[Date Prev][Date Next][Date Index]

E-M:/ Ingham County's Environmental Forum: No more secrets?

Enviro-Mich message from joonmck <joonmck@gateway.net>

Dear EMers,

The Ingham County Health Department has just opened up a community forum
on the environment. On Monday, January 22, Bob Godbold, the director of
the Environmental Health Bureau there, was the guest host of the forum.
I think it might be of interest to EMer's to note Mr. Godbold's response
to my question that day. You can read it at:  


Feel free to make your own comments to the forum.



"Alex J. Sagady & Associates" wrote:
> -------------------------------------------------------------------------
> Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>
> -------------------------------------------------------------------------
> Federal Register: January 25, 2001 (Volume 66, Number 17)]
> [Notices]
> [Page 7815-7818]
>  >From the Federal Register Online via GPO Access [wais.access.gpo.gov]
> [DOCID:fr25ja01-51]
> -----------------------------------------------------------------------
> [DOCKET NO. 50-341]
> Detroit Edison Company; Fermi 2 Environmental Assessment and
> Finding of no Significant Impact
>      The U.S. Nuclear Regulatory Commission (NRC) is considering
> issuance of an amendment to Facility Operating License No. NPF-43
> issued to Detroit Edison Company (the licensee), for operation of Fermi
> 2, located in Monroe County, Michigan.
> Environmental Assessment
> Identification of the Proposed Action
>      The proposed action would revise the Fermi 2 Technical
> Specifications (TSs) by changing (1) the design features description of
> the fuel storage equipment and configuration to allow an increase in
> the spent fuel pool (SFP) storage capacity and (2) the description of
> the high-density spent fuel racks program to clarify that the
> surveillance program is applicable only to racks containing Boraflex as
> a neutron absorber.
>      Currently, the SFP for Fermi 2 has 14 freestanding high-density
> (Boraflex) fuel racks, four General Electric (GE) low-density racks,
> and a rack for defective fuel, for a total storage capacity of 2414
> fuel assemblies. As part of a proposed modification, the licensee plans
> to increase Fermi 2's spent fuel storage capacity by 2194 spaces in a
> three-phase operation. In phase one, four additional high-density racks
> will be added to open spaces in the SFP. In phase two, the GE racks,
> the rack for defective fuel, and one high-density rack would be
> replaced with five new high-density racks. In phase three, the
> remaining 13 existing racks would be replaced with 14 new high-density
> racks. At the completion of phase three, the entire available floor
> space of the pool would be occupied with fuel storage racks providing
> for a total storage capacity of 4608 assemblies. Two platforms will be
> installed above the new high-density fuel storage racks to accommodate
> storage of miscellaneous activated components.
>      The proposed action is in accordance with the licensee's
> application for
> [[Page 7816]]
> amendment dated November 19, 1999, as supplemented on May 31, August 2,
> October 19, and November 21, 2000.
> The Need for the Proposed Action
>      The proposed action is needed to maintain full core offload
> capability by expanding the spent fuel storage capacity. The licensee
> estimates that it will lose the ability to fully offload the reactor
> fuel by June 2001. The expanded storage capacity would extend full core
> offload capability to the year 2015. The current Fermi 2 operating
> license authorizes plant operations through March 20, 2025.
> Environmental Impacts of the Proposed Action
> Radioactive Wastes
>      The existing contaminated fuel storage racks will be the main
> source of radioactive waste for the proposed modification. The racks
> will be washed prior to being removed from the pool to remove as much
> contamination as possible. The racks will then be shipped, using a
> special Department of Transportation approved container, to a volume
> reduction facility for processing and subsequent disposal at an
> authorized burial site.
>      In order to maintain the SFP water as clean as possible, underwater
> vacuuming of the SFP will be used to remove radioactive crud, sediment,
> and other debris generated in the rack replacement. Filters from use of
> this underwater vacuum system will also be a source of solid radwaste.
>      The impact of the expanded fuel storage capacity on the production
> and release of radioactive waste during normal operations is not
> expected to be significant. The level of radioactive contamination in
> the pool water impacts the amount of solid waste produced by pool
> purification system resins, as well as the liquid effluents originating
> from SFP water. Radioactive gases that evolve from the surface of the
> pool also contribute to the plant's gaseous effluents. However, the
> levels of gaseous and particulate radioactivity in the pool water are
> dominated by the most recent reactor core offload to the SFP, not the
> older cooled fuel stored in the pool. Therefore, the storage of
> additional aged spent fuel assemblies resulting from this proposed
> design change will have a minimal contribution to the levels of
> radioactivity in the pool water.
>      On the basis of its review of the Fermi 2 license amendment
> request, the NRC staff concludes that the proposed increase in spent
> fuel storage capacity (1) is not expected to result in an increase in
> the amount of gaseous tritium released from the SFP; (2) will result in
> a negligible increase in the amount of radioactive liquid released to
> the environment; and, (3) will not result in a significant increase in
> the volume of solid radioactive waste. Finally, small amounts of
> additional waste resin may be generated by the SFP's clean-up systems
> on a one-time basis. Shipping containers for these resins, the old
> racks, and debris generated by reracking will conform to 10 CFR part
> 71, ``Packaging and Transportation of Radioactive Material,'' and the
> requirements of States through which shipments may pass. Therefore, the
> NRC staff finds that, with regard to radioactive waste, the proposed
> increase in spent fuel storage capacity at Fermi 2 is acceptable.
> Radiological Impact Assessment
>      The NRC staff has reviewed the licensee's plan for the replacement
> of the existing SFP storage racks at Fermi 2 with respect to
> occupational radiation exposure. As stated above, the licensee plans to
> replace the existing fuel storage racks in the SFP with 23 new high-
> density racks. A number of facilities have performed similar operations
> in the past. On the basis of the lessons learned from these operations,
> the licensee estimates that the proposed fuel rack installation can be
> performed within a radiological dose estimate of approximately 12
> person-rem. This estimate includes the rad-waste processing of the
> existing contaminated racks, as well as the projected dose to divers,
> in the event they are used, consistent with the licensee's contingency
> plan.
>      All of the operations involved in the fuel rack installations will
> utilize detailed procedures prepared with full consideration of as low
> as reasonably achievable (ALARA) principles. Workers performing the SFP
> re-racking operation will be given pre-job briefings to ensure that
> they are aware of their job responsibilities and precautions associated
> with the job. The licensee will monitor and control work, personnel
> traffic, and equipment movement in the SFP area to minimize
> contamination and to assure that exposures are maintained ALARA.
> Personnel will wear protective clothing and respiratory protective
> equipment, if necessary. Alarming dosimeters will be used as needed to
> confirm exposure and dose rates, while thermal luminescent dosimeters
> (TLDs) will be used to officially document the dose received.
> Additional personnel monitoring equipment (such as extremity TLDs or
> multiple TLDs) will be issued for appropriate tasks.
>      As indicated previously, the licensee intends to complete the
> three-phase fuel rack replacement without the use of divers in the
> pool. Removal of existing racks and installation of the new racks are
> expected to be completed remotely from the surface of the pool.
> However, if diving is necessary, the licensee has developed a
> contingency plan that includes diving procedures that are consistent
> with Regulatory Guide 8.38, Appendix A, in terms of diver restraint,
> radiological monitoring, physical monitoring, and standard SFP diving
> operations.
>      Prior to any diving operations, the radioactive sources in the pool
> will be configured to maximize the distance and shielding of the
> divers. Three dimensional radiation surveys will be performed with
> appropriate equipment. In addition, the divers will be equipped with
> monitors to survey the work area during each dive. The licensee will
> utilize underwater TV cameras to maintain visual contact with the
> divers during all diving operations. The divers will also be physically
> restrained by a dive tender with a tether contained in the dive
> umbilical. The SFP water will be continuously filtered through the SFP
> purification system in order to maintain water clarity. In addition,
> the licensee will vacuum the SFP floor prior to initiation of the
> diving operation and will vacuum the pool additional times during the
> diving operation, if it should become necessary, to maintain diver
> doses ALARA. Each diver will be equipped with whole body and extremity
> dosimetry (including alarming dosimetry) with remote, above surface,
> readouts that will be continuously monitored by radiation protection
> personnel.
>      All items removed from the pool, as well as divers, if used, will
> be monitored for radiation and contamination. This monitoring will be
> performed in isolated ``bull pens'' that separate the potentially
> contaminated areas from the rest of the refueling floor. The bull pens
> will minimize the possible spread of contamination, including ``hot
> particles'' (or discrete radioactive particles (DRPs)). Based on the
> Fermi 2 operating history and fuel integrity experience, the licensee
> does not anticipate any significant radiological challenges from DRPs.
>      The licensee assessed the radiological exposure impact of the
> proposed SFP design change on areas of the plant during normal
> operations. Revised shielding calculations indicate that the dose rates
> through the east and west walls of the pool would have only a modest
> increase (to 0.6 mrem/hr compared to the previous maximum of
> [[Page 7817]]
> 0.5 mrem/hr). The maximum dose rates in the equipment storage room,
> adjacent to the north wall of the pool, increased to 400 mrem/hr. These
> calculations are based on the conservative assumption that all
> assemblies in the storage array have cooled for only 60 hours. The
> actual operational dose rates in this area will depend upon the age of
> the fuel stored in the north end of the pool. In addition, this area is
> not a normally occupied room and can be controlled as a high radiation
> area consistent with the requirement in 10 CFR part 20. The licensee
> has provided marked up radiation zoning maps from the Fermi 2 Updated
> Safety Analysis Report to reflect these design changes.
>      On the basis of the NRC staff review of the Fermi 2 license
> amendment, the NRC staff concludes that the proposed increase in spent
> fuel storage capacity at Fermi 2 can be performed in a manner that will
> ensure that doses to the workers will be maintained ALARA. The NRC
> staff finds that the projected dose for the project of 12 person-rem is
> in the range of doses for similar modifications at other plants and is,
> therefore, acceptable.
> Accident Considerations
>      The proposed modification increases the spent fuel storage
> capacity, but it does not change the method for handling spent fuel
> assemblies.
>      The proposed expansion of the SFP will not affect any of the
> assumptions or inputs used in evaluating the dose consequences of a
> fuel handling accident and, therefore, will not result in an increase
> in the doses from a postulated fuel handling accident.
> Environmental Impact Conclusions
>      The proposed action will not significantly increase the probability
> or consequences of accidents, no changes are being made in the types of
> any effluents that may be released off-site, and there is no
> significant increase in occupational or public exposure. Therefore,
> there are no significant radiological environmental impacts associated
> with the proposed action.
>      With regard to potential nonradiological impacts, the proposed
> action does not involve any historic sites. It does not affect
> nonradiological plant effluents and has no other environmental impacts.
> Therefore, there are no significant nonradiological environmental
> impacts associated with the proposed action.
>      Accordingly, the NRC concludes that there are no significant
> environmental impacts associated with the proposed action.
> Alternatives to the Proposed
> Shipping Fuel to a Permanent Federal Fuel Storage/Disposal Facility
>      Shipment of spent fuel to a high-level radioactive storage facility
> is an alternative to increasing the onsite spent fuel storage capacity.
> However, the U.S. Department of Energy's (DOE's) high-level radioactive
> waste repository is not expected to begin receiving spent fuel until
> approximately 2010, at the earliest. To date, no interim Federal
> storage facility has yet to be approved in advance of a decision on a
> permanent repository. Therefore, shipping the spent fuel to the DOE
> repository is not considered an alternative to increasing the onsite
> fuel storage capacity at this time.
> Shipping Fuel to a Reprocessing Facility
>      Reprocessing of spent fuel from Fermi 2 is not within the
> reasonable range of alternatives since there are no operating
> commercial reprocessing facilities in the United States. Therefore,
> spent fuel would have to be shipped to an overseas facility for
> reprocessing. However, this approach has never been used and it would
> require approval by the Department of State as well as other entities.
> Additionally, the cost of spent fuel reprocessing is not offset by the
> salvage value of the residual uranium; reprocessing represents an added
> cost.
> Shipping the Fuel Offsite to Another Utility or Private Fuel Storage
> Facility
>      The shipment of fuel to another utility or transferring fuel to
> another of the licensee's facilities would provide short-term relief at
> Fermi 2. The Nuclear Waste Policy Act of 1982, Subtitle B, Section
> 131(a)(1), however, clearly places the responsibility for the interim
> storage of spent fuel with each owner or operator of a nuclear plant.
> The SFPs at the other reactor sites were designed with capacity to
> accommodate spent fuel from those particular sites. Therefore,
> transferring spent fuel from Fermi 2 to other sites would create
> storage capacity problems at those locations. The shipment of spent
> fuel to another site is not an acceptable alternative because of
> increased fuel handling risks and additional occupational radiation
> exposure, as well as the fact that no additional storage capacity would
> be created.
>      The shipment of fuel to a private fuel storage facility is an
> alternative to increasing the onsite spent fuel storage capacity.
> However, a private fuel storage facility is not licensed at this time.
> Therefore, shipping the spent fuel to a private fuel storage facility
> is not considered an alternative to increased onsite fuel storage
> capacity at this time.
> Alternatives Creating Additional Storage Capacity
>      Alternative technologies that would create additional storage
> capacity include rod consolidation, dry cask storage, modular vault dry
> storage, and constructing a new pool. Rod consolidation involves
> disassembling the spent fuel assemblies and storing the fuel rods from
> two or more assemblies into a stainless steel canister that can be
> stored in the spent fuel racks. Industry experience with rod
> consolidation is currently limited, primarily due to concerns for
> potential gap activity release due to rod breakage, the potential for
> increased fuel cladding corrosion due to some of the protective oxide
> layer being scraped off, and because the prolonged consolidation
> activity could interfere with ongoing plant operations. Dry cask
> storage is a method of transferring spent fuel, after storage in the
> pool for several years, to high capacity casks with passive heat
> dissipation features. After loading, the casks are stored outdoors on a
> seismically qualified concrete pad. Concerns for dry cask storage
> include the need for special security provisions and high cost. Vault
> storage consists of storing spent fuel in shielded stainless steel
> cylinders in a horizontal configuration in a reinforced concrete vault.
> The concrete vault provides missile and earthquake protection and
> radiation shielding. Concerns for vault dry storage include security,
> land consumption, eventual decommissioning of the new vault, the
> potential for fuel or clad rupture due to high temperatures, and high
> cost. The alternative of constructing and licensing new spent fuel
> pools is not practical for Fermi 2 because such an effort would require
> about 10 years to complete and would be an expensive alternative.
>      The alternative technologies that could create additional storage
> capacity involve additional fuel handling with an attendant opportunity
> for a fuel handling accident, involve higher cumulative dose to workers
> affecting the fuel transfers, require additional security measures that
> are significantly more expensive, and would not result in a significant
> improvement in environmental impacts compared to the proposed reracking
> modifications.
> Reduction of Spent Fuel Generation
>      Generally, improved usage of the fuel and/or operation at a reduced
> power level would be an alternative that would decrease the amount of
> fuel being stored in the SFPs and, thus, increase the
> [[Page 7818]]
> amount of time before the maximum storage capacities of the SFPs are
> reached. With extended burnup of fuel assemblies, the fuel cycle would
> be extended and fewer off-loads would be necessary. This is not an
> alternative for resolving the loss of full core off-load capability
> that will occur as a result of Fermi 2 receiving new fuel for Cycle 9
> in June 2001. In addition, operating the plant at a reduced power level
> would not make effective use of available resources and would cause
> unnecessary economic hardship on the licensee and its customers.
> Therefore, reducing the amount of spent fuel generated by increasing
> burnup further or reducing power is not considered a practical
> alternative.
> The No-Action Alternative
>      The NRC staff, also, considered denial of the proposed action
> (i.e., the ``no-action'' alternative). Denying the application would
> result in no significant change in current environmental impacts. The
> environmental impacts of the proposed action and the alternative
> actions are similar.
> Alternative Use of Resources
>      This action does not involve the use of any resources not
> previously considered in the Final Environmental Statement for Fermi 2.
> Agencies and Persons Contacted
>      In accordance with its stated policy, on December 11, 2000, the NRC
> staff consulted with the Michigan State official, M. Eldsman of the
> Michigan Public Service Commission, regarding the environmental impact
> of the proposed action. The state official had no comments.
> Finding of No Significant Impact
>      On the basis of the environmental assessment, the NRC concludes
> that the proposed action will not have a significant effect on the
> quality of the human environment. Accordingly, the NRC has determined
> not to prepare an environmental impact statement for the proposed
> action.
>      For further details with respect to the proposed action, see the
> licensee's letter dated November 19, 1999, as supplemented by letters
> dated May 31, August 2, October 19, and November 21, 2000, which are
> available for public inspection at the NRC's Public Document Room,
> located at One White Flint North, 11555 Rockville Pike (first floor),
> Rockville, Maryland. Publicly available records will be accessible
> electronically from the ADAMS Public Library component on the NRC Web
> site, http://www.nrc.gov (the Electronic Reading Room).
>      Dated at Rockville, Maryland, this 19th day of January, 2001.
>      For the Nuclear Regulatory Commission.
> Claudia M. Craig,
> Section Chief, Section 1, Project Directorate III, Division of
> Licensing Project Management, Office of Nuclear Reactor Regulation.
> [FR Doc. 01-2304 Filed 1-24-01; 8:45 am]
> BILLING CODE 7590-01-P
> ----------------------------------------------------------------------------
> Alex J. Sagady & Associates        Email:  ajs@sagady.com
> Environmental Enforcement, Permits/Technical Review, Public Policy and
> Communications on Air, Water and Waste Issues
> and Community Environmental Protection
> PO Box 39  East Lansing, MI  48826-0039
> (517) 332-6971 (voice); (517) 332-8987 (fax)
> ----------------------------------------------------------------------------
> ==============================================================
> ENVIRO-MICH:  Internet List and Forum for Michigan Environmental
> and Conservation Issues and Michigan-based Citizen Action.   Archives at
> http://www.great-lakes.net/lists/enviro-mich/
> Postings to:  enviro-mich@great-lakes.net      For info, send email to
> majordomo@great-lakes.net  with a one-line message body of  "info enviro-mich"
> ==============================================================

ENVIRO-MICH:  Internet List and Forum for Michigan Environmental
and Conservation Issues and Michigan-based Citizen Action.   Archives at

Postings to:  enviro-mich@great-lakes.net      For info, send email to
majordomo@great-lakes.net  with a one-line message body of  "info enviro-mich"