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This Addendum to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, May 1996, supplements the analyses reported in Section 6.3 "Transportation," and especially Section 6.3.2, "Table S-4-Environmental Impacts of Transportation of Fuel and Waste to and From One Light-Water-Cooled Nuclear Power Reactor" of that report. The analyses reported in this addendum specifically address whether the environmental impacts of the transportation of higher enrichment and higher burnup spent nuclear fuel are consistent with the values of 10 CFR 51.52, Table S-4 as applicable to license renewal, continue to be applicable given that it is likely that spent fuel will be shipped to a single destination, such as the proposed repository at Yucca Mountain in Nye County, Nevada, and given that spent fuel shipments will involve higher enrichment and higher burnup fuel than was assumed in calculating the impacts shown in Table S-4. The analyses reported in this Addendum provide the basis for amending the U.S. Nuclear Regulatory Commission's (NRC) regulations for addressing the environmental impacts associated with the transportation of fuel and waste to and from a commercial nuclear power plant within the context of the license renewal review process. The amendment is to the provisions in 10 CFR 51.53(c) and in Appendix B to Subpart A of 10 CFR Part 51 which specify how Table S-4 is to be used in individual license renewal reviews. The values in Table S-4 are found to be bounding when accounting for spent fuel shipments to a single destination and for the shipment of higher enriched and higher burnup fuel. The amendment affects only the provisions in §51.53(c) and Appendix B to Subpart A that govern the use of impact values codified in 10 CFR 51.52 as it applies to reviews to renew the operating license of individual nuclear power plants. It is not intended that this Addendum support any other regulatory decision by the NRC.
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In NUREG-1437, Section 6.3 ("Transportation"), the radiological and nonradiological environmental impacts resulting from transportation of low-level radioactive waste and mixed waste(1) to off-site disposal facilities and of spent fuel to a monitored retrievable storage facility or a permanent repository were assessed. The environmental impacts from the transportation of fuel and waste attributable to license renewal were found to be small when they are within the impact parameters identified in 10 CFR 51.52. The findings in NUREG-1437 were codified in an amendment to 10 CFR Part 51 published in the Federal Register on June 5, 1996 (61 FR 28467). Public comments were solicited on the use of Table S-4 and several other areas of the final rule. This comment process identified two questions that should be addressed generically rather than requiring each license renewal applicant to address them individually. The first question is whether the environmental impact values contained in Table S-4 are still appropriate for use in license renewal reviews if spent fuel is transported to a single destination such as the candidate repository at Yucca Mountain, Nevada, even though the values in Table S-4 were developed from data reflecting spent fuel shipments to several destinations. The second question is whether the environmental impact values contained in Table S-4 are still appropriate for use in license renewal reviews given that applicants will be shipping spent fuel that is more highly enriched and irradiated longer than is accounted for in the analysis to develop Table S-4. Paragraph 51.52(a) requires a plant-specific analysis of transportation impacts if the uranium-235 enrichment exceeds 4 percent or if the average level of irradiation exceeds 33,000 megawatt-days per metric ton of uranium (MWd/MTU). The analyses in this Addendum are limited to these two questions. Numerous public comments that question the scope of the analyses were submitted on the draft Addendum. These comments and the NRC responses found in Appendix 1 provide further understanding of the purpose and scope of this Addendum to NUREG-1437.
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On June 5, 1996, the Commission published in the Federal Register (61 FR 28467) a final rule amending its environmental protection regulations in 10 CFR Part 51 to improve the efficiency of the process of environmental review for applicants seeking to renew a nuclear power plant operating license for up to an additional 20 years. The rulemaking was based on the analyses reported in NUREG-1437 and was initiated with the objectives of (1) improving the efficiency of the license renewal process by drawing on the considerable experience of operating nuclear power plants in generic assessments of many of the environmental impacts, (2) reporting the analyses and findings in NUREG-1437, (3) codifying the findings in the Commission's environmental protection regulations so that repetitive reviews of those impacts that are well understood could be avoided.
In the statement accompanying the final rule, the Commission solicited comments on the treatment of low-level waste storage and disposal impacts, the cumulative radiological effects from the uranium fuel cycle, and the effects from the disposal of high-level waste (HLW) and spent fuel. The final rule would not become effective until these comments had been considered. A number of commentors argued that the requirements for the review of transportation of high-level waste in the rule were unclear with respect to (1) the use and legal status of 10 CFR 51.52, "Environmental effects of transportation of fuel and waste--Table S-4," in plant-specific license renewal reviews; (2) the conditions that must be met before an applicant may adopt Table S-4; and (3) the extent to which the generic effects of transporting spent fuel to a high-level waste repository should be considered in a plant-specific license renewal review.
After considering the comments received on the rule, the Commission republished the rule in the Federal Register on December 18, 1996 (61 FR 66537). The rule at 10 CFR 51.53(3)(c)(ii)(M) continued to require that "The environmental effects of transportation of fuel and waste shall be reviewed in accordance with 10 CFR 51.52." However, because of the comments received, the Commission added to that paragraph the requirement that
The review of impacts shall also discuss the generic and cumulative impacts associated with transportation operation in the vicinity of a high-level waste repository site. The candidate site at Yucca Mountain should be used for the purpose of impact analysis as long as that site is under consideration for licensing.
Also in response to the comments, the Commission stated that
As part of its effort to develop regulatory guidance for this rule, the Commission will consider whether further changes to the rule are desirable to generically address: (1) the issue of cumulative transportation impacts and (2) the implications that the use of higher burn-up fuel have for the conclusions in Table S-4. After consideration of these issues, the Commission will determine whether the issue of transportation impacts should be changed to Category 1.(2)
Chapter 6 of NUREG-1437 addresses the environmental impacts associated with the management of radiological and nonradiological wastes resulting from license renewal. Section 6.3, "Transportation," addresses the environmental impacts resulting from the shipment of (1) low-level radioactive waste and mixed waste(3) to off-site disposal facilities, (2) fresh fuel to the plant, and (3) spent nuclear fuel (SNF) from the plant to a monitored retrievable storage facility or permanent repository. Section 6.3 also provides an assessment of the applicability to license renewal of 10 CFR 51.52. In Section 6.3.4, the NRC concluded that "The environmental impacts from the transport of fuel and waste attributable to license renewal are found to be small when they are within the range of impact parameters identified in Table S-4." This finding was codified in Table B-1, "Summary of findings on NEPA issues for license renewal of nuclear power plants," of Appendix B to Subpart A of 10 CFR Part 51 in order to extend the use of Table S-4 to license renewal reviews. There were, however, certain circumstances not accounted for in the original analyses supporting Table S-4 and not adequately treated in the 1996 amendment for license renewal.
Summary Table S-4 was published in 10 CFR Part 51 to be used by an applicant for a nuclear power plant construction permit in its environmental report and by the NRC in its environmental impact statements. Table S-4, which accounts for the environmental effects of transportation of fuel and waste to and from the nuclear power plant, was intended to be a generic statement of transportation impacts that can be adopted in the review of any plant, as long as certain conditions identified in Part 51 are met. The environmental impact values in Table S-4 were developed from information available from actual shipments from nuclear power plants to a number of different destinations. Because a single destination at Yucca Mountain is now under consideration, it is necessary to determine whether it is reasonable to continue using the environmental impact values in Table S-4 in license renewal reviews. This Addendum provides the assessment to make that determination.
The environmental implications of the use of more highly enriched and higher burnup fuel than is considered in 10 CFR 51.51 (Table S-3) and in 10 CFR 51.52 (Table S-4) are assessed in NUREG-1437, Section 6.2.3. However, the analysis and conclusions relative to Table S-4 are not brought forward to Section 6.3, "Transportation." This Addendum corrects that omission and expands the assessment of the impacts of transportation of higher enriched and higher burnup fuel. Previously, if fuel enrichment was to exceed 4 percent and burnup was to exceed 33,000 MWd/MTU during the license renewal period, the applicant had to provide a full review of the environmental impacts of transportation of fuel and waste to and from the reactor. For a number of years, licensees have been moving to the use of higher enriched fuel and longer burnup of that fuel than was specified for Table S-4. This Addendum contains an assessment of transportation of fuel having a uranium-235 enrichment of up to 5 percent and irradiated up to 62,000 MWd/MTU. That assessment indicates that the values shown in Table S-4 continue to be a reasonable estimate of environmental impacts of transportation of fuel and waste for the purpose of license renewal reviews.
1. Mixed waste is low-level radioactive waste that also contains chemically hazardous constituents.
2. In NUREG-1437 and in the rule, Category 1 issues are those environmental issues for which the analysis and findings have been determined to be applicable to all nuclear power plants or to plants with specific types of cooling systems or other common plant or site characteristics. Absent new information that significantly changes the finding, these generic findings may be adopted in plant license renewal reviews. Category 2 issues are those environmental issues for which the analysis did not result in a finding common to all plants or to plants with common characteristics. Plant-specific reviews are required for Category 2 issues.
3. Because only the radiological aspects of transportation are of interest here, in the remainder of this report, mixed waste will not be distinguished from other low level-waste.