ML20126E400

Responds to Re Partial Enrichment of Fuel Rods W/Recycle Pu Instead of U-235 Per Amend 4 & Change 34. Discusses Pu Use Hazards Considerations Litigation,Amend 4 Proceedings & GEIS Preparation Re Pu Fuel Use

ML20126E400
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	04/27/1973
From:	Giambusso A US ATOMIC ENERGY COMMISSION (AEC)
To:	Reizen M MICHIGAN, STATE OF
Shared Package
ML20126E404	List: ML20126E400 ML20126E406 ML20126E409 ML20126E411
References
NUDOCS 8101270256
Download: ML20126E400 (12)

Text

cs c x APR 2 71973 I, Docket fio. 50-155 Maurice S. Reizon, M. D., Director Michigan Department of Public Health State of Michigan 3500 North Loga, Lansing, Michigan A%14

Dear Dr. Reizen:

Your letter of March 16, 1973 to Chairman Ray concerning partial en-richment of the Big Roci: fuel rods with recycle plu*, onium instead of uranium 235 as described in Change fio. 34 and Ar:ent.aant No. 4 (dated Deceder 6,1972) ferred to me to Facility Operating License M. DPR-6, has been re-for reply.

Your letter questioned our conclusion that Amendaent No. 4 does not in-evaluated because "there is uncertainty actong sci tthe amendment pemits an increase in plutonitc inventory from M to tonium fuel usage in comercial reactors".150 kilograms and the case of West Michigan Environmental , et al.,

Action Ci i

Docket of No.

Michigan. G 50-73, in the U. S. District Court for the Western District is not the view of the regulatory staff of the Atomic Ene i For your infonnation however, we are enclosing a copy of the December l .

1972 staff memorandum which documents the finding of no significant h ,

ards considerations different fmm those previously evaluated. i Your letter requested that *a new license be renuired for the operation  :

of this and safety, plant with plutoniten environmental criteriafuel which will necessitate a complete healt!

review".

health and safety issues for persons offsite in the event of incident".Yo ,

by the Commission's regulations.For tTis use of plutonium fuel, a c!  !

Rather an amendment to such license l is considered the 4;propriate manner in which to account for the chang to authorize this plutonium fuel and, accordingly, an amendment to DPR-6 wasi issued W' " p ;e a /L ,

to such use.

Because of the public interest which has been 9' 1

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Maurice S. Reizen, H. D. .

i shown concerning this amendment, the Comission has offered an oppor-j- tunity for hearing on the amendment. - A copy of that notice, published in the Federal Register on April 10,1973 (38 F.R. 9104), is enclosed for your infomation and guidance, should you desire to. participate in the proceedings. In the event that you desire to so participate it is incumbent- that you comply with the requirements set forth therein and the Comission's Regulations,10 CFR Part 2, in particular 10 CFR Section 2.714, a copy of which is enclosed.

In regard to the broader question concerning the use of plutonium fuel, you may be interested in our plant to prepare a generic environmental survey concerning the plutonium fuel cycle. These plans were discussed in our recent testimony regarding the tiranium Fuel Cycle before an Atomic Safety and Licensing Board. The specific reference is pages 130-136 of Docket PM-50-3 on Thursday, February 1,1973, copy enclosed. We expect to complete the plutonitsn fuel cycle statement and hold a hearing in 1974. In this respect it may be of interest to you that we have been advised, in conversations with the Consumers Power Company, that Consuners does not plan to operate Big Rock with a core containinq more than 50 kilograns of plutonium recycle fuel until after 1974 If we can be of further assistance, please let us know.

NMdd g r 1 I nad by

-b br/ e Rcia S. 5010 A u/(ca hr*- hz/s ar ' *

p. , ,, , g g y y A. Giambusso, Deputy Director M M[ I' for Reactor Projects 1

M I 2 ),4 . m s/ trectorate of Licensing sureY

1. Memo dated 12/6/72 '8M 2.

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Notice Transcript RM-50-3, pp.130-136

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Docket No. 50-155 Maurice S. Rei n, M. D. , Director MichiganDepartkutofPublicHealth State of Michigad s 3500 North Iogan Lansing, Michigan 8914

Dear Dr. Reizen:

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We have reviewed your le ter to Dr. Ray (da/ ted March 16,-1973) concerning partial enric1xcent of the ig Rock Point.' fuel rods with recycle plutonium instead of uranium 235 as scribed in Khange No. 34 and Amendment No. 4 (dated December 6,1972) to cility Operating License No. DPR-6.

Your letter questioned our conc usicy that Amendment No. 4 does not involve significant hazard consi erations different from those pre- '

viously evaluated because "there uncertainty among scientists" and because "the amendment permit / n increase in plutonium inventory from 50 to 150 kilograms and con tit tes the first licensure for significant plutonium fuel usag in amercial reactors". As you are no doubt aware, these part lar i sues are now the subject matter of litigation in the case of West Michi an Environmental Action Council v. AEC, et al. , Dockef No. G 58- , in the U. S. District Court for the Western Distript of Michigan .in view of this liti-gation, it would te inapproptiste for us to iscuss these allegations in detail at this time. For your information, however, we are enclosing a copy of h.se December 6, )972 memorandum of J s J. Shea which documents , c findita of no significant hazards iderations different from those previously eva'1uated.

Your letter requested t t "a new license be required for the operation of this plant with plutchium fuel which will necessitate a complete health, safety, and env}ronmental criteria review". Your request la " based upon health and safety issues for persons offsite in event of incident". For this[use of plutonium fuel, a completely new license was not required, rathet an amendment to DPR-6 was issued to authorize such use. Because of the public interest which has been shown concerning w---, i,pm ,,f..p..r- eiw-g., w- w..,%+- ,,.- ,,-- yw ,i3e-,+rew y,.,-pg. yap. e p q. + ,-,s .

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I liaurice S. Reizen, M. D. 3. The restYictions on the amount of plutonium e chment result in a maximum plutonium inventory accumulation in,the core that is approximately three to four times the plutorylum inventory resulting from the production of plutonium from irrapiation of uranium 238 during reactor operation with U-235 enricKed fuel only. The change in fission product inventory resuf ting from the fissioning of recycled plutonium and the noted'ingfease in the plutonium inventory do not cause significant changes to the calculated radiation dose rates during normal oy' accident conditions. The recognized small. increase in I-131 yroduction is partially offset by the expected improvement in clad integrity. The fission products released to via the primary coola%e nt gand atmosphey'e air jector willduring normal by be restricted operation the limits specified in the AE pproved Technical Specifications that have been in use for \he st decade at Big Rock Point.

\

It should be noted that plant modi ications to be completed during the 1974 outage are expected to resul,Qn full conformance to the AEC Interim Acceptance Criteria for et ,ency Core Cooling Systems for the new Reload G fuel bundles.

Your letter stated that in your opinion the use of plutonium enrichment in the manner and quantities s'uthorized ~or Big Rock Point could change the public health andpafety critel a for normal operation and materially increase the otential publ hazard in event of an incident because " plutonium fuel is more to e than the conventional uranium core composition an its physical pro rties make it one of the most difficult elemen ' to control".

Plutonium is produced in 11 uranium-fueled reacto and has been considered in the safety evaluations of these reactolg. Under normal operating conditions, e plutonium oxide is confined w4 thin the sirealoy cladding. To ate there is no evidence in any 'a the oper-sting power reactors of excessive levels of uranium oxide (br plutonium oxide having escaped to the primary coolant system even though measurable quantities f fission gases have been released from some fuel rods with defect a cladding. In addition to the safety con-siderations, escape ofs significant quantities of uranium or plutonium into the coolant could not be tolerated for the practical reason that cleanup costs to permit routine maintenance and surveillance would be excessive. During normal operation with plutonium enriched fuel, it is impossible for the plutonium to become airborne. When the

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l Maurice S. Reizen, M. D. I

( i full conversi of the Big Rock Point core to the plutonium oxide bearing fuci is completed s (some time af ter 1978), the core will contain no more than 300xpounds of plutonium isotopes compared with about 25,;00 pounds of branium. In the dilute oxide form to be.used in the Big Rock Point cort, temperatures well in excess of the, fuel melting temperature of about 5000'F would be required to cause' ' noticeable vaporization of plut' onium oxide.

\ obability design We have determined that for the most extreme low I basis accident, the release of plutonium to the tmosphere is acceptably within 10 CFR 100 guidelines, and the fission products released from the plutonium enriched core continue to be th,e limiting factors in assessing the potential risk of radiation exposure to the public.

\ /

Your letter stated that "the Hazards Summary Report did not consider theuseofplutoniut.fuelanhanenvironmentalimpactstatementhas l not been submitted for the ophration of the Big Rock Point plant".

/

The Big Rock Point reactor has een operating for more than ten years in accord with Technic.11 Specifi ations issued by the AEC that include ,

1 limits on radioactivity released o ,the environment that satisfy the 3 ,,

requirements of 10 CFR 20. The ba is for the technical specifications ,'

limits on radioactive releases to the atmosphere were derived from l.,J l l

the Big Rock Point Harards Summary' d port which included consideration I I

of the eff ects of all radionuclides p esent, including plutonium. I Although not labeled " Environmental act Statement", our evaluation did encompass such cont.ideration' for th site as it exists today with ~

an installed, licensed nuclear sover pla t. i f f The change from a current plutonium invent ry of about 88 pounds to )

an inventory of about 300 poupids of plutoni m isotopes over a four- l year period does not signifipantly change th calculated radiation doses to the public in the shant of an accide . Kalasse of fission ,

l products remains the limiti's f actor in assess g the accidsnt radiation hazards to the p lic.

Your letter requested tha "a new license be requi d for te.

the operation a complete J

of this plant with plutodium fuel which will necessi eur request )

health, safety, and environmental criteria review". s 1 is " based upon health and safety issues for persons offsite in event of incident". \

- 6. 6 Maurice S. Reizen, M. D. -

\

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The license has been changed by Amendment No. 4 to Facility License No. DPR-6, bas Ad on our evaluation, to authorize an in' crease from 50 kilograms to 50 kilograms in the amount of plutonium that can be received, posses % sed,andusedinconnectionwith 'eration of the Big Rock Point fac'111ty. Our evaluation of thi hange considered the health, safety, theincreasedpluto\andenvironmentalconsidertonsassociatedwith nium authorization. There is no evident justifi-cation to review all ther (non-plutonium r ated) aspects of reactor operation. We have, i effect, accomplish d by a change to. the license what you suggest accomp ishing by issuin a new license.

Since ely, A. Giambusso, Deputy Director for Reactor Projects irectorate of Licensing Distribution Chairman Ray (2)

Commissioner Ramey Commissioner Larson /

n Commissioner Doub i

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Maurice S. Reizen, M. D., birector Michigan Department of Public Health i State of Michigan s 3500 North Logan i Lansing, Michigan 48914,

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Dear Dr. Reizen:

We have reviewed your lette to Dr. Ray (pated March 16, 1973)- concerning partial enrichment of about 0%oftheBptRockPointfuelrodswith that has been used in all of recycle the fuelplutonium instead rei roda of approved of ranium d fuel 23) n dles prior to authorization of Change No. 34 and Amendment}(o. 4 ated- December 6, 2972) - to ,

Facility Operating License No. WR-6.

Your letter questioned our conc 1 ion that Amendment No. 4 does not involvesignificanthazardconsidefstionsdifferentfromthosepre-viously evaluated because "there $t neertainty among scientists" and because "the amendant permity an neresse in plutonium inventory from 50 to 150 kilograms and constitute the first licensure for significantplutoniumfuelusag[incomm cial reactors".

l The bases for the AEC conclus n that there re no significant hazard considerations dif f erent from those previous 1 evaluated are: t

1. The Reload G fuel bund containing an 11 s11 fuel rod configu-ration instead of the f x 9 fuel . rod array in current use results in reduced fuel tempeystures during normal and accident conditions. ,

The reduced fuel temp'eratures, in addition- to other design and f abrication improvements of the fuel pellets, will anhance fuel r rod clad integrity; f.e., reduce further the potential for leakage of fission products from the fuel into the coolant.

2. The limit of 24 plut' onium enriched rods per bundle positioned  ;

around the unpowered center rod prevants significant neutronic changes or uncertainties that could affect predicted core behavior  :

or reduce the dynamic safety margins. l 1

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_ __. ._ n _ . , _ _ ._. _-._. _ _. _ _.._ .. _ _ _ _ ._. _ _ _ _ . ,

Maurice S. Reisen, M. D. ,

this amendment, the t h ission has offered an opportunity for hearing on the amendment and has designated an Atomic Safety and Licensing Board to receive and rule en requests for such a hearing and/or petitions for intervention in such a hearing. A copy of that notice, published in the Federal Register on April 10, 1973 (38 F.R. 9104),

is enclosed for your information and guidance, should you desire to participate in he further proceedings.

With regard to th broader question concerning the use of plutonium fuel, you may be terested in our plans to piepare a generic fuel cycle statement.for lutonium fuel. These plans were discussed in our recent testimony regarding the Uraniumguel Cycle before an Atomic Safety and Lic ing Board The spfecific reference is pages 130-136 of Docket BM- -3onThuredzy,rpruary1,1973. We expect to complete the plutonih fuel cycle statement and hold a hearing in 1974. Although the pkecise dates fo'r the stetsment'and hearing have not yet been establihhad, we have' been advised, in conversations with your staff and with the Consumers Power Company, that Consumers does not plan to operate Big Rock with a core containing more than 50 kilograms of plutoniwa r yele fuel until af ter 1974.

If we can be of further assist , please let us know.

i Sincaroly, A. G ambusso Deputy Director fo Reactor Projaets Dirac rate of Licensing- ,

Raciosures:

1. Memo fa JJ5hea dtd 12/s/72

2. . Notice 3 10 CFR Part 2 Distribution GCunn gham, OGC (G-town)

Ehughe , L:RP JHendrie, L:TA -

Chairman Ray (2) RP ' Reading SSmiley, L:El

• Commissioner Ramey Branch Reading JScinto, OGC '

Commissioner Larson JF0' Leery, L DJSkovholt,'L OR SEE ATTACHED y HShapar, OGC TJCarter, L:0R YELLOWS FOR CON , -

Commissioner Doub DLZiemann,k:0RB2 Docket File AGiamb2sso, L:RP CURRENCES:

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Docket No. 50-155 Haurice S. Re\sen, H. D. , Director Michigan Depart' ment of Public Health State of Michigan s 3500 North logan \

Lansing,..ichigan 48914

Dear Dr. Reizen:

\

\

We have reviewed your letter to Dr. Ra (dated March 16, 1973) concerning partial enrichment of the Big Rock Po t fuel rods with recycle plutonium instead of uranium 235 as described Change No. 34 and Amendment No. .

(dated December 6,1972) to Facilit Operating License No. DPR-6.

\

Your letter questioned our concip on that Amendment No. 4 does not involve significant hazard consi rations different from those pre-viously evaluated because "ther i's uncertainty among scientists" and because "the amendment pe es b increase in plutonium inventory from 50 to 150 kilograms and nstit es the first licensure for significant plutonium fuel u ge in co ercial reactors". As you are no doubt aware, these pa icular is es are now the subject matter  :

of litigation in the case o West Michiga Environmental Action l I

Council v. AEC, et al., uo et No. G 58-73, in the U. S. District Court for the Western Dis ict of Michigan. n view of this liti-gation, it would be inapp opriate for us to d cuss these allegations l in detail at this time. For your information, ever, we are enclosing l a copy of the December , 1972 memorandum of Jane J. Shes which 1 documents the finding o no significant hszards co iderations I different from those p eviously evaluated.  !

i i Your letter requested that "a new licenas be required for the operation l I

of this plant with plui onium fuel which will necessitate a complete health, safety, and en ronmental criteria review". Your request is " based upon health and safety issues for persons offsite in event

• of incident". The statutory framework of the AEC provides for amend-ment of licenses, rather than issuance of new licenses, when changes l

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Maurice S. Reisen, M. D. -

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in operation are proposed. That course was followed with the issuance of Amendment No. 4 to Facility Operating License,No. DPR-6. Because of the public ingerest which has been shown co erning this amendment, the Connission hah offered an opportunity for earing on the amend-ment and has desi tad an Atomic Safety an censing Board to receive and rule on requests for such a hearing an /or petitions for inter-vention in such a hea ing. A copy of t notice, published in the Federal Reg,ister on Ap 1 10, 1973 (38 .R. 9104), is enclosed for your information and gu ance, should ou desire to participate in the further proceedings.

S neerely,-

\

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A. Giambusso, Deputy Director for Reactor Projects Directorate of Licensing

Enclosures:

2. Memo'im JJShea dtd 12/6/72

2. Notice

3. 10 CFR Part 2 Distribution s Chairman Ray (2)

Commissioner Ramey Commissioner Larson Commissioner Doub Docket File AEC PDR L Reading RP Reading Branch F.eading DLZiemann, L:0RB #2 l

JF0' Leary, L JJShea, L:0RB #2 HShapar, OGC RMDiggs, L: ORB #2 AGiambusso, L:PJ' JMHendrie, L:TR GErtter, DRA (#5448)

' MGroff, DRA EHughes, L:RP JScinto, OGC .

DJSkovholt, L:0R k e_ -

TJCarter, L:0R  %%

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Maurice S. Reizen, M. D., birector Michigan Department of Public Health State of Michigan \

3500 North Logan \

Lansing, Michigan 48914,

Dear Dr. Reizen:

We have reviewed your lette to Dr. Ray (pated March 16, 1973) concerning partial enrichment of about 0%oftheBptRockPointfuelrodswith recycle plutonium instead of ranium 23 that has been used in all of the fuel rods of approved rel d fuel udies prior to authorization of Change No. 34 and Amendment o. 4 sted December 6,1972) to Facility Operating License No. R-6.

Your letter questioned our conclu on that Amendment No. 4 does not involve significant hazard conside tions different from those pre-viously evaluated because "there j ' neertainty among scientists" and because "the amendment permit an neresse in plutonium inventory from 50 to 150 kilograms and con titute the first licensure for significant plutonium fuel usag in comm cial reactors".

The bases for the AEC conclusion that there re no significant hazard considerations diff erent from/those previous 1

1. The Reload G fuel bund an containing %e/ \ evaluated are:

11 gli fuel rod configu-ration instead of the f x 9 fuel rod array in current use results in reduced fuel tempeyatures during normal and accident conditions.

The reduced fuel temp,Aratures, in addition to other design and f abrication improve nts of the fuel pellets, will enhance fuel rod clad integrity; .e., reduce further the potential for leakage of fission products rom the fuel into the coolant.

2. The limit of 24 plut' onium enriched rods per bundle positioned around the unpowered center rod prevants significant neutronic changes or uncertainties that could affect predicted core behavior or reduce the dynamic safety margins.

- um

I Maurice S. Reisen, M. D. 3. . The resttictions on the amount of plutonium en cheent result in a maximum plutonium inventory accumulation in the core that is approximately three to four times the pluto um inventory resulting from the production of plutonium from irrap ation of uranium 238 during reactor operation with U-235 enric ed fuel only. The l change in fission product inventory res ting from the fissioning I of recycled plutonium and the noted ing ease in the plutonium inventory do not.cause significant ch ges to the calculated radiation dose rates during normal o accident conditions. The recognized small i'acrease in 1-131 oduction is partially offset by the expected imphovement in claf integrity. -The fission products released to the atmosphe7e during normal operation via the primary coolantgand air jector will be restricted by the limits specified in e AE pproved Technical Specifications that have been in use for he at decade at Big Rock Point.

It should be noted that plant mod ications to be completed during the 1974 outage are expected to resul, n full conformance to the AEC Interim Acceptance Criteria for e ency. Core Cooling Systems for  ;

the new Reload G fuel bundles.

Your letter stated that in yo y opinion the use of plutonium enrichment in the manner and quantities authorized or Big Rock Point could change the public health and hafety crite a for normal operation andmateriallyincreasethefotentialpubl hazard in event of an incident because " plutonium, fuel is more to e than the conventional uraniumcorecompositionafitsphysicalpro rties make it one of the most difficult elements to control".

Plutonium is produced in 11 uranium-fueled reacto . and has been considered in the safety evaluations of these reactolg. Under normal operating conditions, e plutonium oxide is confined within the aircaloy cladding. To ate there is no evidence in any'a{ the oper-ating power reactors of excessive levels of uranium oxide 'or plutonium oxide having escaped to the primary coolant system even though measurable quantities f fission gases have been released from some fuel rods with defect a cladding. In addition to the safety con-siderations, escape ofs significant quantities of uranium or plutonium into the coolant could not be tolerated for the practical reason that f cleanup costs to permit routine maintenance and survaillance would be excessive. During normal operation with plutonium enriched fuel, it is impossible for the plutonium to become airborne. When the mis

Maurice S. Reizen, M. D. .

r full conversi of the Big Rock Point core to the plutonium oxide bearing fuel is completed s (some time af ter 1978), the core will contain no more than 3003 pounds of plutonium isotopes compared with about 25,J00 pounds of branium. In the dilute oxide form to be used in the Big Rock Point core, temperatures well in excess of the, c fuel melting temperature of about 5000*F would be required to cause noticeable -

vaporization of plut' onium oxide.

\ /

f' We have determined thdt for the most extreme low probability. design basis accident, the release of plutonium to theptmosphere is acceptably within 10 CFR 100 guidelines, and the fission products released from

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the plutonium enriched core continue to be the limiting factors in assessing the potential risk of radiation es;p'osure to the public.

\ /

Your latter stated that "thd Hazards Sununary Report did not consider the use of plutonium fuel anh an environmental impact statement has ~

not been submitted for the ophration of the Big Rock Point plant".

The Big Rock Point reactor has een operating for more than ten years in accord with Technical Specifi ations issued by the AEC that include limits on radioactivity released o the environment that satisfy the  ;,

requirements of 10 CFR 20. The ba is for the technical specifications '

limits on radioactive releases to the atmosphere were derived from i the Big Rock Point Hazards Summary lleport which included consideration oftheeffectsofallradionuclidespjesent, including plutoaium.  !

Although not labeled " Environmental impact Statement", our evaluation \

did encompass such consideration for tii site as it exists today with "-~

an installed, licensed nuclear hover pia t.

I The change from a current plut' onium invent ry of about 88 pounds to an inventory of about 300 pounds of plutoni isotopes over a four-year period does not significantly change th calculated radiation dosestothepublicinthefantofanaccide . Release of fission products remains the limiti g f actor in assess g the accident radiation hazards to the p lic.

Your letter requested ths, "a new license be requi d for the operation of this plant with plutodium fuel which will necessi te a complete health, safety, and environmental criteria review". eur s request is " based upon health and safety issues for persons offsite in .

event of incident".

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