not clear, however, that such changes and improvements have been projected uniformly for each step within the fuel cycle. For example, specific inprovements have been pro-jected with respect to occupational exposure control in nuclear po.,,er plants and with respect to effluent control systems for fuel fabrication and fuel reprocessing plants. By contrast, the assumption with regard to the control of wastes and effluents from "uranium operations" (which estimates show will be the major contributor to population dose regardless of which fuel cycle option is selected) is that current procedures will continue.
The Conmittee believes that the usefulness of the report would be enhanced by the addition of a descriptive section expressing the views of the NRC Staff on what might be considered state of the art (in the sense of awlicable good co:nmercial practices) by 5 to 10 year increments during the time span from 1975 through 2000. Included in such projections should be semi-quantitative sensitivity analyses of how each of these changes might affect the associated environmental impacts and population dose estimates.
Applicability of the Person-rem Concept Person-rem calculations are used throughout the NURE<r0002 docwnent as a means for estimating the "health effects" on the population of the dif-ferent fuel recycle options. The estimates of population effects are based on an assumed linear relationship between dose and resulting radiobiological 2680
Honorable Marcus November 17, 1976 consequences.
The Committee believes it should be recognized that there is not universal agreement that "health effects" bear a linear relationship to dose. The Committee recommends that an acknowledg-ment of this issue be included in NUREG-0002.
Consideration of All Dose Pathways Most estimates in NUREG-0002 cover only the dose commitment to in-dividuals which results from exposure to the immediate radionuclide release from a given nuclear facility. Consideration of other path-ways to man may be important, particularly for releases involving long-lived radionuclides. Since these other pathways may be important on a long-term basis, the Committee recommends that they be carefully as-sessed in terms of their potential implications in evaluations of the relative impact of the several fuel cycle options.
The Committee will continue to follow progress in the NRC Staff's evaluations of the health impact of the several fuel cycle options and will provide additional comments as appropriate.
REF*':RENCE:
Sincerely yours, f)~V,o/JI/~
Dade w. Moeller Chairman NUREG-0002, Final Generic Environmental Statement on the Use of Recycle Plutonium in Mixed Oxide Fuel in Light Water Cooled Reactors - Health, Safety and Environment.
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