ML20210C322
| ML20210C322 | |
| Person / Time | |
|---|---|
| Issue date: | 02/11/1986 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML20210C328 | List: |
| References | |
| FOIA-86-497, TASK-RINV, TASK-SE SECY-86-049, SECY-86-49, NUDOCS 8603240239 | |
| Download: ML20210C322 (37) | |
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- I W( ) t LL M/ sj'pp QwjgI RULEMAKING ISSUE February 11, 1986 SECY-86-49 For: The Commissioners From: Victor Stello, Jr.
Acting Executive Director for Operations
Subject:
PETITION FOR RULEMAKING SUBMITTED BY POLLUTION AND ENVIRONMENTAL PP.0BLEMS, INC., REQUESTING AMENDMENT TO 10 CFR PART 51, " LICENSING AND REGULATORY POLICY AND PROCEDURES FOR ENVIRONMENTAL PROTECTION"
Purpose:
To obtain Commission approval for publication of a Federal Register Notice denying the petition and to inform the Consnission that the staff is preparing an environmental assessment to address the petitioner's principal concern.
Category: This notation vote paper involves a minor policy question.
Background:
On March 17, 1980, Ms. Catherine Quigg filed the subject petition for rulemaking with the NRC (Docket No. PRM-51-6) on behalf of Pollution and Environmental Problems, Inc. (Enclo-sureA). The petitioner's primary concern is with a potential future nationwide program of using high burnup fuel in nuclear reactors. In accordance with 10 CFR 2.802, the petitioner requested the NRC to amend 10 CFR Part 51, " Licensing and Regu-latory Policy and Procedures for Environmental Protection," to require the preparation of a generic environmental impact statement for high burnup nuclear fuel
- as used in commercial nuclear reactors, stored in spent fuel pools or cooling racks, or potentially as processed in reprocessing plants or disposed of in permanent waste disposal sites.
- The length of use, or total energy generated, or "burnup" of fuel in a reactor is measured in tenns of megawatt days per metric ton of uranium (Mwd /MtU) or Gwd/MtU where 1 Gwd/MtU = 1000 Mwd /Mtu. Typically, fuel has been removed from reactors after 3 to 5 years with burnup levels of 28 Gwd/MtU for BWRs and 1 33 Gwd/MtU for PWRs. "High" or " Extended" burnup nuclear fuel is considered, l for the purpose of this discussion, to be fuel that is left in a reactor long enough to achieve a burnup of greater than 40 Gwd/MtU. Burnup levels of up to about 60 Gwd/MtU are being considered.
l CONTACT:
M. R. Fleishman, RES -
443-7616 0 3 2 d'f' Q } f
, - _ _ - . -[$$P^' i
The Commis'sioners 2 The petitioner's secondary concern is with the existing limited DOE-initiated cost-shared high burnup fuel developmental projects being conducted in cooperation with five LWR fuel vendors licensed by NRC. The petitioner states that these limited develop-mental activities, which she believes could cause significant and widespread short- and long-tem effects on the human environment, are now being conducted without an Environmental Impact Statement.
The petitioner contends that the use of high burnup fuel could have the following significant_ effects upon the human environ-ment:
- 1. Greater fission gas releases from nuclear reactors,
- 2. Increased fission gas releases from spent fuel pools,
- 3. Creation of spent fuel of poorer cuality than present low burnup specimens which can lead to long term environmental hazards,
- 4. Potential for greater radiological impact from reactor and spent fuel pool accidents, and
- 5. Increased radioactive material releases during reprocessing.
Notice of receipt of this petition and request for public comment was published in the Federal Register on April 15, 1980 (45 FR 25557). Fourteen public coment letters were received.
Three comenters were in favor of the petition and eleven comenters opposed the petition. Almost all comenters provided technical support for their position and some provided a legal rationale as well. The staff evaluated all of the coment letters. A table cate attached (Enclosure B)gorizing the public comment letters is Discussion: 1. Developmental Procram and NEPA Requirements: To date NRC has approved individual license amendments which permit use of high burnup fuel in a limited demonstration mode at five reactors as part of a DOE-initiated, cost-sharing program.
NEPA analysis for license amendments focuses sharply on the application submitted by the utility rather than on broader generic environmental issues related to the general use of high burnup fuels. The Comission has found, in response to two earlier petitions by Ms. Quigg for the Zion plant *, that
- Commonwealth Edison Company (Zion Station, Units 1 & 2), DD-80-11, 11 NRC 496 (1980)
Comonwealth Edison Company (Zion Station, Units 1 & 2), 0D-81-2, 13 NRC 283 (1981)
' The Commissioners 3 such limited demonstration "use will not significantly affect the health and safety of the public or the quality of the human environment."
Based on review of the Environmental Assessment prepared by DOE (DOE /EA-0118, August 1980) for the demonstration program, the staff concluded that the cumulative impact of license amendments pemitting limited use of high burnup fuel is not significant. In addition permission for such limited use does not bind the Commission to subsequent approval for greater use of high burnup fuel. Thus, there is no unsatisfied NEPA requirement resulting from the license amendments necessary to the current phase of the DOE demonstration program.
- 2. Full Scale Commercial Use: The petitioner contends that these demonstration programs are harbingers of full scale commercial use of extended burnup fuels in U.S. reactors.
Data gathered by the staff (Enclosure C), and information such as that presented at.the American Nuclear Society .
topical meeting on " LWR Extended Burnup Fuel Performance and Utilization" held in April 1982, indicate that this contention is probably correct. For example, the U.S.
nuclear reactor demonstration program has burned over'3800 fuel rods to date to 40 Gwd/MtU or higher. Fuel manu-facturers contend that the design changes, combined with improved fuel management procedures are capable of extending burnup to 55 Gwd/MtU or higher. The licensing staff has evaluated topical reports from these fuel manufacturers (Babcock and Wilcox, Combustion Engineering, Exxon Nuclear Corporation, General Electric and Westinghouse) on this fuel. The evaluations were completed and the licensing staff did not uncover anything in their review that would lead the staff to believe that extended burnup is not licensable and there does not appear to be a particular burnup limit at which some substantial damage to the fuel could occur.
Preliminary results of the demonstration programs have already resulted in applications for license amendments for the use of fuels designed for higher burnups. Amendment Nos. 36 and 16 to North Anna 1 and 2, and Amendment Nos. 73 and 74 to Surry 1 and 2, issued January 19, 1982, allow theseplantstg3gadfuelwithenrichmentsincreasedfrom 3.7% to 4.1% U . Burnup of this fuel will be limited to ,
37 Gwd/MtU until the NRC staff evaluation of the topical
The Comissionsrs 4 reports mentioned earlier has been completed. Amendment No. 71 to the Calvert Cliffs license g issued June 24, 1982 to allow fuel enriched to 4.1% U to be loaded.
The Safety Evaluation burnup limit for this case was 34 Gwd/MtU assembly batch average at discharge.
The above indicates that the trend to full scale comercial use of extended burnup fuels is beginning. However, indications from the utilities are that the trend will be cautious at first, i.e., the applicants will request only partial core loadings to only slightly higher burnups.
If the current economic parameters remain constant, how-ever, the trend is expected to accelerate so that within the
.next 10 to 12 years most licensees will plan for burnups of 45 Gwd/MtU or more, with refueling cycles of 1.5 to 2 years instead of the current 1 year cycle. This means that the time is now ripe for considering the possible need for an environmental impact statement.
- 3. Environmental Impact Statement (EIS): The petitioner desires that a Generic Environmental Impact Statement (GEIS) be prepared, based on the concern that piecemeal licensing actions would lead to de-facto general use of high burnup fuel on a large comercial scale without consideration of generic environmental factors.
At the time the petition was submitted, requesting modi-fication of 10 CFR Part 51 to require preparation of an EIS with regard to the use of high burnup fuel, there already existed a requirement (551.5(a)(10)) that mandated an EIS for "any... action which the Comission detemines is a major Comission action significantly affecting the quality of the human environment." Furthemore, 551.5(c) required that a negative declaration and environmental impact appraisal be prepared if it is determined that an EIS is not needed. During 1984, Part 51 was almost completely rewritten and' reorganized. Newsections51.20(a)(1)and 51.20(b)(13)includelanguagesimilartothatintheold 551.5(a)(10). In addition 951.21 now requires that an environmental assessnent (EA) be performed for all licensing and regulatory actions applicable to NRC's domestic licensing and related regulatory functions. The EA is to
" provide sufficient evidence and analysis for determining whether to prepare an environmental impact statement or a finding of no significant impact." Thus, the mechanism is
- now in place to respond to the concerns of the petitioner.
The prime question is whether or not there are liable to be i
significant impacts to the human environment from this higher utilization of fuel as would require preparing a GEIS.
' The-Comissionsrs 5 Staff 1.- An amendment to 10 CFR 51 to require preparation of a foEcTusions:
c GEIS, as requested by the petitioner, is unnecessary because 10 CFR Section 51.20 already provides an adequate basis for the preparation of an environmental impact statement with regard to high burnup fuel on either a demonstration or a comercial scale by requiring an environmental impact statement for "any... action which the Comission detennines is a major Comission action significantly affecting the quality of the human environ-ment." Furthermore, 651.21 requires an EA to detennine the need for an EIS. Finally, the NRC regulations are already in compliance with Council on Environmental Quality (CEQ) guidelines for preparing EIS's; hence, no further change is necessary.
- 2. The existing DOE developmental demonstration program does not adversely affect the health and safety of the public nor affect the quality of the human environment as previously found by the Comission during (a) approval of specific license amendments to permit use of higher burnup fuel at five reactors as part of the DOE program, and.(b) denial of two earlier similar petitions, and as demonstrated in the DOE environmental assessment (DOE /EA-0118, August 1980).
- 3. Because of the apparent trend toward use of extended burnup fuel, the time is now ripe to perform an environmental assessment on the commercial utilization of extended burnep fuels on a large scale to detennine if the cumulative impacts of this utilization can signiricantly affect the quality of the human environment and thus necessitate development of a generic environmental impact statement.
Staff Action: 1. . Task to be Addressed: In light of the first staff conclusion above, we recommend denial of the petitioner's request that 10 CFR Part 51 be amended. However, the staff
! believes that it is both prudent and timely to assess the potential environmental impacts of the widespread use of 4
high burnup fuel, in view of the trend toward increased use of high burnup fuel and the recent availability of
, information to assess its environmental implications.
Therefore, the staff has initiated preparation of an EA to provide the information necessary to make a determination of the need for a GEIS. This will include consideration of the environmental effects of the use of higher burnup fuel on:
uranium mining and milling, fuel manufacture, refueling, post-irradiation storage, transportation, waste disposal, I fission product release during reactor operation, reactor ard spent fuel pool accidents, and reprocessing if it should become part of the nuclear fuel cycle.
' The Comissioners 6 l
l 2.. Resourcesi Material has already been prepared by NMSS, NRR and RES staff that will be useful in preparation of an EA. Furthermore, the Atomic Industrial Forum has recently completed a study, under the National Enviromental Studies Pro,iect on "The Environmental Conse- -
quences of Higher Fuel Burnup," AIF/NESP-032, dated June 1985, that should provide needed data for the EA.
It is expected that the EA, which would involve some new analyses as well as compilation and digestion of existing
, information, will require about 9 man-months of effort. If it is determined that a GEIS is warranted, an additional 4-6 man-years of effort could be required.
- 3. Schedule: The staff plans to' complete the EA by the end of July 1986. If we decide that a GEIS is warranted we would make this recomendation to the Comission about August 1986. The development of a GEIS, if needed, is expected to take 2 years to complete.
Recommendations: That the Comission:
- 1. Approve publication of the denial of the petition for rulemaking, as set forth in Enclosure D.
- 2. Note:
- a. .That the Subcomittee on Nuclear Regulation of the Senate Comittee on Environment and Public Works, the Subcomittee on Energy and the Environment of the House Comittee on Interior and Insular Affairs, the Subcomittee on Energy Conservation and Power of the House Comittee on Energy and Commerce, and the Subcomittee on Environment, Energy and Natural Resources of the House Comittee on Government Operations will be informed.
- b. That the petitioner will be notified (Enclosure E).
- c. That the staff has comenced preparation of an environmental assessment of the use of high burnup fuel.
- d. That the staff recomends this paper be placed in the PDR.
The Commissioners 7
. Schedulino: Recommend that this be handled as a notation vote.
m lfetorStello V
(, Jr.
Acting Executive Director for Operations
Enclosures:
A. Copy of Petition for Rulemaking B. Table of Public Coment Letters C. Memorandum: Information on High Burnup Fuel, Feb. 8, 1982, R. J. Mattson, Director of Systems Integration, to F. J. Arsenault, Director, Division of Health, Siting and Waste Management D. Federal Register Notice Denying the PRM ~
E. Response-to Petitioner Commissioners' comments or consent should be provided directly to the Office of the Secretary by c.o.b. Friday February 28, 1986.
Commission Staff Office comments, if any, should be submitted to the Commissioners NLT Friday, February 21, 1986, with an information copy to the Office of the Secretary. If the paper is of such a nature that it requires additional time for analytical review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.
DISTRIBUTION:
Commissioners OGC OPE OI OCA OIA OPA j REGIONAL OFFICES
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ENCLOSURE A
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pellution & Earfromants1 Probless, Zus. .
F.0. Boz M Falatine,1111 mis 600$1 Marsh 6,1960
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D0QWTED 9 USNRC s.
3 I.; MAR 17 580 > :
Mr. Samuel J, chilk ga et the SeedNI i Soaretary of the Commissica Dochi Sarda p U.S. Ikslear Regulatory Commiseion .
Washington, D.C. 20555 4 p I #dslI RE: Petition 2mpacts for Rulensking on Generof Righ Burzaap 3h Dear Mr. Chi 2k t and the utilities With the decision not to reprocess, the federal governmenin lightwater reactors west to use more uranium in aristing snaclear fuelTo r and tint end, the U.S across the country.
initiated cost-shared high burzaap projects with Duke Power Com Arkansas Power & Light.
(p.c.i.) projects with Consumer Power Company irradiation and Commonr On March 7,1979 the 20 issued a permit to Coned2,allowing i up to about the of four tion spent fuel meseblies to artended Zion's Technical specifications provide for a burnup limit burnups in Z an 25,000 WD/MW. The 20 admita thera has been no orperionea theless issued with full of 38,000 lard /ETU.
sine fuel asemblies irradiated to these burnups, but noneppreciable a Negative Declaration stating the higher burisape would have no a .
emirounental inpast. tl These arperiments and others are idespread u being conductd without an Emirem 2spect Statment, eran though they n e m iro m ant. oculd ca se significant and wM long and stort term effects on the kme l the nationwide program of high burnup fuel la nuclear reac t
to follow thase fairly limited experiments.
l legislatir e hearimg, Eugene Toiland, annager at theroMorris ss Ope fuel pool, said he anticipates the use of high buranap fuel in reac the eeuntry in eening years. ting the quality According to NtFA, 8aajor require 8 Federal actions significantly affeca detailed l In accordance with ICCFR, of the 1saman enrirement8 U.S.
(EIS) by the responsible government official. t Statement, Part 2 802, please consider this letter sqr formal petition to the to amend 10llFR Fart 51 to require that a full Enrironmental l r Impact l im
. be y,repared severing the generie enrironter. afuel as used in c i ecoling racket and potentially as processed in reproceca ng of in permanent sites. .
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unirso:TArms 8 a NUCLEAR REGULATORY COMMISSION c .e me am. o. c. m.
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BN FEB MEMORANDUM FOR: Frank J. Arsenault, Director Division of Health, Siting and Waste Management FROM: Roger J. Mattson, Director Division of Systems Integration
SUBJECT:
INFORMATION ON HIGH-BURNUP FUELS As a partial response to your October 13, 1981 request for infomation to be used for the PEPI Petition on High-Burnup Fuel (PRM 51-6), the attached report, prepared by a staff consultant, is provided for your use. We believe that the report provides answers to most of your questions. We will continue to try to fill in some of the gaps through direct contact with a limited number of licensees.
As an aid in locating the desired infomation in the report, the following tables, figures, and pages correspond to the numbered items in your October letter:
- 1. Present quantity of fuel undergoing high-burnup operation: Refer to Table 8 for PWRs and to the Appendix and Reference 2 (containing infomation claimed to be proprietary by one vendor) for BWRs.
- 2. Projections for future high-burnup use: Refer to Figure 7 for PWRs (no infomation as yet on BWRs).
- 3. Quantity of high-burnup fuel stored: See Conclusions on (We hope to get some plant-specific infomation on this.)page 3.
- 4. Names of facilities involved and dates of irradiation and storage:
Refer to Table 6 for some PWR infomation. We hope to get some BWR infomation through direct contact with licensees.
In addition to the specific locations noted above, the report Suninary (p.1) and Conclusion (p.3) sections also contain condensed information that addresses your questions. We hope this infomation will be useful to you in your consideration of the PEPI petition. For further comuni-cations on this matter please contact Dr. Michael Tokar of the Core Performance Branch (extension 29478).
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{ttso , Director Roger D.
Division o M)f Systems Integration
Attachment:
As stated cc: E. Conti R. Grill S. Boyd Enclosure C
OBaHelle Pacific . Northwest Laboratories P.O. Sos Srr R:chland. % ashirgron 1.'.5.A. 99352 Telephone !"si 375-2615 TeIn 15-25N January 18, 1982 ,
Dr. M. Tokar Core Performance Branch .
Division of Systems Integration Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mike:
Attach Task lta9d)is the informal on schedule. Theletter report letter that report completes provides the milestone information that we for have been able to collect in an effort to answer the DES (b) re needs the information to aid them in responding to the PEPI(c) petition, quest. RES PRM 51-6, that would require a GESM0-like generic envirenmental impact statement on high-burnup fuels.
Sincerely,
& tA$ '
W. J. Bailey Nuclear Fuels Section WJB:jz Attachments: Nonproprietary letter report and proprietary appendix.
cc: HE Ransom (DOE-RL) without attachments Chief, Core Performance Branch (NRC-NRR-DSI) with attachments (3) +
(a) Task 1 in the Fuel Operating Experience Evaluation Program III (FIN No. 2501; TD 1518).
'(b) Division of Health, Siting, and Waste Management, Office of Nuclear Regulatory Research (RES).
(c) Pollution and Environmental Problems, Inc., (PEPI).
HIGH-BURNUP FUELS INFORMATION W. J. Bailey January 13, 1982
SUMMARY
The Office of Nuclear Regulatory Research (RES)I") requested that the Office of Nuclear Reactor Regulation (NRR)(a) furnish updated information on high-burnup fuels. RES needs such infomation to aid them in responding to the PEPI(b) petition, PRM 51-6, on extended burnup. This informal letter report provides the information that Pacific Northwest Laboratory (PNL) was able to obtain for NRR in an effort to answer the RES request. The letter report was prepared under NRC's Fuel Operating Experience Evaluation Program III (FIN No. 2501).
Over 3800 PWR fuel rodsIC) have attained burnups of 40,000 mwd /MTU or higher. A significant number of BWR fuel assembliesId) have reached burnups of 26,000 mwd /MTU or higher (see proprietary data in the Apoendix). With in-core BWR fuel, the lead assembly burnuo (through January 1981) was 40,000 mwd /MTU (Ref. 2).
A 1981 paper (Ref. 3) includes a projection of the transition of PWRs to high burnup. That projection shows the conversion to high burnup starting in 1983 and reaching 100f. in 1994. To date PNL has not located a similar recent projection for BWRs.
INTRODUCTION In an October 1981 memorandum (Ref. 4), the Division of Health, Siting,
.and Waste Management of RES requested updated information on hich-burnup fuels (a) U.S. Nuclear Regulatory Comission (NRC)
(b) Pollution end Environmental Problems, Inc. (PEPI).
(c) A PWR fuel assembly (see Table 1 in Reference 1) typically contains 176 to 264 fuel rods and weighs about 580 to 700 kg.
(d) A BWR fuel assembly (see Table 1 in Reference 1) typically contains
- 49 fuel rods (older type) or 60 to 63' fuel rods (newer type) and weighs about 290 to 320 kg.
1 -
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from the Division of Systems Integra' Eon (DSI) of NRR. RES needs the infor: nation to' aid them in responding to the PEPI petition, PRM 51-6, that would require a GESMO-like generic environmental impact statement on high-burnup fuels. RES expressed interest in the following kinds of information: the present quantity of uranium, nunters of fuel elements and/or assemblies, etc., currently undergoing high burnup in U.S. reactors; projections for future high-burnup use; the quantity of high-burnup fuel now stored in reactors, spenf. fuel pools, cooling racks, etc., or awaiting reprocessing or disposal; and the names of the facilities involved as well as dates and lengths of irradiation and storage.
As a result, the Core Performance Branch (CPB) of DSI incorporated the preparation of an informal letter report on the extended burnup petition issues as Task 1 of Fuel Operating Experience Evaluation Program III (FIN No. 2501; TD1518), a program sponsored by CPB at PNL. Work on Task I was initiated on December 1,1981,(a) and has resulted in this letter report, which includes the information on Zircaloy-clad BWR and PWR fuel that PNL was able to collect in an effort to answer the RES request.
On December 23, 1981, PNL contacted M. Tokar (CPB) regarding some difficulties being encountered in locating some of the information (e.g.,
dates and lengths of irradiation and storage of high-burnup fuel) needed for
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this letter report. One step that had been considered was to purchase some comercially available data. However, the et hmated cost for acquiring such
! data was substantially greater than the toLal amount of funds allocated by NRC to Task 1. Also, one fuel vendor recently notified PNL that any future NRC-related requests for fuel information should come from the NRC. Other fuel vendors indicated that some of the requested information is the property of the utilities. M. Tokar indicated at that time that he would investigate the problem.
1 i (a) The Richland Operations Office of the U.S. Department of Energy signed the Request for Services (TD1518) on November 25, 1981.
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{ CONCLUSIONS -
e Over 3839 PWR fuel rods (more than 1071 in-core; more than 2768 discharged) have attained burnups of 40,000 mwd /MTU or higher.
e Over 41,472 PWR fuel rods (more than 995 in-core; more th'an 40,477 discharged) have reached burnups of 36,000 mwd /HTU to nearly 40,000 mwd /MTU. .
e' Over 162,203 PWR fuel rods (more than 4?,232 in-cc e; more than 119,971 discharged) have attained burnups of 32,000 Wd/MTU to nearly 36,000 mwd /MTU.
o A significant number of discharged BWR fuel asse:nblies have achieved burnups of 26,000 mwd /MTU or higher (see proprietary data in Appendix).
e With in-core BWR fuel, the lead assembly burnup, through January 1981, was 40,000 mwd /MTU (Ref. 2). As of August 1,1981,'in-core BWR fuel assemblies had reached average burnups as high as 40,800 mwd /MTU (Ref. 5).
e Most discharged high-burnup fuels have resided in storage pools for a relatively short time (Ref. 6).
e The recent (1981) projectionI *) by EPRI (Ref. 3) for the transition of PWRs to high burnup shows the conversion starting with 105 in 1983 and reaching 1001 in 1994.
e To cate, PM. has not located a recent similar projection for the transition of BWRs to high burnup, except for the information(b) from a 1979 report (Ref. 7).
. o ' There were several problems (in addition to those noted in the Introduction) encountered by PNL in assembling these data from the j .
available literature. As is evident in the tables (see Discussion),
(a) See Figure 7 under Discussion.
(b) See Figure 5 under Discussion.
3
the burnups, were reported in many different forms and for rods only in some cases and for assemblies only in other cases. Some fuel may be counted twice as it is difficult in certain cases to identify individual fuel assemblies when two organizations (e.g., DOE ~
and a vendor or EPRI and a ' vendor) report on the same' fuel.
DISCUSSION Extended-burnup prograns are currently underway that involve BWR fuel and PWR fuel that are to be irradiated to average assembly burnups up to 43,000 Ed/MTU and up to 55,000 E d/MTU, respectively. A 1979 report (Pef. 8) indicated that with such burnups (i.e., 55,000 mwd /MTU), the peak pellet burnups will now exceed 60,000 mwd /MTU (up from the current 40,000 mwd /MTU).
The extended-burnup program sponsored by the Electric Power Research Institute (EPRI) is shown in Table 1 (Ref. 9). The extended-burnup fuel demonsti ations with current product-line fuel being sponsored by the Department of Energy (DOE) are shown in Table 2 (Ref. 5). Recent studies by EPRI (Refs 9 and 10) indicate that if reprocessing is not available, the optimum discharge burnup for PWR fuel is in the high 40,000 to 50,000 mwd /MTU range, and if i reprocessing is .available, the optimum discharge burnup for PWR fuel is in the low 40,000 mwd /MTU range. A 1981 German paper (Ref.11) states that "an increase in target burnup consequently means an approach to technological limits." Table 3 is from Reference 11 and shows various aspects of I
high-burnup fuel and their relevance (classified with regard to their importance) to BWR' and PWR fuel. Both Reference 11 and Reference 10 point out that Zircaloy corrosion, particularly with PWR fuel rods (they operate at I
higher surface heat fluxes than BWR fuel rods), may be a limiting factor ")
in extended burnup fuel cycles.
It was indicated in 1978 that the current nominal design burnups for BWR and PWR fuel were 27,300 mwd /MTU and 33,000 mwd /MTU, respectively.(Ref. 7.and 12). In 1981, the design and warranty exposures are stated to be (a) Assuming that the pellet-cladding interaction phenomenon is eliminated '
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TABl.E 2. Extended Burnup Fuel Demonstrations Sponsored by 110E With Current Product-Line Fuel (Ref. 5)
CURRENT IA5 OF AUGUST I,1981) TARGET NO. OF . AWRAGE- NO. OF AWRAGE l ASSEMBLIES SURNUP, ASSEMBLIES BURNUP, YEAR 1R00SI MWdNTU 19005) MWdNTU COMPLETED UTILITYKUEL WN00RREACTOR 5
.0,000 e DUKES &WDCONS-1 4 40,000 I 1983 ,
l 20 33,400 - -
COMPLITED e OMAHAC-EKORT CALHOUN I 1 44.A00 1 52,000 1982 13,200 1 49,000 1994 O AP&LEflANO-2 1 1 38,700 1 42,000 1991 e VEPC0lLM50RRY-2 57,000 - -
COMPLITED m e -Jp!8R-3 151 5 %.100 COMPLITED e NSPEENONilCELLO 2 37.200 2 39,400 I?$2 2 40.800 2 43.000 1982 e CONSUMERS &GPUEXXON 4 30.200 4 35,500 1983 MYSIER CREEK
%.700 1601 38.500 1982 mig ROCK POINT 1601 ,
s
TABt.E 3.- Various Aspects of High-Burnup Fuel and Their Relevance to PWR and BWR Fuel (Ref. 11)
RELEVANCE TO HIGH BURNUP ASRCT PWR FUEL BWR RIEL e WATERSIDE CLADlJING CORROSION XX X X e DIMENSIONAL CHANGES OF CLADDING X. X X e FUELBEHAVIOR
- DIMENSIONS AND INTEGRITY X
- INTERACTION WITH CLADDING X X
- FlSSION GAS RELEASE ISTEADY1 X X X (TRANSIENTI X X X X e POWER RAMPlNG BEHAVIOR X X X e POVER CYCLING BEHAVIOR X X
, o ASSEMBLY STRUCTURE
- LENGTH CHANGES, BOW X X
- FUEL ROD BOW X X
- RELAXATION OF SPACER SPRINGS X
- CORROSION OF ZRY-SPACER GRIDS X e GADOLINIA BURNOUT AND X X X TECHNOLOGICAL BEHAVIOR w
l 7
l
- l s28,000 Ed/MTU, for BWR fuel and 33,000 to 36,000 for PWR fuel (Refs. 9 and 10). As a result, for this study a search of the available literature was conducted to locate data on Zircaloy-clad BWR and PWR fuel that has attained burnups greater than 27,000 Ed/MTU and 33,000 mwd /MTU, respectively. The results of the search are described below.
Infomation on discharged BWR fuel with burnups greater than .
j 27,000 W d/MTU is presented in Table 4. Table 5 provides data on in-core BWR fuel that has attained burnups greater than 27,000 mwd /MTU. Additional l
information (proprietary data), including Table Al which shows the
- distribution of discharged high-burnup BWR fuel assemblies, is in the Appendix.
Table 6 presents information on discharged PWR fuel that attained burnups l greater than 33,000 mwd /MTU. Table 7 provides data on in-core PWR fuel with burnups greater than 33,000 mwd /MTU. Table 8 shows the distribution of active (in-core) and discharged high-burnup PWR fuel rods.
Domestic BWR fuel experience is sumarized in Figure 1. Domestic PWR fuel experience is sumacized in Figure 2. ,
In addition to the information presented above, there are some other data on high-burnup f.uel. .There are 32 PWR fuel assemblies (maximum burnup -
i 33,160 Nd/MTU; average burnup - 31,500 mwd /MTU) from Point Beach-2 that have
.been stored at General Electric's Morris Operation since July-September 1976.
Also, some Zircaloy-clad Shippingport fuel bundles with high burnup and/or long storage times have been examined (Refs. 6,13, and 14). Two bundles (0551 and 0074) of Shippingport PWR Core 1 bladet fuel were exposed to water in the reactor f rom late 1957 until discharge. The estimated bundle average burnups were 4000 mwd /MTU for bundle 0551 and 18,000 mwd /MTU for bundle 0074 (one rod from this bundle has a burnup of 36,000 mwd /MTU). Fuel rods from bundle 0551 were stored in deionized water at the Expended Core l Facility in Idaho for nearly 21 yr prior to examination (Ref. 6) in 1980,-
representing the world's oldest pool-stored Zircaloy-clad fuel. Bundle 0074 has also been stored in deicnized water at the Expended Core Facility since reactor discharge in 1964. The bundles have been stored at the Receiving Basin for Off-Site Fuel at the Savannah River Plant since September 1981.
8 l
3 .
TABLE 4. Discharged BWR Fuel With Burnups Greater Than 27,000 mid/MTU Ihsaber leunber Burnap,teid/MTU Maniaman Average Reference of of Fuel pod Isunber Fuel Rods Assendilles Average Assesd>Q Assembly Dates and Comments Vendor Plant Discharged in 1980 (00E Progran). I
[ anon leuclear Big Rock Point 4 34.900 I 34.000 Burnup as of last outage (00E Program). 2 General Electric Monticello 2nticell6 5 . 36.100 Discharged by or before August 1.1981 5 (DOE Program).
I 29.000 Discharged in or before January 1981. 2 Quad CIttes-l 1 to 3 31.000 Burnup at of last outage; discharged 2 Quad Cities-I in or before January 1981.
3* -31.000 As of Fall 1980. 2.9 Quad Cities-1
- Mined-oxide (UO 2-Pu02 fuel assemblies.
I e
J
TABLE 5. In-Core BWR Fuel With Burnups Greater Than 27e000 Wd/MTU Gurnup, labl/MTU
- lhamber Aver #9e Peet IIustser Reference of of fuel Sed Nes tess Aver 49e Asseat ty' Pellet Router Feel Reds Assemblies Aver 49e Assembly Asse s]h Gael Geel_ 9etes end.Cesmants 9 ender Plant i 5
=- re :: m:e, ,it,,1- ,re,-
< - -le- .89 m t ,.lat .[ ,,,00 As of .e er n . it 1:
,i
.1, l.t . .. 0 As of December 31. 1900 1 Oyster Creek 560 20.300 As of August 1. 1981 5-4 30*?no To be achieved in 1983 5
Oyster Creet 35.500 40 fino At last estege (la er before Jammery 1998) 2 1
General Electric Manticelle As of August 1. 1988 5 37.705 f.5 39.000 55.000 is he achieved in 1987 00t Program Manticelle 4* ff 5 40.eno As of Amoest 1.1988 43.000 55.1100 to be achtved in 1982 F.5
$ 2l As of May 1980, after 3 cycles 9
-21.000 f.9 Peach Gottom-2 >33.000 To be u hlevd In 1902 M 1 W en 4 F
-40.000 55.000 to be achieved in 1983 lander cansideration) j 2 2 31.n00 As of last este9e Quad Cities -1 Ila er hefere Jenmary 1901) l
'Bl *sie0 As of Fall 1988 . (Pat Pr w en I
quod Cities -l 2** - M.000 le be schleved in Fall l987 F L
- lhee essembly mes discharged in er before Janeery 1981.
- Mised-eside (Unt-Puol) fuel esse =Siles.
L ___
TABLE 6. Discharged PWR Fuel with Burnups Greater than 33e000 Wd/MTU .
asutw eersue. seldfeste of muuher ma neum IIes tnum Seera9e geglen estch esference feel of feel IIss tems sed. and estes and Comments meter _
sender Plant Beds . essembtles fuel ed Seerage S_ wee age, Asseshly esseemly Average Swereer
! Ament feel dluterare nefore 3.19 8.bc.ce s . - el.6es 19F9; feel stored slece them.
l I unicos 33.729 Mecharged le 19es; stored I Gre asses.l* slece them. .
4 -40.see elscharged la late 1979; F5 econoe.t stored slece them.
I 40.000 Sischarged le 19 ; stared I seemee.1 slace then.
37.000 Bluberged le 99es; stored I etenee.t since them.
37.730 Mscharged le 8900; stored I Sanche Sece slece thee.
- 43. Gee elscharged le 1980; stored I Centeellen Celeert Cliffs.1 tot i slece thee.
tagleserlag le 33.430 Storherged le 19es; stored I Fort Calhoun f.el6 since thee, 33.400 Completed en er Before S fort Catheen M ceselfel (get programp.
3F fW eluberged le 1980; stored I IIslee fantes B.968 12 p slece them.
ea
- 33.858 eluherged le ites; stored I i
IIllistene 2 879 S state them.
J
.e. Giuh-god I. i=0; siered i
- .... S esa M slace them.
meclear 57.ene Completed en er before 5
$ see.ame
. testin9heuse 88 3 (voltalal" 13 reds) setellel test program).
33.620 Seglen 3 feel deuhargPd SS IG-?I Cose.1 13.0 % 1979; stored since thee.
33 lle Orglas 1 feel dinherged in M.ft ladlee Pelet.) 83.9 % 8979; stored stare thee.
50.089 Irredleted during 1968 1976; 16.74 Jose de Cabreve 2 rods eluterged erler to sad (teritala of 1976; 5 er 6 rods are in g dry storage le Spels.
I 49.989 38.900 Se9l es f fuel discharged at it.N Prelate fstand-l ene of Cycle 3184f 781; stored elece them.
44.440 Seglen 7 fuel discharged at 19.M
- Pratrie Island.l 8 49.770 end of Cycle f 199 feel; stored slece them.
- artensas Reclese epit 8.
- f orelyn reacter.
t gycle g of glee.g.
a
~ ---- __
I TABLE 6. (contd)
I or % lem,=
of m s==
t rol .maner 9 ns.im. .d- see I. n.e,e.e se, a s.ich soferee,e mueer 9eeder Plant beds Asse.foi Iles feel and Aserage asevege Assess.J Assembly avereer Average, Ostes and tensets M.940 angles 3 feel discharged la M.FF Freerle Island-l 7,86 0 197s; stored elece thee.
Pretree Island-t 7.100 M ,830 esgles 3 feel discharged le 21,77 1970; stored state them. ,
Polet Beach-l 2 40,est N,4M Aeglens 2 and 3 feel dis. 39,30 thereed at end of Cycle $
llellt): stored state them.
! Polet Beach-2 37 4F,A09 N.MS Degles 3 feel dluberged at St M end of Cycle 3 (SFIFF):
stored siete them.
Pelet teach-2 3 46,700 M,Sgg toglen 5 feel discharged et 39,M '
end of Cycle 6 (98/8913 stored slece them.
Delet Beach-f 8 44.400 40,000 Reglas 5 feel discherp at St.M and of Cycle 8 (94feges stored slece thee.
41,400 N,WS Sogles 5 fuel diuharged at 19,M
> Polet Beuh-F S end of fycle 6 (98/89) stored slece them.
Pelet teach-! 6,63r M.les aegles 3 feel discharged le M-73 N 19783 stored elece them.
90 7,100 M. Pee negles 3 feel elscharged le 27,33
! Pelet teach-t 1977; stored slece thee.
21en-8 M 47,000 N,ege Regian 3 feel discherysd at it.M and of Cycle 3199f 7983 stared slece thee.
5 37.988 N,403 Regles 2 feet dinherysd et 19,M 28 1 end of cycle 3 leotteig stored slece thee.
Ilen.1 4 49,3ee 46.3se anglen 3 feel sluterase et ig,M sed of Cycle et telle633 stared slece thee, 96.17e se9t en a feel dtuberged en #1,77 Itaa-l 13.056 89re; stored slece them.
L i lice-F 64 47.700 N, pes argem 3 feet deuterged at it.M end of Cycle 3 feif 79)g stored slece then, lies-2 13,056 M,let anglen 3 feel sluterged le 78.77 897e stored state snee.
(
j
- Artantes esclear tune--untt 8.
- forelys reacter, t Epcle 4 et item-1.
9 TABLE 7. In-Core'PWR Fuel with Burnups Greater Than 33,000 mwd /MTU Burg stad/Ittu I . Ilumber Nueer Asseely Maulman Averar Peak Batch Satch. Average Reference of of feel feel Reds Asseshlles Peak Sed Assembly Asseshly Average _ Averaged Goal Sates and Comments __ shammer Vendor Plant
-40.000 As of late 1979 ]M Prwas .e 5.M Babcock a lfilcos Oconee-I to be athleved la 1903 l Ill - 50.000 Comhustion Arkansas-2 il 13.200
- 4. 000 As of 5/1/88
- i. .e -hie.ed in i,.4 i= prw- 5 in,ineerin, As of 10f00 To be achieved in 1982 ll W PN'"
3 Inttally* -48.000 43,0nn '
Calvert Cliffs-l 1 of the 3 55.000 34.200, As of 12/31100 (la Cycle 3) I Calvert Cliffs-2 164 1 33.900 As of 12f31/OO (in Cycle 3) 1 Calvert Cliffs-2 11.632 68 4'*400 la 1982 DOE Progran 5 Jert Calhoun 1l 2.000 40.300 As of 12131/00 (in Cycle El I g Fort Calhoun 2.992 IF w I poblason-2 157 41.700 As of 12131/00 Esson Iloclear 33.500 As of 12/31/00 (la Cycle 10) 1.10 laestinghouse Berneo-l** ,
34.100 As of 12/31/00 (la Cycle 5) 1.10 Indian Point-2 34.500 As of 12/31100 (la Cycle 9) 1.10 Point Seach-l 36.lsul as of 12/31/30 (in Cycle 1) 1.18
. Point Beach-2 34.900 As of !?f3]f00 (la Cycle 6) 1.10 Fralrie Island.1 35.103 As of 12/31100 (la Cycle 5) 1.10 Prairie Island-2 ,
"'# e ed la 1988
'"I P' ** I Suny-7 If 42.000 As of 12131/00 To he achieved in 1984 5 t m Pr w as 28*300 9 IF8J8" en.nno Cerc{
33.200 As of 12f 31100 (la Cycle 2) 1.18 Turkey Point-4 36.100 As 12f33100 (in Cycle 5) 1.10 Flen-1 a 1982 ftPRIProtros 9.18 Plon-l. -2 4f 55.000 h ev 37.l00 As of 12f31/00 (in Cycle 5) 1.10 i flow-2
- Ne asseshly discharged af ter each of first tuo cycles.
- Inreign reacler
TABLE 8. Distribution of in-Core and Discharged High-Burnup PWR Fuel Rods In-Core Fuel Rods (as of 12/31/80) Discharged Fuel Rods .
40,000 32,000 to 36,000 to 40,000 Reference 32,000 to 36,000 to
<36,000 <40,000 and Higher <36,000 <40,000 and Higher Number Burnup, W d/MTU
- l Fuel Vendor: .
(a) (b) (c) 1 Babcock & Wilcox 0 176 6.308 0 162 1 Combustion Engineering (d) 11,796 (e) (f) 1' Exxon Nuclear 895 113,663 40,477. 2,606 1,18 Wes'tinghouse(9) 30,436 995
>42,232 >995 >l.071 >l19,971 >40,477 >2,768
- icials , ;
a (a) Among 266,448 fuel rods in-core, the maximum rod-average burnup is 32,430 Wd/MTU and the mean rod-average burnup is 14,740 Md/MTU. .
(b) Among 61,360 rods discharged in 1980, the maximum rod-average burnup is 39,240 Wd/MTU and the mean rod-average burnup is 24,900 mwd /MTU.
(c) Among 586,054 rods (cumulative) irradiated through December 1980, the maximum rod-average burnup is 41.600 mwd /MTU and the mean rod-average burnup is 18,560 mwd /MTU.
(d) Based on fuel assembly batch-averaged burnup.
(c) Among 157 fuel assenhlips in-core, the maximum assembly burnup is 41,700 mwd /MTU.
(f) Among 56 fuel assemblies discharged in 1980, the maximum assembly burnup is 40,400 Md/MTU.
(g) Based on assembly-wise burnup.
. s 0
The fellowing eyesifie sommente relate to potential significant a impacts basis for my ofregusets high burzaap fuel on the laanan environment e the and sons
- 1. .
Greater fiselon gas releases from assolear reacters.
According to Aeoording to Maclear Safety, Vol.19, Ib. 6, Nov-Dee.1978:
from the research sommunity indicate growing evidence e...soaments for an eased rate af fission-gas release in lightwater reactor fuels (1 Division of30,000103/M1U..
above Raclear Power, DDE, also Dr.projects Peter lang, acting director as a side effect of higher fuel burnup times. greater fission gas releases In its Safsty Eraluation Report on increased fuel burnup at Zio 3RC soncedes the amount of long-lived fission products and s the,t ' Irradiating fuel to extended burnups . the ease will statoes oou14 increase the fraction af failed fuel in the core er er Wt previously r y from Zion 2 during this extendedburmap program orious than a durlag cycles, compliance with W technical specifications will maint 1
tions of radioactivity within allowed limits.' -
fa other words, the 2C, without notifying the public of the or kind of sacreased radioactirity releases fica the guantity Zion station
, decided onus.
to our behe,1f Wt this increased amount of radioactivity e is ac The MC made this decision unilaterally without actifying the publie er without benefit of public hearings er input.
We sall to guestion the democracy and ethics of this decision-mak fuel on a natiozaride scale.
, especially as p auclear h public is entitled to know guantatively ani qualitatively the radionuclide releases. emissions attributable to higher burmrp, ins adva should not be the determining factor la higher bura .
- 2. .
damage to fuel any occur with higher Righerburnup.3her irradiation surface of the fuel rods.ourrent IMs have not experienced excessire Re suggests, inwever, that: 82f burzaaps and residence times are increased significantly, it is possible tlat a layer of oxide and erud deposits any develop, raising a the oxid as I.
_ _ . _ _ _ _ - ___________Qom- . - _ . - , - _ - _ - . - - . . - . - . - - _ - - . - - , , . . , . --- . , _ _ . - -_ - . - - . , -
~ ~ -w
- h t
i interface temperature safficiently to aseelerate corrosion." ,
I submit that the above-statd possibility of fuel sorrosion raises serious guestions regarding the guality of spent fuel prod higher bur my.
to and from the spent fuel pool and subsequently to the atensphere and publis will be higher. .
The publis, in the absence of sa EZB, is belag aeked to accept the risk of greater fission gas releases from spent fuel pools in or their effects on W hznan enrironment.
tems
- 5. Production of inferior grade Free nuclear
$ousspent fuel which government eenincluding research, lead to torn ein iro:=sental hazards. It is useless in predicting 3Mur,-0404, is based eh low burrazy fuel.
- pool storage behavlor of high burnup fuel.
The public is surrently being asked to accept grea N EC's XJRE:",-0404 assures eitizens Wt in highly populated areas. -
'At-reactor spent fuel een be increase!...with no sacrifice to public 8 and 'The em ironmental impact of 4,he propo sed besith and entstrincreased at-reactor spent fuel storage was msgligible... ba pool water techelogr.'
24 should be pointed out that exist.iag pool water technologr and research is based on low burnup fuel. A.B. Jotasom Jr., in his ' Behavior of Spent Maclear Fuel in Tatar Pbol Storage,' notes th The EC's projections for safe storage of spent fuel are this based en limited low burzzap pool storage experiences with no experience. beyond
%.000 WD/m includizg miittary.
l spent fuel product of the future, if high burr.up is permitted on a The,idescale, aw le of unktman guality and is enticipated by some scientists to have decidedly poorer structural abaracteristics and integr present low burnup specimens.more utilities to go to higher buttary, the probably be degraded 3 at best it is unknown.
The los burnup opent fusi storage orp rience at the Ibrris Operation and Wt researched by A.B. Johnsom Jr. of Battelle laboratory becomes e
l -
surmty l
.. quigg !
l irreterant as a basis for spent fuel behavior predictions as the United States movee 19eard higher burnup. I submit that 3EIREG-0404 should be
.. declared null and void as a document on which to base spent. fuel safety ad enr4ronmental eensiderations. i Before proceding with reactor-scale orperiments that sould endanger their )
health and enrirotusent, the publie la entitled to seientiffs projections and analyses of high burnup. These should include, but not be limited te, risks of premature rod failure, estimations of increased fission gas ;
releases and fuel rod ' internal pressure, likelihood of sorrosion and
%driaing of eladding and structural materialsWe andshould erpostations be giran of a fuel i asse=bly dimensional and structural shauges. )
- reasonable explanation of the reasons uly the above research cannot be J sarried on in industry and government laboratories, before proceeding with !
experimentation in the human environment,. l
' I
- 4. Potential for greater radiological impact in reactor and spent fuel pool accidents. The projected impact of high burnup The on reactor and spent fuel impact of larger accidente has nat beam revealed to the public.
radioactive gas releases from high burnup fuels in a loss of ooolant ;
' accident,either in the reactor or the spent fuel pool, stou14 he an ,
important consideration in allowing utilities permission for higher burnup. )
According to R.O. Ngrer, Director of safety Systems, Office of 3ruelear l Reastor Regulations, U.S. ERCS 8...the RRQ has reason to believe that l the plant safety analyses underpredicted fission gas releases at high )
burnup s. '
The public is entitled to krew the sorrected estimates for increase in fissica gas release due to high burnups espeelally since all indications are that fission gas release is a direct functio.n of buruup.
- 5. Increased radioactive releases during reprocessing. The radioactivity in spent fuel increases proportionately with fuel burnup as do waste discharges. For example, the content of krypton-85 goes from 6,000 euries yor astris ton at 20,000 notD/M1U, and 8,000 eurisa yor metris ton atWith 35,000 END/E:V - to 9,100 euries per metric ton at 40,000 ED/ET.
higher burnup fuels, the tritium released in liquid discharges from aWest Y reprocessing plant will increase drastically.
releases to go from 1,200 euries per month to as such as 20,000 suries Per month w!th high burnup fuel. (sourest 'Buelear Fuel Reprocessings Radio-logical 2mpact of West Taller," by Dr. Philip Hatfield, in The Naclear Cycle, prepared by the Union af Doneerned geientists, MIT Press, Carbridge, Mass., 1975. .
. A e
_ _ _ _ _ _ x,
Dur m y
., * , 45155 An eenclusion. I urgetly Petition the U.S. Ifuelear Regulatory Comission for ruleseking on the generic arwirometal impact of high burmy nuclear fuel in commerotal lightwater melaar reactors and in the storage, reprocese-ing or disposal of amid fuel after irradiation.
The 20's adop' tion of generic regulations regarding high burnup fuel is a necessitir if public health and safety is to be protected.
Simoorely, g A k- "- es "'
Catherine quigg, resenroh ector Pollution & Dzv$ronnenta! Probics, Inc.
F.C. Boz M -
Falatine, Illinois 60067 (312/)51-6695)
O O
4 l .
I l
O 4
l l l o
t 9
EMCLOSURE B
MATRIX OF PUBLIC COMMENT LETTERS Provides Provides Letter Technical Legal Concerned
-Docket Basis for Basis for with Specific No. Comenter _
For Against Position Position Site 1 John F. Doherty X X X Houston Texas 2 Univ. of X X
~Pittsburgh 3 DOE, Wash. D.C. X X ,
4 Duke Power Co. X X X 5 Arkansas Power X X
& Light 6 Battelle, Pacific X X Northwest Lab.
7 Citizens Opposed X X to Radioactive -
Pollution -
8 Virginia Electric X X X
, & Power Co.
9 Commonwealth X X X X Edison 10 council on Energy X X Independence -
H WA X X
, 12 Westinghouse X X X Elec'.ric Corp.
l 13 Yankee Atomic X X Electric Co.
14 Babcock & Wilcox X X i
l l
1 _ . _ _ _ _ . - -
Enclosure B
8O ENCLOSURE C
44.000 9 0
40,000 . o a 36,000 - ay A
32,000 ,,,
3 28,000 -
. ",0
$ - CURRENT KRFORMANE * * **
g 24,M SRCIFICATION # * %{
G d N,% ~
8 e e
't g . e*J$ . eei
= i6.000 -
8.,e 12,000 - *
- g , e% og ,
3, e 8,000 -
e
- * ' gg,* * ,s,e e '
e
- g
- 4,000 -
0 1962 1964 1966 1968 1970 1972 1974 1976 1978 1980 1982 1984 YEAR FIGURE 1. Domestic BWR Burnup Experience. Data Points (e) for Discharged Fuel are from SSA-122 (Ref. 7) and are Unscreened, Unweighted Exposures of Discharged Fuel, Regardless of Amount of Fuel involved. Other Data Points are for Discharged Fuel (m), Fuel Still in Cores (o), and EPRI (A) and DOE (v) Fuel That is to be Discharged in the Future.
64,000 60,000 - en en
%,000 -
3 52,000 - V e, 7 48,000 -
- E W
44,000 - "a
- a f ,% V 40,000 - s' eP S
.m
. .*P m Q'g I
- , y y, ,a!e
- f.
!- 3r.000 Cenat a nRrea,. m et s *
[ g3,000 - SPECIFICATION , g g
{E u.= - .
8,**.1%,,-
- ge t *
- 20. = -
16, = -
. .'* 43
.i t. ,< = ,
u,000 -
. . .s *. e i,a -
4,000 -
0 1962 1964 1966 1968 1970 1972 1974 1976 1978 1980 1982 1984 YEAR FIGURE 2. Domestic PWR Fuel' Burnup Experience. Data Points (e) are from SSA-122 (Ref. 7) and are Unscreened, Unweighted Exposures of Discharged Fuel, Regardless of Amount of Fuel Involved. Other.
Data Points are for Discharged Fuel (s), Fuel Still in Cores (o), and EPRI (A) and DOE (v) Fuel That is to be Discharged in the Future. Also shown are Westinghouse Fuel Rods Irradiated in (a) BR-3 (Vulcain) and (b) Jose de Cabrera (Zorita)~.
16
.- . _ _. _ a
l Similar fuel rods from the NELBA II test program in Shippingport have been examined (Refs 13 and 14). The fuel was in the reactor for about 17 years (12.3 years of reactor operation). Irradiation of the fuel started in December ~1957. The fuel was discharged in 1964 after attaining a burnup of
~
41,000 mwd /MTU. The fuel was stored in water for the next fou'r years and then examined. These and other fuel examinations conducted in the U.S. and other countries are shown in Figure 3 (Ref. 6).
Some stainless steel-clad PWR fuel has achieved burnups of 33,000-37,500 mwd /MTU (Refs.15 and 16). However, information on that fuel was not included in this letter report because the extended burnup programs involve only Zircaloy-clad fuel.
A 1979 report (Ref. 7) provides information on historical and projected trends in fuel burnup (Figure 4), historical and projected quantities of plutonium produced in nuclear power plants (Figure 5), and historical and projected total quantities of uranium in discharged fuel (Figure 6).
Projections about the transition of the PWR industry to high burnup have published in 1979 and 1981. The projection from the 1981 EPRI paper (Ref. 3) is shown in Figure 7 and is more conservat.ive than that in the 1979 paper (Ref. 17). As Figure 7 shows, EPRI assumes an increasing conversion, starting with 10% conversion in 1983 and 100% conversion in 1994. To date, PNL has not located a similar recent figure illustrating the projected transition of BWRs
! to high burnup. However, Reference 3 states that ". . . many BWR and PWR I
operators are preparing to extend burnups. This trend confirms the predictions of . . ." Figure 7. -
e 17
o AD INFL(Zry-CLA0 CAN00 FUEU BD BNFL(Zry-CLA0 BWit FUEU 1905 - 80,000 - CD BNFL(Zry-CLA0 PWit FUEli DD BNFL(Zry-CIA 0 SGHWit FUEU l MAXI AGJM EXPECED BuieluPICOMERCIAL E a ONfLISS-GAD PWR FUEU 08 -
DEMONSiitAll0N F 0 MCL(Zry4: LAD CANDU FUEU pgoggAus)
GD MCL (Zry-CLA0 CAN00 FUEll )
i !
60,000 -
HO PNL(Zry-CLAD SHIPPINGPORT PWR FUEU
- Zry-CIA 0 SHIPPINCPORT 5000
" I I 3 JA PNL ISS CLAD CONNECilCUT YANKEE PWit F' JEU S OR K O KWU (Zry-CLAD PWR FUEL -
E
~
a NONoESTRUCilVE EXAMINAil0N ONLY)
E anco -
3 U R g .#m -
Ko M I '
5 g.
~
CD
- E 2cos -
20,000 - 80 .
10os -
- Go .
AO HO i Do l i IFn i l i .
,_ , i I i i 16 20 2e o 4 s 12 ilE IN WAKR STORAGE AS OF 1908, yr FIGURE 3. Sunnary of Spent Fuel Examinations to Define Effects of Water Storage (Ref. 6)
S I i\ \ ca I m{ l i 2
\ b Je B a *
\ -
541 g ,
. e D \ \ e s e
- \ \ 3 -
3 ;
~
- \ \ E3 - J
= s \ \ I: e
- 5 \ \ QA -
3
\
~R 1 -
\
\ 5 ~ E-a t
\ \ s. %
c t
e e
m
, \ E o . m
\ g -
\\
. \ - .
E \ g\ I h \ q
- ,E
- m P i" e W u e
. m 5
$5
- Z T
. , c
- m - g s$s Y
- 3 4 N L
% o
~
. m E
o .
- g -
y w
e S
. _ g -
e g
~
i i i 1 i I o o o o o o o o o o o o o o o C. C. C. C. C. C. C.
o o o o o o o l
8 m o e m u -
n4m/pmW 'dnuanE '
19 .
i '
j j .i 300 i I I I I I I I g i g i .
250 -
j 200 - p,,, g,,,,, p,,g,,,,,
so- .
on Current Specificationg ,
E -
I = 150 -
tc 3:
.a 10 0 -
c 80 -
- n. -
. 60 -
E Increased Burnup Projected -
@ iZ 40 -
to 50,000 Mwd /meu PWR Itistorical -*--
E 8 41,000 Mwd /mlU BWR ~
20 -
by 1990
, / .
- s' . ~
10 -
l_g Projected I I I i i l 1 l' I I I l i O 1990
~
1970 1974 1978 1982 1986 1962 1966 FIGURE 5. Historical and Projected Quantities of Plutonium Produced in Nuclear Power Plants (Ref. 7)
I I I I I I I l I I I I 1
1 e
af 50,000 -
e
~
Fuel Burnup Projected p.M p '
a gg,2,)g ui on. Cwrent Specificollon -
30,000 - c ft
.p' i'%'
i 3:
J
.E a
m E 10,000 -- Historical *---- lacreased Burnup Projected f .
o
, 2 -
- - Projected l 1.000 --
~
I I I I I I I I I I I I O
1978 1982 1986 1990 1966 1970 1974 Historical and Projected Total Quantities of Uranium in FIGURE 6.
li Discharged Fuel (Ref. 7) e I
I
1.5
. k m
I ~
-=
Bl 58 0.5 U
5
'. 47,000 o
l45,000 -
a' I -
g 40,000 W
b 8
m E
34,000 1980 19 5 1990 1995 YEAR FIGURE 7. Transition of PWR Industry to High Burnup (Ref. 3) 4 l
22
_. REFERENCES (1) W. J. Bailey, K. H. Rising, and M. Tokar, Fuel Performance Annual Report for 1980. NUREG/CR-2410 (PNL-3953), in publication.
(2) R. J. Williams, et al., Experience with BWR Fuel Through' January 1981.
NEDE-24343-P, May 1981. This document is not publicly available becuse it contains proprietary information.
(3) Df G. Franklin, " Economic Impact of Nuclear Core Materials Limitations,"jd , e'T Nuclear Technoloay 55(3):607-616 December 1981. . gc> 'y (4) F. J. Arsenault (NRC-RES), Memorandum to R. J. Mattson (NRC-NRR), "High Burnup Fuels, Request for Information," October 13, 1981.
(5) P. M. Lang, Office of Nuclear Energy, U.S. Department of Energy, private communication (a table entitled " Extended Burnup Fuel Demonstrations:
Current Product-Line Fuel"), August 1981.
(6) E. R. Bradley, W. J. Bailey, A. B. Johnson, Jr., and L. M. Lowry, Examination of Zircaloy-Clad Spent Fuel After Extended Pool Storage.
PNL-3921, September 1981. .
(7) S. E. Turner, W. J. Elgin, and R. P. Hancock, Historical Survey of Nuclear Fuel Utilization in U.S. LWR Power Plants. SSA-122 (DOE /ER/10020-TI) August 1979.
(8) J. T. A. Roberts, et al., LWR Fuel Ferformance Program: Progress in 1978. EPRI NP-1024-SR, 1979.
(9) D. G. Franklin, H. Ocken, and T. Oldberg, LWR Core Materials Perfortnance Program: Progress in 1979-1980. EPRI NP-1770-SR, March 1981.
(10) J. T. A. Roberts, et al., "The EPRI LWR Surveillance Program," IAEA
. Specialists' Meeting on Examination of Fuel Assembly for Water fo3Ted Power Reactors, Tokyo, Japan, November 1981. (Paper No. 5).
l (11) R. Manzel and H. Knaab, "Perfonnance Evaluation of LWR-Fuel," IAEA l Specialists' Meeting on Examination of Fuel Assembly for Water Cooled Power Reactors, Tokyo, Japan, November 1981. (Paper No.14).
(12) J. O. Roberts, S. M. Davis, and D. A. Nash, Coal and Nuclear: A Comparison of the Cost of Generating Baseload Electricity by Region.
NUREG-0480, 1978.
(13) E. Hillner, Corrosion and Hydriding Performance Evaluation of Three Zircaloy-2 Clad Fuel Assemblies Af ter Continuous Exposure in PWR Cores 1 and 2 at Shippingport. Pennsylvania. WAPD-TM-1412, January 1980.
23
(14) E. Hillner, " Corrosion and Hydriding Performance of Zircaloy Tubing After Extended Exposure in the Shippingport Pressurized Water Reactor."
Zirconium in Nuclear Applications, ASTM STP 551, American Society for Testing and Materials, (pp. 449-462) 1974.
(15) A. B. Johnson, Jr., W. J. Bailey, R. E. Schreiber, and F. M. Kustas, Annual Report-FY1979. Spent Fuel and Fuel Pool Component ~ Integrity.
PNL-3171, May 1980.
(16) A. B. Johnson, Jr., and W. J. Bailey, Scientific Basis for Confidence that Spent Fuel Can Be Stored Until Geologic Disposal Facilities are Available. PML-5A-8197, January 1980. (This was PNL's contribution to "Section IV-Extended Storage Assessment" of DOE's draft for NRC l Caifidence Rulemaking. The DOE testimony was issued as DOE /NE-007 on April 15,1980).
(17) W. H. Bachman, J. J. Beanderean, and W. J. Lippold, " Fuel Management Schemes for Extended Burnup in CE Operating Reactors," Trans. Am. Nucl.
Soc. 33:395,1979.
(18) J. Skaritka and J. A. Iorii, Operational Experience with Westinghouse Cores (up to December 31. 1980). WCAP-8183, Revision 10, May 1981.
(19) M. Tokar, W. J. Bailey, and M. E. Cunningham, Fuel Performance Annual Report for 1979. NUREG/CR-1818 (PNL-3583), January 1981.
(20) J. Skaritka and J. A. Iorii, Operational Experience with Westinghouse Cores (up to December 31. 1979). WCAP-8183, Revision 9, April 1980.
(21) J. Skaritka and J. A. Iorii, Operational Experience with Westinghouse Cores (up to December 31. 1978). WCAP-8183, Revision 8, April 1979.
l (22) T. L. O'Hara and J. A. Iorii, Operational Experience with Westinghouse Cores (up to December 31. 1977). WCAP-8183, Revision 7, March 1978.
(23) R. E. Schreiber and J. A. Iorii, Operational Experience with Westinghouse Cores (up to December 31. 1976). WCAP-8183, Revision 6, June 1977.
(24) E. Roberts, et al., " Fuel Modeling and Performance of High Burnup Fuel Rods," American Nuclear Society Topical Meeting on Water Reactor Fuel i
Performance, St. Charles, Illinois, May 1977 (pp.133-135).
l (25) J. T. Mayer, et al., "B&W Fuel. Performance to 40,000 mwd /MTU Burnup,"
Trans. Am. Nucl. Soc. 38:286-287, June 1981.
24
? 9 i
,7n-, - - . , - - - - , - - - - , , , , - - , , - - , , - - . . - - - - - , - - - - - -
APPENDIX ,
The distribution of discharged high-burnup BWR fuel assemblies is shown in Table A1. Through January 1981, over [ ] fuel assemblies have attained burnups in the [ ] to [ ] mwd /MTU. range (Ref. 2).
Other notes: In Table 4, the one fuel assembly (29,000 mwd /MTU burnup) at Quad Cities-1 was charged into the reactor in [ ]
and was discharged in [ ] (Ref. 2). In Table 5, the one fuel assembly (40,000 mwd /MTV'burnup) at Monticello was charged into the reactor in [ ] (Ref. 2).
e ,
e A.1
I e9
- e ,
e t
9 o
ENCLOSURE D
~' _ ~ - . _ _ _ . . _ _ _ _ _ _ _
1 [7590-01]
NUCLEAR REGULATORY COMMISSION 10 CFR Part 51 (Docket No. PRM-51-6)
AGENCY: Nuclear Regulatory Commission ACTION: Notice of Denial of Petition for Rulemaking
SUMMARY
- The Nuclear Regulatory Commission is denying a petition for rulemaking submitted on March 17, 1980, by Ms. Catherine Quigg on behalf of Pollution and Enviromental Problems, Inc., which requests that 10 CFR Part 51 be amended to require the preparation of an environmental impact statement on the generic environmental impacts of high burnup nuclear fuel as used in commercial nuclear reactors, stored in spent fuel pools or cooling racks, or potentially as processed in reprocessing plants or disposed of in permanent waste disposal sites.
ADDRESSES: Copies of comments and documents cited in this notice are available for public inspection at the NRC Public Document Room,1717 H Street, NW.,
Washington, D.C.
FOR FURTHER INFORMATION CONTACT:
Mr. Morton R. Fleishman, Office of Nuclear Regulatory Research, U. S. Nuclear Regulatory Commission, Washington, D.C. 20555, Telephone 301-443-7616.
Enclosure D
2 [7590-01]
SUPPLEMENTARY INFORMATION:
Background:
On March 17, 1980, Ms. Catherine Quigg filed a petition for rulemaking with the NRC (Docket No. PRM-51-6) on behalf of Pollution and Environmental Problems, Inc. Notice of receipt of this petition and a request for comments was published in the Federal Register on April 15, 1980 (45 FR 25557).
The petitioner contends that the use of high burnup fuel
- could have the following significant effects upon the human environment:
- 1. Greater fission gas releases from nuclear reactors.
- 2. Increased fission gas releases from spent fuel pools.
- 3. Production of " Inferior grade" spent fuel which can lead to long term environmental hazards.
- 4. Potential for greater radiological imoact from reactor and spent fuel
. pool accidents.
- 5. Increased radioactive material releases during reprocessing.
The petitioner requests that 10 CFR Part 51 be amended to require that a full environmental impact statement be prepared covering the generic environ-mental impacts of high burnup nuclear fuel.
- The length of use, or total energy generated, or "burnup" of fuel in a reactor is measured in terms of megawatt days per metric ton of uranium (Mwd /MtU) or Gwd/Mtu where 1 Gwd/MtU = 1000 Mwd /Mtu. Typically, fuel has been removed from reactors after 3 to 5 years with burnuo levels of 28 Gwd/MtU for boiling water reactors and 33 Gwd/MtU for pressurized water reactors. "High" or " Extended" burnup nuclear fuel is considered, for the purpose of this discussion, to be fuel that is left in a reactor long enough to achieve a burnup of greater than 40 Gwd/Mtu. Burnup levels of up to about 60 Gwd/MtU are beino considered.
- Enclosure D
3 [7590-01]
Fourteen (14) public comment letters have been received relative to the subject petition for rulemaking. These may be examined in the NRC public docu-ment room. Three commenters were in favor of the petition and' eleven commenters opposed the petition. All coment letters have been evaluated by the NRC staff.
Discussion:
The request of the petitioner was that the Commission amend 10 CFR Part 51, " Licensing and Regulatory Policy and Procedures for Environmental Pro-tection," of its regulations to require the preparation of an environmental impact statement (EIS) on the subject covered by the petition. At the time the petition was submitted there already existed a requirement (10 CFR 951.5(a)(10)) that mandated an EIS under certain conditions. Furthermore, 551.5(c) required that a negative declaration and environmental impact appraisal be prepared if it is detemined that an EIS is not needed. During 1984, 10 CFR Part 51 was almost completely rewritten and reorganized. New 151.20(a)(1) and $51.20(b)(13) include language similar to that in the old
$51.5(a)(10) and new $51.21 requires an environmental assessment (EA) be made i
for certain regulatory actions. The Comission concludes that an amendment to the regulations, as requested by the petition, is unnecessary because 10 CFR
]
951.20 already provides an adequate basis for the preparation of an EIS with regard to high burnup fuel on a commercial scale by requiring an EIS for J "any... action which the Commission determines is a ma,ior Commission action significantly affecting the quality of the human environment." Furthermore, 10 CFR 651.21 requires that an EA be performed for all licensing and Enclosure D
4 [7590-01]
regulatory actions applicable to NRC's domestic licensing and related regulatory functions. The EA is to " provide sufficient evidence and analysis for deteming whether to prepare an environmental impact statement or a finding of no significant impact." Finally, the NRC regulations are already in compliance with the Comission on Environmental Quality (CEQ) guidelines for preparing environmental impact statements.
The Comission, therefore, denies the petition.
4 However, indications from the nuclear utility industry are that there will be an increasing number of applications for license amendments pemitting use of high burnup fuel. The trend is expected to be cautious at first, but if the fuel performs satisfactorily and if current economic paraneters remain constant, the trend is expected to continue so that within the next 10 to 12 years most licensees will plan for burnups of 45 Gwd/MtU or more. In view of this trend, the Comission thinks that the petitioner's concern about the environmental impact has merit. The Comission believes that it is both prudent and timely to evaluate the significance of this effect. Therefore, the Comission has initiated preparation of an EA on the potential use of high burnup fuel to provide the information necessary to determine whether a more detailed EIS is warranted. We expect the assessment to be completed by mid-1986.
l Enclosure D ,
5 [7590-01]
Dated at Washington, D.C. this day of , 1986.
For the Nuclear Regulatory Comission Samuel J. Chilk, Secretary of the Comission.
I Enclosure D
e 6
9 e.
O ENCLOSURE E
i Ms. Catherine Quigg i 838 Harriet Lane Barrington, IL 60010
Dear Ms. Quigg:
This letter is in response to the petition for rulemaking submitted by you on behalf of Pollution and Environmental Problems, Inc., dated March 17, 1980.
The petition requested that 10 CFR Part 51 be amended to require a full Environmental Impact Statement be prepared covering the generic environmental impacts of high burnup nuclear fuel as used in comercial nuclear reactors, stored in spent fuel pools or cooling racks and potentially as processed in reprocessing plants or disposed of in permanent sites.
You were notified of receipt of the petition and of the notice of petition and request for comments in the FEDERAL REGISTER.
After reviewing the petition, and the comments received from the public, its licensing experience and current policies, and other factors, the Commission has denied the petition for rulemaking. The bases for this decision are set forth in the enclosed notice of denial.
In view of the anticipated increase in applications for the use of high burnup fuel, the Commission has initiated preparation of an environmental assessment to determine if an environmental impact statement is warranted. We expect the assessment to be completed in mid-1986.
Sincerely, Samuel J. Chilk Secretary of the Comission
Enclosure:
FEDERAL REGISTER Notice Enclosure E