Supplemental Analyses for Cumulative Environmental Impacts. . .

Response: The DOT regulations do not require that SNF shipments only use federal
highways. Therefore, the NRC assumed that the beltway is a possible route around Las
Vegas.

Comment: The NRC should address the implications of higher enrichment, higher burnup
fuel for consequences of radiological sabotage, as NRC has done so far for the increase in
burnup from 33,000 MWd/MTU to 40,000 MWd/MTU (see 49 FR 23867, Proposed Revisions
to 10 CFR 73, Modification of Protection Requirements for Spent Fuel Shipments, 6/8/84).

Response: The NRC has not quantified the likelihood of the occurrence of sabotage in
this analysis because the likelihood of an individual attack cannot be determined with any
degree of certainty. Nonetheless, the NRC has considered, for the purposes of this
environmental impact statement and rulemaking, the environmental consequences of Such
an event. In the determination of the consequences of such an event, higher burnup is only
one factor. Based on the staff’s study of higher burnup fuel (NUREG-1437, Vol.1,
Addendum 1, Table 2), the consequences of a sabotage event involving such fuel could be
larger than those in the studies referenced by the commentor. However, given that the
consequences of the studies referenced by the commentor were small, even modest
increases due to the effects of higher burnup fuel would not result in unacceptably large
consequences. Because burnup is not the only factor that could affect the consequences of
a sabotage event, the staff continues to study this area. Should new and significant
information result from the further study, actions addressing such information will be
considered.

Nevertheless, the extensive security measures required by NRC regulations make
sabotage events extremely unlikely. Moreover, the casks required to be used to transport
spent fuel are designed to withstand very substantial impacts during transport without loss of
containment integrity. The cask designs should serve to further reduce the likelihood of
release of radioactive material in the extremely unlikely event of sabotage. In view of the fact
that NRC safeguards regulations make sabotage events extremely unlikely, and the fact that
the cask designs themselves should make a release of radioactive material unlikely even
were sabotage to occur, and based on our judgement that, in the extremely unlikely event
that sabotage and releases did occur, the consequences from higher burnup fuel would not
be unacceptably large, we have concluded that a more extensive study of higher burnup fuel
consequences is not warranted for this environmental impact statement and rulemaking.

On June 22, 1999, the Nevada Attorney General filed a petition with the Commission which
requested the NRC to amend regulations governing safeguards for shipments of spent
nuclear fuel against sabotage and terrorism and to initiate a comprehensive assessment. In
particular, the petition indicated that NRC should factor into its regulations the changing
nature of threats posed by domestic terrorists, the increased availability of advanced
weaponry and the greater vulnerability of larger shipping casks traveling across the country.
if, as a result of reviewing this petition, the NRC reaches conclusions that are inconsistent
with the results or assumptions in the present rulemaking, the Commission will need to revisit
the analysis presented here.

Al-17 NUREG-1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

Tabie 3. Estimated cumulative radiation exposure resulting from

SNF transport in Clark County?

Radiation exposure (person-Sv)?

Transport
Incident-free transport accidents
Crew* Public ? Public
From northeast using beltway
without license renewal 12.8 27.7 3.05
From northeast using beltway
with license renewal 19.3 41.4 4.57
From northeast through downtown
without license renewal 14.2 29.0 4.02
From northeast through downtown
with license renewal 21.3 43.5 6.03
From south using beltway
without license renewal 13.2 29.0 5.42
From south using beltway
with license renewal 19.7 43.7 8.13
From south through downtown
without license renewal 11.8 27.4 4.65
From south through downtown
with license renewal 17.7 41.1 6.97

a
Transportation risks were calculated using RADTRAN version 4.0.19.SI, dated March
16, 1999. Access to RADTRAN 4 was furnished on TRANSNET computer system by the U.S.
Department of Energy’s Transportation Technology Center at Sandia National Laboratories.

¢ 1 person Sv = 100 person-rem.

Transport crew size was assumed to be 4 persons (2 people in the truck and 2 people in
the escort vehicle). Crew dose is for the time spent driving In Clark County, approximately 166
to 230 km (approximately 100 to 145 miles); the dose involved in driving to Clark County is not

included.

“The incident-free risk to the public does not include the risk to the crew.

17

NUREG- 1437, Addendum 1


AVAILABILITY NOTICE
Availability of Reference Materials Cited in NRC Publications

NRC publications in the NUREG series, NRC regu-
lations, and Title 10, Energy, of the Code of Federal
Regulations, may be purchased from one of the fol-
lowing sources:

1. The Superintendent of Documents
U.S. Government Printing Office
PO. Box 37082
Washington, DC 20402-9328
<http://www.access.gpo.gov/su_docs>
202-512-1800

2. The National Technical Information Service
Springfield, VA 22161-0002
<http://www.ntis.gov/ordernow>
703—487~—4650

The NUREG series comprises (1) brochures
(NUREG/BR-XXxX), (2) proceedings of confer-
ences (NUREG/CP-XXXX), (3) reports resulting
from international agreements (NUREG/IA-XXXX),
(4) technical and administrative reports and books
[(NUREG-XXXX) or (NUREG/CR-XXXX)], and (5)
compilations of legal decisions and orders of the
Commission and Atomic and Safety Licensing
Boards and of Office Directors’ decisions under
Section 2.206 of NRC's regulations (NUREG-

XXX).

Asingle copy of each NRC draft report is available
free, to the extent of supply, upon written request
as follows:

Address: Office of the Chief Information Officer
Reproduction and Distribution
Services Section
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001
E-mail: <DISTRIBUTION@nrc.gov>
Facsimile: 301-415-2289

A portion of NRC regulatory and technical informa-
tion is available at NRC’s World Wide Web site:

<http://www.nre.gov>

All NRC documents released to the public are avail-
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microfiche, or, in some cases, diskette, from the
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Microfiche of most NRC documents made publicly
available since January 1981 may be found in the
Local Public Document Rooms (LPDRs) located in
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of the LPDRs may be obtained from the PDR (see
previous paragraph) or through:

<http://www.nrc.gov/NRC/NUREGS/
SR1350/V9/Ipdr/htm|>

Publicly released documents include, to name a
few, NUREG-series reports; Federal Register no-
tices; applicant, licensee, and vendor documents
and correspondence; NRC correspondence and
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tices; inspection and investigation reports; licens-
ee event reports; and Commission papers and
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Documents available from public and special tech-
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as books, journal articles, and transactions, Feder-
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and congressional reports. Such documents as
theses, dissertations, foreign reports and transla-
tions, and non-NRC conference proceedings may
be purchased from their sponsoring organization.

Copies of industry codes and standards used in a
substantive manner in the NRC regulatory process
are maintained at the NRC Library, Two White Flint
North, 11545 Rockville Pike, Rockville, MD
20852-2738. These standards are available in the
library for reference use by the public. Codes and
standards are usually copyrighted and may be
purchased from the originating organization or, if
they are American National Standards, from—

American National Standards Institute
11 West 42nd Street

New York, NY 10036-8002
<http://www.ansi.org>
212-642-4900





Supplemental Analyses for Cumulative Environmental Impacts. . .

ECHO CHECK

&& Edited Mon Jun 21 15:25:58 1999

&& _North_route_via_city_without_rx_life_extension_
TITLE RADTRAN 4.0 INPUT

FORM UNIT

DIMEN 31 8 3 10 18

PARM 1 3 210

PACKAGE
LABGRP
SOLID GAS VOLATIL
SHIPMENT
LABISO
RSL MNS4 FESS FES9 cose co60
KR85 SR89 SR90 yor 2R95 NB9S
RULO3 RULOG $B125 TEL25M E127 TE127M
S134 8137 CE141 E144 PM147 EU1S4
PU238 PU239 Pu240 PU241 aM241 cm242
244
NORMAL
NMODE=1
9.000E-01 5.000E-02 5.000E-02 8.849E+01 4.025E+01 2.416E+01
4.000E+00 3-100E+00 0.000E+00 1.100B-02 1.000E+00 0.000E+00
0.000E+00 3.000E+01 2.000E+01 0.000E+00 1.000E+02 1.000E+02
2.000E+00 8.000E-02 5.000E-02 8.500E-01 4.700E+02 7.800E+02
2.800E+03
ACCIDENT
SEVFRC
NPOP=1
NMODE=1
4.62E-01 3.02E-0i 1.76E-01 4.03E-02 1.18E-02 6.47E-03
5.71E-04 1.13E-04
NPOP=|
NMODE=1
4.35E-01 2-85E-01 2.21E-01 5.06B-02 6.64E-03 1.74E-03
6.72E-05 5.93E-06
3.82E-01 2.78E-02 6.36E-03 7.42E-04 1.46E-04
1.13E-05 9.94E-07
RELEASE
RFRAC
GROUP=1
0.00E+00 6.00E-08 2.00E-07 2.00E-06 2.00E-06 2.00E-06
2.00E-05 2.00E-05
GROUP=2
0.00E+00 9.90E-03 3.30E-02 3.90E-01 3.30E-01 3.30E-01
6.30E-01 6.30E-01
GROUP=3
0.00E+00 6.00E-06 2.00E-05 2.00E-04 2.00E-04 2.00E-04
2.00E-03 2.-00E-03
EOF
ISOTOPES -1 50185 1.00 13.000 1.00 0.00 vEGASi
cR51 7.40E-16 SOLID 2
MNS4 4.80E+01 SOLID 2
FESS 3-82E+03 SOLID 2
FE59 3.84E-10 SOLID 2
co58 3.67E-04 SOLID 2
C060 1.20E+04 SOLID 2
KR85 1.96E+04 GAS 10
SR89_ 1.42E-05 SOLID 2
SR90  2.20E+05 SOLID 2
Y91 5.81E-04 SOLID 2
ZR95 1.78E-04 SOLID 2
NB95S 1.24E-02 SOLID 2
RU103 2.40E-08 VOLATIL 7
RU106 4.04E+04 VOLATIL 7
$B125 5.80E+03 SOLID 2
TEL2Z5M 1.63E+02 SOLID 2
E127 2.09E-01 SOLID 2
E127 2-12E-01 SOLID 2
CS134 1.09E+05 VOLATIL 7
CS137 3.21E+0S VOLATIL 7
A3-11 NUREG-1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

estimated here are conservative, the NRC staff assumed that shipments would be by legal-
weight trucks rather than heavy-haul trucks because fewer shipments would be required if
heavy-haul trucks were used.

To examine the effects of license renewal, the NRC staff used two estimates of SNF that
would be transported to the repository. The first was based on the assumption that no
nuclear plants have their licenses renewed, and the second was based on the assumption
that all existing nuclear plants would operate for the full duration of a 20-year license renewal
period. This means that the amount of SNF shipped for the license renewal case was
assumed to be 50 percent greater than the amount of SNF for the no-license renewal case.
The assumption used for the license renewal estimate is conservative because some plant
owners have already decided not to request renewal of plant operating licenses.

As noted above, the NWPA prohibits DOE from accepting more than 70,000 MTHM of HLW
at the Yucca Mountain repository, only 63,000 MTHM of which would be SNF. Based on this
limit, DOE estimates on the order of 37,600 truck shipments of SNF to Yucca Mountain,
assuming all SNF travels by truck in legal-weight casks (K. Skipper, Yucca Mountain Site
Office, personal communication to D. P. Cleary, NRC, July 11, 1997). For this analysis, the
NRC staff assumed that all current and committed SNF, about 84,000 MTHM, would be
disposed of at Yucca Mountain. [The Nuclear Waste Technical Review Board (1997) made a
very similar estimate of current and committed SNF.] Using DOE’s estimated number of
shipments and the total amount of SNF leads to an estimate of the order of 50,000 truck
shipments without license renewal. Assuming all plants renew their licenses and operate for
an additional 20 years, the estimate is on the order of 75,000 truck shipments.°

The analysis used the RADTRAN computer code (Section 2.2.3) to estimate the radiation
doses to the people of Clark County and to transportation workers. The route and population
density numbers used by RADTRAN computer code were generated by the HIGHWAY
computer code and modified by the NRC staff to account for population growth

(Section 2.2.1). The human health implication of the radiological exposures were estimated
by use of BEIR V radiation-dose-to-cancer-risk factors (Section 2.2.3). The risk of non-
radiological accidents were estimated by using U.S. Department of Transportation statistics
(Section 2.3.2).

2.2.1 Transportation and Route Scenarios

The HIGHWAY computer code (Johnson et. al. 1993) was used to select routes. The
HIGHWAY computer code models the U.S. highway system. Its data base includes all
interstates, most U.S. highways, and many State, county, or local roadways. It represents
about 380,000 km [240,000 miles] of roadway. Several different routing options are available
in the highway program, including probable commercial routes, routes on the interstate
highway system, routes that bypass major urban areas, and preferred routes designated by
the States. Additional detailed routing analysis can be performed by blocking individual or

trucks would be routed on interstate highways to the maximum possible extent.

® Although these estimates exceed the 70,000 MTHM limit for the first repository in the NWPA, they
represent conservative assumptions (i.e., overestimates) that would define an upper bound of potential impacts
for a repository at Yucca Mountain.

7 NUREG- 1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

CEM41 2.715-11 SOLID 2
CEl44 2.21+04 SOLID 2
PM147 9.17%+04 SOLID 2
EUIS4 1.77B+04 SOLID 2
PU238 «1.72E+04 SOLID 2
PU239 7.09+02 SOLID 2
PU2Z40 1.32E+03 SOLID 2
PU241 2.88E+05 SOLID 2
AM241 3.17E+03 SOLID 2
M242 1.14+02 SOLID 2
cM244 -2.18E+04 SOLID 2

LINK 1 1.84E+02 8. 80E+01 3.80E+00 4.70E+02 2.25E-07 R 1
LINK 1 2.30E+01 4.OOE+01 4.53E+02 7.80E+02 2.25E-07 S 1
LINK 1 1.22E+01 2.40E+01 2.51E+03 2.80E+03 3.60E-07 U 1
PKGSIZ.

VEGAS1 5.00
EOF

NUREG-1437, Addendum | A3-6


Supplemental Analyses for Cumulative Environmental Impacts. . .

2.6 ENVIRONMENTAL JUSTICE

Environmental justice refers to a Federal policy in which Federal actions should not result in
disproportionately high and adverse environmental impacts on low-income or minority
populations. Executive Order 12898 (59 FR 7629) directs Federal executive agencies to
consider environmental justice under NEPA. Although the Executive Order does not apply to
the NRC, an independent agency, the NRC has stated that it will comply with the Executive
Order.

As explained earlier, only people within 0.8 km [0.5 mile] of the route followed by the trucks
transporting SNF would receive any appreciable radiation dose, even under accident
scenarios. Consequently, the NRC staff examined available data on low-income and minority
populations within that distance along transportation routes to determine if there was reason
to suspect that SNF transport impacts might fall disproportionately on low-income or minority
groups. To this end, the NRC staff examined the racial, ethnic and population characteristics
of Clark County as a whole and the same characteristics of the transportation routes.

Table 8 describes the overall racial and ethnic characteristics for the population groups in
Clark County (Bureau of the Census 1990).

Nevada is one of the fastest growing states in the U.S., with Clark County growing faster

than any other Nevada county. The 1990 census listed 741,459 people as living in the county
(Census Bureau Database C90STF1A; http://venus.census.gov/cdrom/lookup/929978369,
accessed June 21, 1999). Clark county’s projected 1999 population was 1,337,400, and the
projected 2004 population is 1,656,840 (Nevada State Demographer June 1, 1998). Las
Vegas accounted for most of the County’s growth. In July 1998, an estimated

448,244 persons resided in Las Vegas, a 6 percent increase since July 1997. In addition to
residents, Las Vegas has many visitors staying in hotels.

Table 9 reports the percentage of ethnic and racial groups living within 0.5 mile (0.8 km) of
the transportation routes. These data were assembled using an Oak Ridge National
Laboratory computer program that integrates Map-InfoTM with the Census Bureau data
available on CD-ROM (U.S. Census Database C9OSTF1A, 1990). 1990 data were used to
be consistent with the population density estimates used in the HIGHWAY computer code.
Table 9 shows that only for the route from the northeast through downtown would the
fraction of a minority within the 0.8-km (0.5-mile) corridor adjacent to the route be
significantly higher than the county average.

‘8 Per Office of Management and Budget 1998 Directive No. 15, the Census Bureau uses four race
categories (White, Black, American Indian and Alaska native, Asian and Pacific Islander) and two ethnicity
categories, Hispanic and non-Hispanic (Bureau of the Census 1998).

NUREG-1437, Addendum 1 24


Supplemental Analyses for Cumulative Environmental Impacts. . .

Issue Sections Category Findings
Transportation Addendum 1, 1 SMALL. The impacts of transporting spent
2.4 fuel enriched up to 5 percent uranium-235
3.3 with average burnup for the peak rod to

current levels approved by NRC up to

62,000 MWd/MTU and the cumulative
impacts of transporting high-level waste to a
single repository, such as Yucca Mountain,
Nevada are found to be consistent with the
impact values contained in 10 CFR51.52(c),
Summary Table S-4--Environmental Impact
of Transportation of Fuel and Waste to and
from One Light-Water-Cooled Nuclear
Power Reactor. If fuel enrichment or burnup
conditions are not met, the applicant must
submit an assessment of the implications for
the environmental impact values reported in
§51.52.

31 NUREG-1437, Addendum 1


] wnpusppy ‘L¢r1-DFYNN

tv

Route 2. (continued).

State Mileage

+0 CANVI15 NIPTSLOA NV +0 0:00 6/17/99 at 11:34
42.0 115 LAS VEGAS 115 1515 NV 42.0 0:38 6/17/99 at 12:12
61.0 U95 MERCURY S$ U95 LOCL NV 103.0 1:45 6/17/99 at 13:18
MILEAGE WITHIN DENSITY LEVELS
59.7 139 326 821 1861 3326 5815
State Miles -139 -326 -B21 -1861 ~3326 -5815 -9996 >9996

NV 103.0 10.8 28.7 21.6 TL 5.1 6.7 3.1 2.7 3.1 4.9 3.8 5.4
Route
Total 103.0 10.8 28.7 21.6 TAL 5.1 6.7 3.1 2.7 3.1 4.9 3.8 5.4
Percentages
10.5 27.9 21.0 6.9 5.0 6.5 3.0 2.6 3.0 4.8 3.7 5.2
Basis: Estimated 2020 Population
RADTRAN Input Data Rural Suburban Urban
Weighted Population
People/sq. mi. 16.0 961.3 8314.6
People/sq. km. 6.2 371.2 3210.3
Distance Total
Miles 73.3 15.6 14.1 103.0
Kilometers 118.0 25.1 22.7 165.8
Percentage 71.2 1s.1 13.7
Basis (people/sq. mi.) <139 139-3326 >3326 Estimated 2020 Population

Note: Due to rounding, the sum of the mileage in the individual
population categories may not equal the total mileage shown
on this report.

+ -sroodul] jojuauuosnaug aaunjnuny 40, saskpouy [ojuauatddng


Supplemental Analyses for Cumulative Environmental Impacts. . .

requires that “The average level of irradiation of the irradiated fuel from the reactor does not
exceed 33,000 megawatt-days per metric ton, and no irradiated fuel assembly is shipped
until at least 90 days after it is discharged from the reactor.” These two limiting conditions
have been exceeded through nuclear power plant license amendments permitting
incremental increases in the burnup of fuel. During the 1990s, the NRC has reviewed and
approved vendor topical reports requesting approval for higher burnup level. (Letter from M.
J. Virgilio, NRC, to N. J. Liparulo, Westinghouse Electric Corporation, “Acceptance for
Referencing of Topical Report WCAP-12488, ‘Westinghouse Fuel Criteria Evaluation
Process,” dated July 27, 1994; FCF-BAW 10186P-A, “Extended Burnup Evaluation,” June
12, 1997; and Memorandum from T. E. Collins to B. W. Sheron, “Waiver of CRGR Review of
EMF-85-74(P), Revision O, Supplements 1 and 2 Safety Evaluation,” dated February 9,
1998). Approved average burnup for the peak rod now ranges from 50,000 to 62,000
MWd/MTU. The higher burnup levels are associated with uranium-235 enrichment levels of
up to 5 percent by weight. Thus, it is likely that at the time of a submittal of a license renewal
application, many nuclear power plants will be operating at higher fuel burnup and will be
using higher enrichment fuel.

Further, the assumed minimum time for shipping spent fuel of 90 days after discharge from
the reactor was based on the assumption that the spent fuel would be shipped toa
reprocessing facility. Reprocessing spent fuel is currently not a reasonable assumption.
Currently, the reasonable assumption is that spent fuel will be shipped to an interim storage
facility or to an ultimate repository and would have been discharged from the reactor at least
5 years earlier and, in some cases, as many as 40 years earlier. In fact, the current practice
of NRC issuing certificates of compliance for casks used for shipment of power reactor fuel
is to specify 5 years as the minimum cooling period. The assumption of 5-year cooling is an
extremely conservative assumption. For example, there is almost 40,000 tons of spent fuel in
storage now, some of which has been stored for decades. At the earliest, if Yucca Mountain
were found suitable and if DOE were successful in obtaining an NRC license, it willbe at
least 11 years from now until Yucca Mountain would be ready to accept spent fuel for
storage. It would take many years to work off the backlog of stored spent fuel.

3.2 ANALYSES

Because many nuclear power plants are now operating with higher enriched fuel irradiated to
higher burnup levels, motivated in part by a desire to minimize spent fuel inventory, and
because of public concerns about transportation impacts of higher burnup SNF, the NRC
staff examined recent technical literature on, and performed additional analyses of the
characteristics of higher burnup SNF. The analyses summarized below address two
questions: the extent to which higher burnup SNF might have greater incident-free
transportation impacts than spent fuel with the characteristics assumed for Table S-4,
whether accidents involving higher burnup SNF might have unacceptable impacts, and
whether accidents involving higher burnup SNF might cause criticality during a transportation
accident.

For incident-free transportation, the principal concern is whether, because of its different
radiological composition, higher burnup fuel would require more shipments and larger
transportation impacts than predicted by Table S-4. Quantification of the radiation emissions
for reactor fuels is a complex process. However, there are several insights that allow for
scaling of the radioactive emissions from one burnup level to another. For the gamma-ray

27 NUREG-1437, Addendum 1


LCV

| wnpusppy “Ler 1-DaaNN

Route 4. (continued).

0
34.0 115
27.0 1215
49.0 U95

nv 110.0 10.8 28.7
Route
Total 110.0 10.8 28.7
Percentages
9.8 26.1

Basis: Estimated 2020 Population

State Mileage

NV 110.0
CANVI15 NIPTSLOA NV +0 0:00 6/17/99 at
LAS VEGAS S$ 115 1215 NV 34.0 0:31 6/17/99 at
LAS VEGAS NW 1215 U95 NV 61.0 0:55 6/17/99 at
MERCURY $ U95 LOCL NV 110.0 1:49 6/17/99 at

MILEAGE WITHIN DENSITY LEVELS
59.7 139 326 821 1861 3326 5815
~139 -326 ~821 -1861 3326 5815 -9996 >9996

21.6 TL 5.1 6.4 3.2 4.5 6.5 10.0 3.6 2.5
21.6 Ta 5.1 6.4 3.2 4.5 6.5 10.0 3.6 2.5
19.6 6.5 4.6 5.8 2.9 4.1 5.9 9.1 3.3 2.3

RADTRAN Input Data Rural - Suburban Urban

Weighted Population

People/sq. mi. 16.0 1272.6 6469.6
People/sq. km, 6.2 491.3 2498.0
Distance Total
Miles 73.3 20.6 16.1 110.0
Kilometers 118.0 33.2 25.9 177.0
Percentage 66.6 18.7 14.6
Basis (people/sq. mi.) <139 139-3326 >3326 Estimated 2020 Population

Note: Due to rounding, the sum of the mileage in the individual
population categories may not equal the total mileage shown
on this report.

- + -szonduy jpjuauuUodaug aayvjnuny 4of saskjouy jo1uauaddng


Supplemental Analyses for Cumulative Environmental Impacts. . .

Plants: Main Report Section 6.3—‘Transportation,’ Table 9.1 “Summary of findings on NEPA
issues for license renewal of nuclear power plants,’ Draft Report for Comment.

The rule change and the supporting Addendum 1 affect only the plant-specific
environmental analysis required to be submitted in the Environmental Report of an applicant
for the renewal of a nuclear power plant operating license and the plant-specific
supplemental environmental impact statement prepared by the NRC. Even though the
analysis in Addendum 1 focuses on spent-fuel shipments converging on the proposed
repository at Yucca Mountain, Nevada, that analysis and the resulting rule affect only the
review requirements for renewal of an individual nuclear power plant operating license. Itis
not intended that Addendum 1 or the revised rule support any other regulatory decision by
the NRC.

Issue 2—Communications

Comment: NRC failed to consult with Nevada State agencies, Nevada local
governments, and with Nevada Indian Tribes.

Response: As discussed above, a variety of organizations and government agencies
submitted substantive comments in response to the proposed rule. The NRC has
considered these comments and, in many cases, altered its analysis as a result of this input.
Prior to issuance of the proposed rule for comment, however, the NRC did not seek any pre-
publication input from Nevada state agencies, Nevada local Governments, and Nevada
Indian Tribes for the following reasons. First, the rule involves a narrow aspect of the
environmental review of individual nuclear power plant license renewal decisions, which is a
regulatory decision completely separate from the regulatory requirements that will guide the
NRC licensing review of a HLW repository and from the decision process leading toa DOE
site recommendation on Yucca Mountain, Nevada, the site DOE currently has under study.
This rule amends the December 18, 1996, rule with respect to two questions not adequately
answered:

1. Are the current environmental impact values in Table S-4, based on several destinations,
still reasonable to incorporate in a license renewal review that assumes a single
destination for spent fuel at Yucca Mountain, Nevada?

2. Are the current environmental impact values in Table S-4 (which are based on fuel
enriched to no greater than 4 percent, the average level of irradiation of spent fuel not
exceeding 33,000 MWd/MTU, and shipment no less than 90 days after discharge from
the reactor) still reasonable to incorporate in a license renewal review of plants that may
use fuel enriched up to 5 percent and potentially ship spent fuel with a burnup of up to
62,000 MWd/MTU?

The amendment has no direct regulatory impact on any entity within Nevada. The
selection of Yucca Mountain for the generic evaluation of transportation impacts was made
because that site is currently the only one under consideration for a high-level-waste (HLW)
repository. Before HLW is actually transported to Yucca Mountain, Nevada, the State, local
Governments, Indian Tribes, and the public have the opportunity to provide input on site-
specific transportation impacts by commenting on DOE’s draft EIS for the proposed
repository at the Yucca Mountain site, which was made available for a 180-day comment
period beginning on August 13, 1999 (http://www.ymp.gov).

Al-3 NUREG- 1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

CE141
CE144
PM147
EU1S4
PU238
PU239
Pu240
Pu241
AM241
M242
M244

LINK 1 1.18E+02 8.80E+01 6.20E+00 4.70E+02 2.25E-07 R 1
LINK 1 2.51E+01 4.00E+01 3.71E+02 7.80E+02 2.25E-07 S 1
LINK 1 2.27E+01 2.40E+01 3.21E+03 2.80E+03 3.60E-07 U 1

PKGSIZ

VEGAS1

EOF

2.718-11
2.218+04
9.17E+04
1.7 7E+04
1. 72E+04
7. O9E+02
1. 32E+03
2. 88E+05
3.17E+03
1. 145+02
2.185+04

5.00

SOLID
SOLID
SOLID
SOLID
SOLID
SOLID
SOLID
SOLID
SOLID
SOLID
SOLID

RNUNNNYNNNNN

A3-19

NUREG- 1437, Addendum 1




Supplemental Analyses for Cumulative Environmental Impacts. . .

ABSTRACT

This addendum to NUREG-1437, Generic Environmental Impact Statement for License
Renewal of Nuclear Plants, documents the staff's analysis of the potential cumulative
impacts of transporting spent nuclear fuel in the vicinity of a single high-level waste
repository, and summarizes the staff's analyses undertaken to determine 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. The intent of the
study is a generic analysis of the cumulative impacts associated with transportation of spent
nuclear fuel as a result of nuclear power plant license renewal. The results of the analysis
will be used to amend 10 CFR Part 51.53 and Appendix B to Subpart A of 10 CFR Part 51,
and is not intended to support any other regulatory decision by the NRC. This addendum
also includes an appendix that summarizes comments on the draft of the addendum, and
documents the staff's responses to those comments.

i NUREG- 1437, Addendum 1


Supplemental Analyses for Cumutatve Environmental Impacts. . .

6. List OF PREPARERS

B. L. Broadhead, Oak Ridge National Laboratory, Ph.D. and M.S., Nuclear Engineering,
University of Tennessee; 22 years experience in radiation shielding and spent fuel source
analyses. Contribution: Analysis of higher burnup effects, Section 3.2, and higher burnup
source term for RADTRAN analysis.

D. P. Cleary, U.S. Nuclear Regulatory Commission, Graduate studies in Natural Resource
Economics and Environmental Policy, University of Michigan; M.A., Economics,
University of Florida; B.A. Economics, University of Massachusetts; 35 years of
experience in environmental assessment. Contribution: Overall project direction,
Chapter 3, and Appendix 1.

P. E. Johnson, Oak Ridge National Laboratory, M.S., Geography, University of Tennessee;
B.A. Geography, University of Minnesota-Duluth; 20 years of experience in transportation
routing modeling. Contribution: HIGHWAY routing analysis and population projections,
Sect. 2.3.

C.W. Hagan, Oak Ridge National Laboratory, M.A., English, and B.A., Biology, Virginia
Polytechnic Institute and State University; 17 years of experience in technical writing.
Contribution: Document management and Appendix 1.

L. N. McCold, Oak Ridge National Laboratory, M.S., Mechanical Engineering, and B.S.,
Physics, Oregon State University; 17 years of experience in environmental assessment.
Contribution: ORNL project management and technical integration.

C. V. Parks, Oak Ridge National Laboratory, Ph.D., Nuclear Engineering, University of
Tennessee; M.S., Nuclear Engineering, B.S. Nuclear Engineering and B. S. Mechanical
Engineering, N. C. State University; 19 years of experience in nuclear safety analysis for
transportation and storage. Contribution: Analysis of potential effects of clad failure of
higher burnup fuels, Section 3.2.

W. J. Reich, Oak Ridge National Laboratory, M.S. Nuclear Engineering, University of
Missouri-Rolla; B.A. Nuclear Engineering, University of Missouri-Rolla; 8 years of
experience in transportation analysis and risk assessment. Contribution: RADTRAN
analysis, Sect. 2.3.

B. M. Sorensen, Oak Ridge National Laboratory, Ph.D. Sociology, University of Tennessee;
M.A. Urban and Regional Planning, University of Hawaii; B.F.A. Pre-Landscape
Architecture, University of Hawaii; 20 years of experience in environmental impact
analyses. Contribution environmental justice analysis, Section 2.6.

NUREG- 1437, Addendum 1 34


Supplemental Analyses for Cumulative Environmental Impacts. . .

ECHO CHECK

&& Edited Mon Jun 21 15:19:54 1999
&& _North_route_via_beltway_without_rx_life_extension_

TITLE RADTRAN 4.0 INPUT

FORM UNIT

DIMEN 31 8 3 10 18

PARM 13210

PACKAGE
LABGRP
SOLID GAS VOLATIL
SHIPMENT
LABISO
CR51 MNS4 FESS
KR85 SR89 SR90
RU103 RULO6 SB125
cs134 cs137 CE141
PU238 PU239 PU240
M244
NORMAL
NMODE=1
9.000E-01 5.000E-02 5.000E-02
4.000E+00 3.100E+00 0.000E+00
0.000E+00 3.000E+01 2.000E+01
2.000E+00 8.000E-02 5.000E-02
2.800E+03
ACCIDENT
SEVFRC
NPOP=1
NMODE=1
4.62E-01 3.02E-01 1.76E-01
5.71E-04 1.13E-04
NPOP=2
NMODE=1
4.35E-01 2.85E-01 2.21E-01 5
6.72E-05 5.93E-06
NPOP=3
NMODE=1
5.83E-01 3-82E-01 2.78E-02 6
1.13E-05 9.94E-07
RELEASE
RFRAC
GROUP=1
0.00E+00 6-00E-08 2.00E-07 2
2.00E-05 2.00E-05
GROUP=2
0.00E+00 9.90E-03 3.30E-02 3
6.30E-01 6.30E-01
GROUP=3
0.00E+00 6.00E-06 2.00E-05 2
2.00E-03 2.00E-03
EOF
ISOTOPES -1 50185 1.00 13.000
CR51 7.40E-16 SOLID 2
MNS4 4.80E+01 SOLID 2
FESS 3.82E+03 SOLID 2
FE59 3.84E-10 SOLID 2
CO58 3.67E-04 SOLID 2
CO60 1.20E+04 SOLID 2
KR85 1.96E+04 GAS 10
SR89 1.42E-05 SOLID 2
SR90 2.20E+05 SOLID 2
¥91 5.81E-04 SOLID 2
ZR95  1.78E-04 SOLID 2
NB95 1,.24E-02 SOLID 2
RU1O3 2.40E-08 VOLATIL 7
RU1O6 4.04E+04 VOLATIL 7
SB125 5.80E+03 SOLID 2
TE125M 1.63E+02 SOLID 2
E127 2.09E-01 SOLID 2
TE127M = 2.12E-01 SOLID 2
S134 1.09E+05 VOLATIL 7
S137 3.21E+05 VOLATIL 7

FESS
y9o1
TE125M
CE144
PUz41

8. 849E+01
1.100E-02
0.000E+00
8.500E-01

03E-02

-06E-02

-36E-03

-00E-06

-90E-01

-00E-04

1.00

cos8
ZR95
E127
PM147
AM241

1.18E-02

6.64E-03

7.42E-04

2.00E-06

3.30E-01

2.00E-04

co60
NB9S
TE127TMM
EU1S4
M242

4.025E+01 2.416E+01
1.000E+00 0.000E+00
1,000E+02 1.000E+02
4.700E+02 7.800E+02

6.47E-03

1.74E-03

1.46E-04

2.00E-06

3.30E-01

2.00E-04

0.00 VEGAS1

A3-5

NUREG- 1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

EXPECTED VALUES OF POPULATION RISK IN PERSON-REM

GROUND
LINK 1 1.07E+01
LINK 2 2.19E+02
LINK 3 1.518+02

RURAL 1. 07E+01
SUBURB 2.19E+02
URBAN 1.51E+02

TOTALS: 3.82E+02

INHALED

1.62E-01
3.22E+00
1.94E+00

1.62E-01
3.22E+00
1.94E+00

5.33E+00

RESUSPD

4.57E-01
9.11E+00
5.49E+00

4.57E-01
9.11E+00
5.49E+00

1.S1E+01

CLOUDSH

5.07E-04
1.04E-02
6.16E-03

5.07E-04
1.04E-02
6.16E-03

1.71E-02

* NOTE THAT INGESTION RISK IS A SOCIETAL RISK;
THE USER MAY WISH TO TREAT THIS VALUE SEPARATELY.

* INGESTION TOTAL

0.00E+00
0.00E+00
0.00E+00

0.00E+00
0.00E+00
0.00E+00

0.00E+00

1.13E+01
2.32E+02
1.59E+02

1.13E+02
2.32E+02
1.59E+02

4.02E+02

NUREG- 1437, Addendum 1

A3-14


fio weet He Ob

NUREG-1437, Vol. 1
Addendum 1

Generic Environmental
Impact Statement for
License Renewal of
Nuclear Plants

Main Report

Section 6.3—Transportation

Table 9.1 Summary of findings on NEPA
issues for license renewal of nuclear power
plants

Final Report

oan
U.S. Nuclear Regulatory Commission i 4,
Office of Nuclear Reactor Regulation tye i;

Washington, DC 20555-0001 ‘ne





Supplemental Analyses JOT Cumulative Environmentat impacts. . -

(10 mrem/h at 2 m) and that LLW would have dose rates of 1 mrem/h at 1 m. To estimate
the radiological effects of these shipments, the NRC staff assumed that each DOE SNF,
HLW or LLW shipment was equal to a shipment of commercial SNF. For the radiological
impacts of LLW, the assumption is very conservative because, as indicated by DOE's
estimate of 1 mrem/hour (0.01 mSv/hour) at 1 m, LLW is generally much less radioactive
than SNF. For non-radiological effects, the NRC staff assumed that each shipment would
have the same effect regardless of what material was being transported.

Using highest doses and cancer risks in Tables 3 and 4 and the assumptions above, the
NRC staff estimated the doses and LRFCs for shipment of DOE radioactive waste through
Clark County. As shown by Tables 6 and 7, the cumulative doses and expected cancer
fatalities continue to be small compared to the risk of cancer from other causes.

The non-radiological cumulative effects of radioactive waste shipment through Clark County
are dominated by the very large number of LLW shipments. All SNF and DOE radioactive
waste and SNF shipments through Clark County would total to more than 374,000
shipments, almost 5 times as many as SNF shipments with license renewal. Thus, between
125 and 250 non-radiological truck accidents can be expected during the 374,000 shipments
of radioactive wastes through Clark County. The expected number of accident fatalities is
between 0.22 and 0.46 for all shipments of radiological waste over all the years the
shipments would occur. Assuming these shipments occurred over a 40-year period, between
3 and 6 traffic accidents involving trucks transporting all types of radioactive waste materials
would be expected in an average year, and there would be a very small chance that a fatality
would result in any one year.

2.5 SUMMARY OF SNF TRANSPORT IMPACTS

As shown in Table 4, the conservatively estimated LRFC assumed to result from radiation
exposure related to transportation of SNF in Clark County over the entire 40-60 year life of
the transportation campaign to the repository is between 1.6 and 2.6 (including the risk due
to potential accidents) or less than 0.05 LRFC/year. For comparison, it is estimated that
there would be about 5700 LRFC for each year in Clark County from causes unrelated to
SNF transport.

Non-radiological truck-vehicle accidents are possible as a result of transporting SNF through
Clark County. The probability of a fatality is estimated to be less than 0.090 under all
scenarios. For license renewal, the combined radiological and non-radiological risk to the
general public is estimated to be between about 2.3 and 2.6 fatalities over the entire course
of SNF transport through Clark County, including incident-free and accident risks. Without
license renewal, the estimated is between about 1.5 and 1.8 fatalities.

The above analysis shows that, even with conservative assumptions, the cumulative
radiological and accident risks of SNF transport in Clark County are small. It also shows that
alternative assumptions are bounded by this analysis and would result in even smaller
human health impacts. Transporting SNF by rail rather than by truck would reduce human
health effects by reducing the number of shipments and the likelihood of accidents. Shipping
SNF via the proposed beltway would reduce health impacts compared to shipping via the
current interstate highway system. In addition, shipping SNF via the proposed beltway would
reduce health impacts compared to shipping via the current interstate highway system. The
implementation of such mitigative measures must await future decisions that fall well outside

NUREG- 1437, Addendum 1 22


Supplemental Analyses for Cumulative Environmental Impacts...

ECHO CHECK

&& Edited Mon Jun 21 15:48:15 1999
&& _South_route_via_beltway_with_rx_life_extension_
TITLE RADTRAN 4.0 INPUT

FORM UNIT

DIMEN 31 8 3 10 18

PARM 13210
PACKAGE
LABGRP
SOLID
SHIPMENT
LABISO
RSL
KR85
RU103
S134
PU238
M244
NORMAL
NMODE=1
-000E-01
-000E+00
-000E+00
-000E+00
.800E+03

NNOnw

ACCIDENT
SEVFRC

4.62E-01
5.71E-04

GAS —-VOLATIL

MNS4 FESS
SR89 SR90
RU106 $B125
S137 CE141
PU239 Pu240

5.000E-02 5.000E-0
3.100E+00 0.000E+0
3.000E+01 2.000E+0:
8.000E-02 5.000E-0:

3.02E-01 1.76E-01
1.13E-04

2.85E-01 2.21E-01
5.93E-06

5.83E-01 3.82E-01 2.78E-02
1.13E-05 9.94E-07
RELEASE
RFRAC
GROUP=1
0.00E+00 6.00E-08 2.00E-07
2.00E-05 2.00E-05
GROUP=2
0.00E+00 9.90E-03 3.30E-02
6.30E-01 6.30E-01
GROUP=3
0.00E+00 6.00E-06 2.00E-05
2.00E-03 2.00E-03
EOF
ISOTOPES -1 75278 1.00 13.000
CR51 7.40E-16 SOLID 2
MNS4 «4. 80E+01 SOLID 2
FE55 3.82E+03 SOLID 2
FE59 3.84E-10 SOLID 2
co58  3.67E-04 SOLID 2
C060 1.20E+04 SOLID 2
KR85 1. 96E+04 GAS 10
SR89 1.42E-05 SOLID 2
SR90 2.20E+05 SOLID 2
91 5.81E-04 SOLID 2
ZR95 1.78E-04 SOLID 2
NB95 1.24E-02 SOLID 2
RU103 2.40E-08 VOLATIL 7
RULO6 4.04E+04 VOLATIL 7
SB125 5.80E+03 SOLID 2
TE125M 1.63E+02 SOLID 2
TE127 2.09E-01 SOLID 2
TE127M 2.12E-01 SOLID 2
S134 1.09E+05  VOLATIL 7
S137 3.21E+05  VOLATIL 7

FES9 cose C060

Y9L ZR95, NB9S
TE125M TE127 TE127M
CE144 PM147 EU154
PU2z41 AM241 M242
2 8.849E+01 4.025E+01 2.416E+01
0 1.100E-~02 1.000E+00 0.000E+00
1 0.000E+00 1.000E+02 1.000E+02
2 8.500E-01 4.700E+02 7.800E+02
4.03E-02 1.18E-02 6.47E-03
5.06E-02 6.64E-03 1.74E-03
6.36E-03 7.42E-04 1.46E-04
2.00E-06 2.00E-06 2.00E-06
3.90E-01 3.30E-01 3.30E-01
2.00E-04 2.00E-04 2.00E-04

1.00 0.00 VEGAS1

A3-21

NUREG- 1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

CE141 2.71E-11 SOLID 2
CE144 2.21E+04 SOLID 2
PM147 9.17E+04 SOLID 2
BUIS4 1.77E+04 SOLID 2
Pu238 «1.72E+04 SOLID 2
PU239_ -7.09E+02 SOLID 2
PU240 1.32E+03 SOLID 2
PU241 2.88E+05 SOLID 2
AM241 3.17E+03 SOLID 2
M242 -1,14E+02 SOLID 2
cM244 2.18E+04 SOLID 2

LINK 1 1.18E+02 8.80E+01 6.20E+00 4.70E+02 2.25E-07 R 1
LINK 1 2.51E+01 4.00E+01 3.71E+02 7.80E+02 2.25E-07 S 1
LINK 1 2.27E+01 2.40E+01 3.21E+03 2.80E+03 3.60E-07 U 1
PKGSIZ

VEGAS 5.00
EOF

NUREG-1437, Addendum 1 A3-16


Supplemental Analyses Jor Cumutative knvironmentat impacts. . -

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.

2. CUMULATIVE IMPACTS OF
SPENT NUCLEAR FUEL TRANSPORTATION

The purpose of this analysis is to determine whether the Commission can reach a generic
conclusion about the cumulative impacts of spent fuel transport in the vicinity of a repository
due to the renewal of a nuclear power plant operating license. If the Commission can reach
such a conclusion, the issue can be designated a Category 1 issue and the finding codified
in 10 CFR Part 51. For an issue to be designated Category 1, the following criteria must be
met:

(1) The environmental impacts associated with the issue have been
determined to apply either to all plants or, for some issues, to plants having a
specific type of cooling system or other specified plant or site characteristic;

(2) A single significance level (i.e., small, moderate, or large) has been
assigned to the impacts (except for collective off site radiological impacts from the
fuel cycle and from high level waste and spent fuel disposal‘); and

(3) Mitigation of adverse impacts associated with the issue has been
considered in the analysis, and it has been determined that additional plant-
specific mitigation measures are likely not to be sufficiently beneficial to warrant
implementation.

Section 2.1 is a description of the status of the Yucca Mountain site as a potential geologic
repository in order to provide a context for the analysis.° Section 2.2 describes the approach

‘This exception only applies to the two entries in Table B-1 labeled “Offsite radiological impacts (collective
effects)” and “Offsite radiological impacts (spent fuel and high level waste disposal).

5 Any generic conclusions by the Commission concerning the cumulative impacts of transportation
associated with nuclear power plant license renewal would in no way affect any U.S. Department of Energy
(DOE) decision conceming the suitability of Yucca Mountain, any consideration that DOE may give to
transportation impacts in making that decision, and is not intended to support any other regulatory decision by
the NRC.

NUREG-1437, Addendum 1 4


Supplemental Analyses for Cumulative Environmental Impacts. . .

Comment: The NRC should provide affected parties with some statement of the
regulatory effect of the interrelationships between the numerous other similar analyses.

Response: As a general matter, the National Environmental Policy Act (NEPA) requires
all Federal agencies to perform an environmental review for certain actions they propose to
conduct. In the context of nuclear waste management, several agencies have regulatory
and operational responsibilities which may involve various proposed actions that, in turn,
require the preparation of environmental impact statements (EISs). Inevitably, there may be
a degree of overlap in the types of impacts discussed in these various ElSs. However, the
analysis developed by the NRC for the purposes of license renewal is not binding on future
actions and associated environmental impact analyses.

The NRC proposed action that has triggered the preparation of this rulemaking and the
associated analysis of environmental impact is the agency's responsibility to review
applications for the renewal of nuclear power plant licenses. In light of the discrete purpose
of this rulemaking, the NRC has sought to gauge the impacts of license renewal given the
information currently available on those impacts including the transportation of spent fuel.
Even though these impacts do not occur at the plant site during license renewal, the NRC
has considered them here pursuant to its NEPA responsibilities.

Future ElSs prepared by other agencies on proposed actions in the waste management
arena (e.g., any recommendation by DOE on approval of the Yucca Mountain site for
development of a repository) will undoubtedly address some of the same impacts covered by
the analysis described in this notice. Some of these other impact statements are anticipated
to be more detailed given their purpose and the availability of additional information in the
future. This, however, does not diminish the adequacy of the NRC’s action. This analysis is
sufficient for the purpose it serves and it provides the Commission with the information
needed to weigh the likely environmental impacts of SNF transportation for individual license
renewals applications and reach informed decisions regarding the acceptability of these
applications. The rule does not, however, dictate any particular result for future actions
taken with regard to a waste repository or other waste management matters. Specifically,
any generic conclusions by the Commission concerning the cumulative environmental
impacts of transportation associated with nuclear power plants would in no way affect any
DOE decision concerning the suitability of Yucca Mountain or any consideration that DOE
may give to transportation impacts in making that decision.

Comment: Addendum 1 is not meaningful to the public. For example, it is impossible to
determine if the spent fuel isotope inventory shown in the sample pages of the RADTRAN
printout matches the fuel considered in the Addendum.

Response: In preparing Addendum 1, the NRC staff has attempted to write to a broad
and diverse audience as much as possible. The NRC staff acknowledges that this
rulemaking involves complicated, technical issues. However, the NRC staff has attempted to
present these matters in the most clear manner possible. Addendum 1 has been revised
and Table 2 provides the fuel isotope inventory that can be compared to the sample pages of
the RADTRAN computer code printout.

Comment: The study area is inaccurately defined and the location of some cities is
incorrectly stated.

NUREG-1437, Addendum 1 Al-12




Supplemental Analyses for Cumulative Environmental Impacts. . .

INCIDENT-FREE SUMMARY

INCIDENT-FREE POPULATION EXPOSURE IN PERSON-REM

PASSENGR
LINK 1 0,00E+00 8
LINK 2 0.00E+00 2.
LINK 3 0.00E+00 2.

RURAL 0.00E+00 8
SUBURB 0.00E+00 2.
URBAN 0.00E+00 2

TOTALS: 0.00E+00 1.

CREW

-46E+02

33E+02
O6E+02

-46E+02

33E+02

-06E+02

28E+03

HANDLERS OFF LINK

0
0

0.

-00E+00
-00E+00
0.

00E+00

-00E+00
-00E+00
-00E+00

00E+00

1.16E+00
3.32E+01
3.36E+00

1.16E+00
3.32E+01
3.36E+00

3.778401

ON LINK
7.53E+01
7.94E+01
4.45E+02

7.53E+01
7.94E+01
4.45E+02

6.00E+02

STOPS
1.07E+03
5.28E+02
5.28E+02

1.07E+03
5.28E+02
5.28E+02

2.12E+03

MAXIMUM INDIVIDUAL IN-TRANSIT DOSE

LINK
LINK
LINK

1 2.69E-02 REM
2 2.69E-02 REM
3  2.69E-02 REM

EXPECTED VALUES OF POPULATION RISK IN PERSON-REM

GROUND
LINK i 1.04E+01
LINK 2 1.57E+02
LINK 3 1.22E+02

RURAL 1. 04E+01
SUBURB 1.57E+02
URBAN = 1.22E+02

TOTALS: 2.90E+02

INHALED RESUSPD CLOUDSH
1.58E-01 4.46E-01 4.94E-04
2.31E+00 6.52E+00 7.46E-03
1.57E+00 4.43E+00 4.97E-03
1.58E-01 4.46E-01 4.94F-04 0
2.31E+00 6.52E+00 7.46E-03 0
1.57E+00 4,.43E+00 4.97E-03 0
4.03E+00 1.14E+01 1.29E-02 0

NOTE THAT INGESTION RISK IS A SOCIETAL RISK;

‘THE USER MAY WISH TO TREAT THIS VALUE SEPARATELY.

O0E+00
O0E+00

-00E+00
-00E+00
-00E+00

-00E+00

STORAGE TOTALS

0.00E+00 1.99E+03
0.00E+00 8.73E+02
0.00E+00 1.18E+03

0.00E+00 1.99E+03
0.00E+00 8.73E+02
0.00E+00 1.18E+03

0.00E+00 4.05E+03

*INGESTION TOTAL
0.

0.
0.00E+00

1.10E+01
1.66E+02
1.28E+02

1.10E+01
1.66E+02
1.28E+02

3.05E+02

A3-7

NUREG- 1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

sources, the scaling due to burnup is a linear relationship, i.e. a doubling of the burnup
yields, a doubling of the gamma-ray emissions and, typically, a doubling of the dose rate due
to gamma rays. The scaling for neutrons is not linear. Neutron emissions increase as the
fourth power of the burnup ratios given the same initial enrichments; that is, doubling burnup
increases the neutron emissions rate about sixteen times. In practice, however, higher
burnup fuels require higher initial enrichments, such that neutron emissions typically increase
as the square or cube of the burnup ratios. For example, analysis by Parks et al. (1987)
showed that for a 35,000 MWd/MTU and a 60,000 MWd/MTU (burnup ratio 1.71) the neutron
emissions ratio is 4.28 (less than the third power of the burnup ratio).

The increase in the total radiation dose rate due to higher burnup is complicated because the
total dose rate is the sum of the gamma-ray and neutron dose rates. For nominal burnups,
the dose rates at the surface and 2-m from the surface are approximately 90 percent
gamma-rays and 10 percent neutrons. Indeed, Westfall et al. (1990) found that for a
transportation cask that was designed for use in DOE spent fuel applications, the calculated
total dose rate at 2 m for 60,000 MWd/MTU SNF was 2.19 times larger than for 35,000
MWd/MTU SNF. Thus, the total dose from a full cask of 60,000 MWd/MTU SNF would be
about twice as large as the dose from a full cask of 35,000 MWd/MTU SNF. Assuming an
additional increase in maximum burnup to 62,000 MWd/MTU would not invalidate that
assumption given the small increase in burnup from 60,000 MWd/MTU.

The most obvious way to compensate for a doubling of the 2-m dose rate would be to halve
the cask payload. This would increase the number of shipments required, but is unlikely to
be pursued because of the economic and other pressures to minimize spent fuel
transportation activities. In addition, under this scenario, a cask would be partially loaded (i.e.
derated) with the remaining locations in the basket left empty. However, because the cask
would have to be certified for higher burnup to carry even a partial load, the license submittal
could easily analyze the use of inserts, which would drastically reduce the external doses
with less impact on cask capacity.

There are, however, less costly ways to accommodate higher burnup fuels. Broadhead et. al.
(1992) showed that by using a modified basket and by derating the cask 15 percent (an 18-
assembly payload vs a 21-assembly payload) a cask with 5-year-cooled 60,000 MWd/MTU.
spent fuel had a lower dose rate than a 21-assembly cask containing 35,000 MWd/MTU fuel
that had cooled 5 years. While the dose rates of higher-burnup fuels decline more slowly
than 35,000 MWd/MTU fuel, Broadhead et al. also showed that increasing cooling times
from 5 to 15 years compensates for an increase in burnup from 35,000 to 60,000 MWd/MTU.
That is, a cask designed for 5-year-cooled 35,000 MWd/MTU spent fuel should be capable
of accommodating 15-year-old 60,000 MWd/MTU spent fuel without derating. Thus, where
on-site storage of SNF is not too costly, transportation costs and impacts can be minimized
by allowing higher burnup SNF to cool 15 years before disposal.

The above two scenarios present cases where the high burnup fuels can be placed into
standard casks with little or no cask derating, while meeting radiation limits outside of the
cask. Under these scenarios, the actual number of trips to a repository would be decreased
because the number of spent fuel assemblies required for given amount of power would be
smaller with higher burnup fuel. There are other scenarios in which the number of required
trips is reduced by “blending” of cask loadings, in which higher-burnup fuel assemblies are
placed in the middle of the cask, while lower burnup assemblies are place near the edge of
the cask cavity region to absorb radiation from the inner assemblies. While this scenario

NUREG-1437, Addendum 1 28


Supplemental Analyses for Cumulative Environmental Impacts. . .

analysis includes approximately two hours of stationary time in Clark County (during a 100 to
140 mile trip depenciing upon the route) for each truck shipment; and traffic gridlock could be
one of the reasons for the truck being stationary.

To a limited extent, the incorporation of more conservative assumptions of truck speed
into the revised RADTRAN analysis compensates for an analysis of traffic gridlock by
allowing for increased exposure time at any given point during transport. As noted earlier,
these revised assumptions lead to higher but still small dose estimates. In addition, the
routes used in the analysis in Addendum 1 were deliberately chosen to maximize estimated
dose. Actual routes would be less likely to have significant areas where traffic gridlock
occurs. The selection of the actual routes, for example, would comply with the U.S.
Department of Transportation’s Federal Highway Administration regulations (49 CFR Part
397, Subpart D) that require minimizing the time in transit (i.e., avoiding periods of great
traffic congestion) for routing radioactive shipments.

Comment: There was insufficient consideration of routine transportation radiological risks
to vehicle inspectors and escorts.

Response: The RADTRAN analysis in the revised Addendum 1 conservatively uses the
regulatory dose rate limit of .02 mSv/hour (2 mrem/hour) for the vehicle crew. In addition, a
discussion of potential doses to escorts has been included in Addendum 1, Section 2.2.3. In
the analysis, both the escorts and drivers are assumed to be exposed to the regulatory limit,
although the dose to the escorts would realistically be less than that to the drivers. Even with
these more conservative assumptions, the estimated dose and risk to the crew are small and
below regulatory limits.

The risk to vehicle inspectors would be encompassed by the addition of stationary time
for the transport truck in Clark County (see response to comment about traffic gridlock,
above). Again, the estimated dose and risk are increased by the use of more conservative
assumptions; but they remain small and below regulatory limits.

Comment: There was insufficient consideration of severe transportation accident risks.

Response: The Commission has evaluated the potential radiological hazards of severe
transportation accidents involving truck and rail spent nuclear fuel (SNF) shipments
(NUREG/CR-4829, “ Shipping Container Response to Severe Highway and Railway Accident
Conditions” February 1987, commonly referred to as the modal study). The modal study
evaluated SNF shipping casks certified to NRC standards against thermal and mechanical
forces generated in actual truck and rail accidents. This evaluation included an assessment
of cask performance for a number of severe transportation accidents, including the Caldecott
Tunnel fire. The modal study concluded that there would be no release in 994 of 1,000 real
accidents, and that a substantially lower fraction of accidents could result in any significant
release. These results when combined with the probability of a severe accident involving a
shipment of SNF, demonstrate that the overall risk associated with severe accidents of SNF
shipping casks is very low. The results of the modal study were factored into the analysis for
this rulemaking, as an input to the RADTRAN computer code. Additional analyses were
performed to address the possible impacts of accidents involving higher burnup fuel.

The consequences associated with an individual SNF shipment have an upper bound,
based on the amount of material in the package, the availability of mechanisms to disperse

NUREG-1437, Addendum 1 Al-6


Supplemental Analyses for Cumulative Environmental Impacts. ..

Response: The rule language has been amended and Paragraph (M) has been deleted.
This change from the proposed rule was necessary in order to provide consistency with
51.53(c)(3)(ii), as this section only deals with Category 2 issues. Since the cumulative
impacts of transportation of SNF in the vicinity of Yucca Mountain is no longer a Category 2
issue, inclusion in 51.53(c)(3)(ii) is no longer necessary.

Other Comments

This section addresses the comments that are not encompassed by the issue summaries
and responses given above. In addition, some comments were received after the close of
the comment period. These comments were reviewed, and most were found to be similar to
comments already addressed by the issue summaries and responses. However, the
comments that raised new ideas relevant to Addendum 1 are also presented in this section.
For these late comments, revisions to Addendum 1 were necessarily minimal.

Comment: Addendum 1 assumes that truck transport would have the highest doses.
This assumption is not necessarily valid. Also, a different route that avoids Las Vegas
should be addressed. (A route through Nellis Air Force Base and down US-95 is being
considered by DOE and it has been shown to have higher risks of accident fatalities and to
increase the radiological risk.) Routes chosen in Addendum 1 do not bound the analysis

properly.

Response: The transportation and route scenarios and their underlying assumptions
were designed to reflect situations that most likely would result in highest doses in order to
bound the analysis properly as the routes chosen for this analysis were the most populated
routes in the state of Nevada. Also, as noted in an earlier response, the NRC staff consulted
DOE in determining that truck shipments through densely populated areas of Clark County,
Nevada, would have the highest potential impacts among the alternative transportation
scenarios that would be given serious consideration in decisions relating to the suitability of
the site undergoing study for a repository at Yucca Mountain.

The comment that a route from Nellis Air Force Base down US-95 is higher risk than
those selected by the NRC staff provided no specific details concerning that assertion. In
the NRC staff’s view, any route that bypasses major centers of population will have
significantly lower radiological impacts. With regard to traffic accident rates, while it may be
true that certain routes will have accident rates that are higher than average, the average
rates are low enough that modest increases from the average will not significantly change
the staff's conclusions.

Comment: SNF from California would go through Las Vegas twice (in route to Skull
Valley and subsequently to Yucca Mountain), resulting in increased risk.

Response: If the proposed SNF storage facility is licensed and built, some SNF may go
through Clark County on the way to Skull Valley, Utah. The NRC staff has not analyzed this
possible impact because it is not clear at this time that the proposed Skull Valley facility will
be licensed or that the SNF would go through Las Vegas if the facility were built. In addition,
SNF from California makes up only a small fraction of the SNF that would be shipped. The
NRC staff concludes that the conservative assumptions used in the analysis more than
compensate for minor changes in transportation plans that may develop for that fraction of
the total SNF.

Al-11 NUREG-1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

the radioactive contents, the locations and number of receptors, and post-event intervention
than would occur. Further, this upper bound in transit might reasonably be expected to be
less than that at the origin or destination points (where more SNF wouid be stored), and
some events themselves might be expected to have greater consequences than the damage
they cause to the SNF cask. The NRC recognizes that there are some conceivable events
(not necessarily traditional transportation accidents’), that might be hypothesized to occur to
a SNF cask while in transport. Even though these events have an extremely low probability
of occurring, they might result in high consequences if they were to occur. The NRC
considers these events to be remote and speculative and thus, does not call for detailed
consideration. Because the NRC traditionally considers risk to be the product of the
probability of an event and its resultant consequences, events with such low probability of
occurring have a negligible contribution to the overall risk. In addition, as the probabilities of
the events become very low, the value of insights to be gained, for use in regulatory
decisions, is not apparent.

Comment: The study underestimates Clark County’s residential population and growth
rate. In addition, the study does not account for the large nonresident population, resulting in
underestimates of risk and impacts.

_ Response: In keeping with the generic nature and limited intent of the analysis, the
original analysis used best available data and best estimates of existing population and
population growth rates. In response to commentors’ concerns and to reflect the potentially
large population growth rate of Clark County, the NRC staff has incorporated higher
population estimates into the analysis to provide conservative (higher than best estimate)
assessments of potential impacts. However, as indicated by the comment, the task of
estimating the impacts on the area population is more complex than assuming a population
growth rate. Both the rate of growth of the population and changes in location of the
population within the county are important. As stated in Addendum 1, populations within a
half mile of the transportation route are the most affected by the transportation activities.
Therefore, in order to ensure that the size of the affected population is conservative, the
NRC staff's analysis not only increases over time the existing population densities along the
assumed transportation routes, but also forecasts increased residential, business, and
transient/tourist populations in the areas of likely development.

Issue 4—Cumulative Impacts

Comment: NRC failed to consider cumulative impacts of all spent fuel, HLW, and low-
level-waste shipments.

Response: Table S-4 shows the environmental impacts of transportation of fuel and
waste directly attributable to one nuclear power plant. The current rulemaking was narrowly
focused on the question of whether the impact values given in Table S-4 would be different
with spent fuel shipments converging on one destination, Yucca Mountain -- the candidate
site under study by DOE for a repository, rather than several destinations. Table S-4 does
not consider non-commercial power reactor shipments of fuel and waste. Nevertheless, a
discussion of the cumulative impacts of transporting spent fuel, HLW, and low-level waste
through southern Nevada has been added to Addendum 1 (Section 2.4). To estimate the
potential cumulative effects of DOE shipments of LLW to the Nevada Test Site as well as
shipments of HLW to a possible repository, the NRC staff used information published in
DOE’s Waste Management Programmatic EIS (DOE/EJS-0200-F) May 1997. To ensure that

Al-7 NUREG-1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

INCIDENT-FREE SUMMARY

INCI DENT-FREE POPULATION EXPOSURE IN PERSON-RI

PASSENGR CREW HANDLERS OFF LINK ON LINK STOPS

LINK 1 0.00E+00 1.278+03
0.00E+00 4.7 7E+02
LINK 3 0.00E+00 3.79E+02

LINK 2

RURAL 0.00E+00 1.27E+03 0.0)
SUBURB 0.00E+00 4.77E+02 0.0
URBAN 0.00E+00 3.79E+02 0.0

TOTALS: 0.00E+00 2.13E+03 0.0

0.00E+00 1.79E+00 1.13E+
0.00E+00 6.95E+01 1.63E+
0.00E+00 6.25E+00 8.21E+

0E+00 1.79E+00 1.13E4
OE+00 6.95E+01 1.63E+
}OE+00 6.25E+00 8.21E+

OE+00 7.76E+01 1.10E+

02 1.60E+03
02 7.91E+02
02 7.91E+02

02 1.60E+03
02 7.91E+02
02 7.91E+02

03 3.188+03

MAXIMUM INDIVIDUAL IN-TRANSIT DOSE

LINK 1 4.03E-02 REM
LINK 2 4.03E-02 REM
LINK 3 4.03E-02 REM

EXPECTED VALUES OF POPULATION RISK IN PERSON-REM

GROUND
LINK 1 1.60E+01
LINK 2 3.29E+02
LINK 3 2.27E+02

RURAL 1.60E+01
SUBURB 3.29E+02
URBAN = 2..27E+02

TOTALS: 5.72E+02

INHALED
2.43E-01
4.84E+00
2.91E+00

2.43E-01
4.84E+00
2.91E+00

7.99E+00

RESUSPD CLOUDSH
6.86E-01 7.60E-04
1.37E+01 1.56E-02
8.24E+00 9.24E-03

6.86E-01 7.60E-04
1.37E+01 1.56E-02
8.24E+00 9.248-03

2.26E+01 2.56E-02

NOTE THAT INGESTION RISK IS A SOCIETAL RISK;

*INGESTION
0. 00E+00
0.00E+00
0.00E+00

0.00E+00
0.00E+00
0.00E+00

0.00E+00

THE USER MAY WISH TO TREAT THIS VALUE SEPARATELY

EM

STORAGE

0.00E+00
0.00E+00
0.00E+00

0.00E+00
0.00E+00
0.00E+00

0.00E+00

TOTAL

1.69E+01
3.4BE+02
2.38E+02

1.69E+01
3.48E+02
2.38E+02

6.03E+02

TOTALS
2.99E+03
1.50E+03
2.00E+03

2.99E+03
1.50E+03
2.00E+03

6.48E+03

NUREG- 1437, Addendum 1

A3-10


Supplemental Analyses for Cumulative Environmental Impacts. . .

INCIDENT-FREE SUMMARY

INCIDENT-FREE POPULATION EXPOSURE IN PERSON-REM

PASSENGR CREW HANDLERS OFF LINK ON LINK STOPS
LINK 1 0.00E+00 5.43E+02 0.00E+00 1.22E+00 4.83E+01 6.85E+02
LINK 2 0.00E+00 2.54E+02 0.00E+00 2.96E+01 8.67E+01 5.28E+02

LINK 3 0.00E+00 3.83E+02 0.00E+00

RURAL 0.00E+00 5.43E+02 0.00E+00
SUBURB 0.00E+00 2.54E+02 0.00E+00
URBAN 0.00E+00 3.83E+02 0.00E+00

TOTALS: 0.00E+00 1-18E+03 0.00E+00

8.00E+00 8.28E+02 5.28E+02

1.22E+00 4.83E+01 6.85E+02
2.96E+01 8.67E+01 5.28E+02
8.00E+00 8.28E+02 5.28E+02

3.88E+01 9.63E+02 1.74E+03

MAXIMUM INDIVIDUAL IN-TRANSIT DOSE

LINK 1 2.69E-02 REM
LINK 2 2.69E-02 REM
LINK 3 2.69E-02 REM

EXPECTED VALUES OF POPULATION RISK IN PERSON-REM

GROUND
LINK 1 1.09E+01
LINK 2 1.40B+02
LINK 3 2.91E+02

RURAL 1. 09E+01
SUBURB 1.40E+02
URBAN 2.91 E+02

TOTALS: 4.42E+02

INHALED

1.65E-01
2.06E+00
3.73E+00

1,65E-01
2.06E+00
3.73E+00

5.96E+00

RESUSPD

4.66E-01
5.83E+00
1,05E+01

4. 66E-01
5.83E+00
1.05E+01

1.68E+01

CLOUDSH *INGESTION
5.17E-04 0.00E+00
6.67E-03 0.00E+00
1.18E-02 0.00E+00

5.17E-04 0.00E+00
6.67E-03 0.00E+00
1.18E-02 0.00E+00

1.90E-02 0.00E+00

* NOTE THAT INGESTION RISK IS A SOCIETAL RISK;
THE USER MAY WISH TO TREAT THIS VALUE SEPARATELY.

STORAGE

0.00E+00
0.00E+00
0.00E+00

0.00E+00
0.00E+00
0.00E+00

0.00E+00

TOTAL

1.15E+01
1.48E+02
3.05E+02

1.15E+01
1.48E+02
3.05E+02

4.65E+02

TOTALS
1.28E+03
8.98E+02
1.75E+03

1.28E+03
8.98E+02
1.75E+03

3.92E+03

NUREG-1437, Addendum 1

A3-20


Supplemental Analyses for Cumulative Environmental Impacts. . .

APPENDIX 1

STAFF RESPONSES TO PUBLIC COMMENTS
ON ADDENDUM 1 AND THE PROPOSED RULE

THE SCOPING PROCESS

The proposed amendments to 10 CFR 51.53(c)(3)(ii)(J) and (M) were published in the
Federal Register on February 26, 1999 (64 FR 9884-88), and a 60-day comment period that
ended on April 27, 1999, was provided. A Notice of Availability for NUREG-1437, Vol. 1,
Addendum 1 appeared in the same issue of the Federal Register (64 FR 9889) and included
a solicitation for public comments through April 27, 1999.

Thirty-one comment letters were received on the proposed rule from power reactor
licensees, State and local Government agencies, the nuclear power industry and its legal
affiliations, a public interest group, and an individual. Most of the comments were from the
State of Nevada, Clark and Nye Counties, Nevada, and local government entities in Nevada.
These comments focused on the NRC not involving Nevada in scoping and designing the
study in Addendum 1 and on perceived deficiencies in the scope and thoroughness of the
analysis in the Addendum. The State of Utah also submitted extensive comments that
focused on concerns with the scope and thoroughness of the supporting analysis in
Addendum 1, including the lack of consideration of the proposed Private Fuel Storage
Facility at Skull Valley, Utah. Industry comments focused on clarifications in the rule
language.

Written comments were received from the following agencies, organizations, and individuals:

Baltimore Gas and Electric Company

The Honorable Richard H. Bryan, United States Senator

Carolina Power & Light Company

Chattooga River Watershed Coalition (Nicole Hayler)

Clark County, Nevada, Department of Comprehensive Planning, Nuclear
Waste Division (two submissions)

Eureka County, Nevada, Yucca Mountain Information Office

Alice Fessenden, City Council member, City of Mesquite, Nevada

Florida Power and Light Company

Jan Laverty Jones, Mayor, City of Las Vegas

Mineral County, Nevada, Nuclear Projects Office

Nuclear Energy Institute

Nye County, Nevada, Department of Natural Resources and Federal Facilities
Part 51 Utility Group (consists of Commonwealth Edison Company, Duke
Energy Corporation, and Southern Nuclear Operating Company). Comments
submitted by Winston & Strawn, counsel to the Part 51 Utility Group

. PECO Nuclear (A Unit of PECO Energy)

Al-1 NUREG-1437, Addendum 1


NUREG-1437, Vol. 1
Addendum 1

Generic Environmental
Impact Statement
License Renewal of
Nuclear Plants

Main Report

Section 6.3—Transportation

Table 9.1 Summary of findings on NEPA
issues for license renewal of nuclear power

plants

Final Report

—

Manuscript Completed: August 1999
Date Published: August 1999

Division of Regulatory Improvement Programs
Office of Nuclear Reacter Regulation

U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001

NRC Job Code

e pon RE Ca


| winpueppy ‘L¢p1-DTaON

9-7V

Route 3. (continued).
RADTRAN Input Data Rural Suburban Urban

Weighted Population

People/sq. mi. 10.0 1174.1 6489.6
People/sq. km. 3.8 453.3 2505.6
Distance Total
Miles 114.1 14.3 7.6 136.0
Kilometers 183.6 23.0 12.2 218.9
Percentage 83.9 10.5 5.6
Basis (people/sq. mi.) <139 139-3326 >3326 Estimated 2020 population

Note: Due to rounding, the sum of the mileage in the individual population
categories may not equal the total mileage shown on this report.

Route 4. From I-15 south of Las Vegas using bypass.

HIGHWAY 3.4

JBOSS UISISISIIDISISISSI IDS SIIOIUOIIOUSISSCIISGIISO IGE I IOC ISUOIIIOIDIIOEI OGIO TOSI ISHII GI IOUS I Oe

CANVI15 NIPTSLOA NV to MERCURY Ss U95 LOCL NV

JUSSI IOOIIDIIIISIIISSISISISIIOUEISOTIIOSISISI ISIS IIUIO IIS SI ISS IS SEITE EIS USSU ISS SGI IOI IU ISO I IOI

Leaving : 6/17/99 at 11:34 PDT Arriving: 6/17/99 at 13:23 PDT
Total Road Time: 1:49 Total Miles: 110.0

Route Type: C with 2 Driver(s) Time Bias: .70 Mile Bias: +30 Toll Bias: 1.00
The following constraints are in effect:

Route avoids links prohibiting truck use

Route avoids ferry crossings

Mileage by Highway Sign Type:

Interstate: 61.0 U.S.: 49.0 State: +0 Turnpike: 7)
County: .0 Local: .0 Other: 0
Mileage by Highway Lane Type:
Limited Access Multilane: 61.0 Limited Access Single Lane: 0
Multilane Divided: 49.0 Multilane Undivided: 20

Principal Highways: -0 Through Highways: -0 Other: +0

“siooduy poluauuUoNAUT aauninuny sof saskjouy joruatuajddng



Supplemental Analyses Jor Cumutanve Environmentat impacts. . .

The analysis done by the NRC staff concluded that higher burnup fuel would likely cause
higher dose rates during transportation and that dose rates following transportation accidents
with radiological releases would also increase, all other things being equal. However,
despite the increased dose rates the potential impacts on the transport crews and the
affected members of the public would still be acceptably small. The analysis of the potential
for criticality following a change in fuel geometry as the result of a transportation accident
determined that such an event was not a concern.

Issue 8—Environmental Justice
Comment: NRC failed to consider Environmental Justice.

Response: The analysis suggests that the routes through downtown Las Vegas, Nevada
may run through areas containing a higher proportion of low-income and minority groups
than the beltway routes. However, as discussed in Sections 2.3 and 2.4 Addendum, the
radiological and nonradiological impacts of transportation of SNF are small. In addition,
these small impacts are dispersed throughout the entire routes and do not appear to fall
disproportionately in any one area. Based on the analysis performed the NRC staff
concludes the overall impacts of transportation of SNF will not likely be disproportionately
high or adverse for any minority or low-income population.

Issue 9—Regulatory Text
Comment: Several suggestions for clarifying the regulatory text were offered.

Response: The rule has been revised to make it clear that the environmental impact
values in Table S-4 (10 CFR 51.52) may be used to account for the environmental effects of
transportation of fuel and waste to and from a nuclear power plant at repository such as
Yucca Mountain, Nevada, which is under consideration as a HLW repository. If, in the
future, Yucca Mountain is removed from consideration as a HLW repository, the Commission
will evaluate whether the generic analysis performed for the current rule is applicable to other
sites that are considered. If fuel enrichment greater than 5 percent Uranium-235 and fuel
burnup of greater than 62,000 MWd/MTU are approved by the Commission, the Commission
will consider a rulemaking to assess the continuing generic applicability of Table S-4 to
environmental reviews for license renewal.

Comment: The addition to the rule of local transportation impacts associated with
continued operation of a plant during the license renewal period needs further clarification in
the rule language and in the Supplementary Information.

Response: The rule was revised to clarify that the issue of “Public services,
Transportation” in Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 involves the
contribution of highway traffic directly attributable to refurbishment and continued operation
of a plant during the license renewal period to changes in the service levels of highways in
the vicinity of the plant. The majority of traffic directly attributable to a plant is commuting
plant workers.

Comment: Paragraph (M) of 10 CFR 51.53(c)(3)(ii) should be deleted.

NUREG-1437, Addendum 1 Al-10


Supplemental Anatyses yur Cumuuntve environment smpacis. . .

Table 4. Cumulative radiological transportation risks resulting from
SNF transport in Clark County*

Estimated lifetime risk of fatal cancer

(LRFC)?

Incident-free risk Accident tisk

Crew* Public? Public
From northeast using beltway
without license renewal 0.512 1.385 0.153
From northeast using beltway
with license renewal 0.772 2.070 0.229
From northeast through downtown
without license renewal 0.568 1.450 0.201
From northeast through downtown
with license renewal 0.852 2.175 0.302
From south using beltway
without license renewal 0.528 1.450 0.271
From south using beltway
with license renewal 0.788 2.185 0.407
From south through downtown
without license renewai 0.472 1.370 0.233
From south through downtown
with license renewal 0.708 2.055 0.349

a Transportation risks were calculated using RADTRAN (v. 4.0.19.SI., dated March
16, 1999. Access to the RADTRAN computer code was furnished on TRANSNET computer
system by the U.S. Department of Energy's Transportation Technology Center at Sandia
Natiopal Laboratories.

For crew members, the dose conversion factor was 0.0004 estimated lifetime risk of
fatal cancer (LRFC) per person-rem, and for the general public, 0.0005 LRFC per person-
rem. he U.S. average lifetime risk of fatal cancer from all causes is approximately 0.25.

Transport crew size was assumed to be 4 persons (2 people in the truck and 2
people in the escort vehicle). Crew dose is for the time spent driving In Clark County,
approximately 166 to 230 km (approximately 100 to 145 miles); the dose involved in driving
to Clark County is not included.

The incident-free risk to the public does not include the risk to the crew.

NUREG-1437, Addendum I 18


Supplemental Analyses yur Cummauve crvironmeniut impacis. .«

A National Academy of Sciences report (NAS 1990, Table 4-2), commonly called the BEIR V
report, gives estimates of the number of cancer deaths expected to occur from a continuous
exposure of 10 mSv/year [1 rem/year] above background from age 18 until age 65. This
value results in a risk factor of 4.0 x 10°? LRFC per person-Sv [4.0 x 10°* LRFC per
person-rem] that is most applicable to occupational exposure. The BEIR V report also
estimates the number of cancer deaths expected to occur from a continuous lifetime
exposure of 1 mSv/year [100 mrem/year] above background, which results in a risk factor of
5.0 x 10°? LRFC per person-Sv [5.0 x 10“ LRFC per person-rem] that is most applicable to
exposure of the general public. The general public LRFC risk factor is slightly higher than the
occupational risk factor because the general public dose is assumed to be experienced by
people of all ages while the occupational exposures are assumed to be experienced only by
people from age 18 until age 65. Children and adolescents are presumed to be more
susceptible to radiation-induced health effects than adults.

Table 2. Radionuclide inventory for the SNF shipments'

PWR fuel in Physical/ PWR fuel in Physical/

GA-4cask chemical _Dispersibility GA-4.cask chemical _Dispersibility
Isotope _ (Curies) group category Isotope (Curies) group category
Cr 7.40E-16 SOLID 2 weTe 2.12E-01 SOLID 2
Min 4,80E+01 SOLID 2 TMCs 1.09E+05 VOLATILE 7
Fe 3.82E+03 SOLID 2 Cs 3.21E+05 VOLATILE 7
Fe 3.84E-10 SOLID 2 Ba 3.03E+05 SOLID 2
5°Co 3.67E-04 SOLID 2 “Ce 2.71E-11 SOLID 2
Co 1.20E+04 SOLID 2 TMCe 2.21E+04 SOLID 2
Kr 1.96E+04 GAS 10 “Dr 2.21E+04 = SOLID 2
Sr 1.42E-05 SOLID 2 “7PM 9.17E+04 SOLID 2
Sr 2.20E+05 SOLID 2 Eu 1.77E+04 SOLID 2
sy 5.81E-04 SOLID 2 238py 1.72E+04 SOLID 2
Zr 1.78E-04 SOLID 2 239Py 7.09E+02 SOLID 2
Nb 1.24E-02 SOLID 2 20Ry 1.32E+03 SOLID 2
Ru 2.40E-08 VOLATILE 7 2“Py 2.88E+05 SOLID 2
16Ry 4.04E+04 VOLATILE 7 2am 3.17E+03 SOLID 2
5Sb 5.80E+03 SOLID 2 22Cm 1.14E+02 SOLID 2
125"Te 1.63E+02 SOLID 2 240m 2.18E+04 SOLID 2
"Te 2.09E-01 SOLID 2

Total 1.52E+06

‘Based on an ORIGEN-ARP computer code calculation performed by B. Broadhead, Oak Ridge National
Laboratory, on June 10, 1999. The ORIGEN-ARP computer code was used to generate an updated
radionuclide source term that assumed a specific power of 28.3 MW/MTU, a burnup of 62,000 MWd/MTU in 4
fuel cycles, cycle length of 548 days with no downtime between each cycle, 5 year cooling time, 5% fuel
enrichment, and cross sections libraries for a 15 x 15 pressurized water reactor fuel assembly.

NUREG-1437, Addendum 1 14


Supplemental Analyses for Cumulative Environmental Impacts. . .

Accurately examining income distribution is difficult because the poverty data are aggregated
over larger areas than are data for ethnic and racial groups. On the basis of 1990 census
data, the NRC staff estimated the percent of the populations in poverty along the routes as
shown in Table 10. The only route that would encounter higher than the U.S. average of low-
income persons is the route from the northeast through downtown.

Table 10. Fraction of persons along the transportation
routes who are in poverty (percent) *

From the northeast using beltway 8.3
From the northeast through downtown 14.8
From the south using beltway 6.8
From the south through downtown 10.9

County as a whole 10.4

? Based on 1990 census data.

The analysis suggests that the routes through downtown may run through areas containing a
higher proportion of low-income and minority groups than the beltway routes. However, as
discussed in Sections 2.3 and 2.4, the radiological and nonradiological impacts of
transportation of SNF are small. In addition, these small impacts are dispersed throughout
the entire routes and do not appear to fall disproportionately in any one area. Based on the
above analysis the NRC staff concludes the overall impacts of transportation of SNF will not
likely be disproportionately high or adverse for any minority or low-income population.

3. IMPLICATIONS OF HIGHER BURNUP FUEL FoR
THE CONCLUSIONS IN TABLE S-4

3.1 BACKGROUND

The license renewal rule amending 10 CFR Part 51 promulgated on December 18, 1996

(61 FR 66537) gave license renewal applicants the responsibility to comply with the existing
requirements of 10 CFR 51.52. Section 51.52(a) specifies six conditions that must be met in
order for an applicant to adopt the values in Table S-4 of that section, which represent the
contribution of transportation to the environmental costs of licensing the reactor. If the six
conditions are not met, an applicant must submit a full analysis of the environmental impacts
of transportation of fuel and waste in accordance with §51.52(b). Two of the conditions limit
the fuel enrichment level and the burnup level . Paragraph 51.52(a)(2) requires a uranium-
235 enrichment not exceeding 4 percent by weight in the fuel. Paragraph 51.52(a)(3)

NUREG-1437, Addendum 1 26


Supplemental Analyses for Cumulative Environmental Impacts. . .

Comment: The analysis needs to address the impacts of above ground nuclear weapons
testing being done at the Nevada Test Site.

Response: For the purposes of considering the environmental impacts of license
renewal, there does not appear to be a relevant connection between transportation impacts
from civilian SNF and defense related weapons testing at the Nevada test site.

Comment: The analysis relies on assumptions that are 25-30 years old and that have a
number of problems including omission of important radionuclides (lodine-129, Chlorine-36
and Cobalt-60), unrealistic RADTRAN assumptions including inadequate consideration of
severe accidents, outdated assumptions from NUREG-0170 and WASH-1238 including the
failure to consider the degradation of cladding during extended dry storage, and failure to
consider the rail-heavy haul truck option.

Response: With regard to the radionuclides, as indicated in Table 2 of Addendum 1,
Cobalt-60 is considered. While both lodine-129 and Chlorine-36 are long lived, neither is a
significant contributor to overall dose. lodine-129 has a very low specific activity and
Chliorine-36 is a beta emitter.

The issue of the severity of accidents considered in the NRC staff's analysis was
addressed in an earlier response to comment. The assumptions that are used in the NRC
staff's analysis have been periodically reviewed and found adequate. The hypothetical
accident conditions of 10 CFR 71.73 have been evaluated against actual conditions
encountered in highway and railway accidents and were found to be bounding as
documented in NUREG/CR-4829, February 1987, “Shipping Container Response to Severe
Highway and Railway Accident Conditions.” As noted in Table 3 of Addendum 1, the version
of RADTRAN used is updated to March 1999.

Section 3 of Addendum 1 does consider the possible effect of cladding degradation on
criticality in the context of increased burnup. That analysis would be equally applicable to
any cladding degradation that might occur during prolonged dry storage of the SNF.

With regard to what is asserted to be inadequate consideration of the potential
radiological impacts of the rail-heavy haul truck option, the NRC staff has analyzed the
radiological impacts of the truck mode along various routes through and around Las Vegas
and concludes that they are the limiting scenarios. The largest doses in the incident-free
conditions are now to the public. If the rail-heavy haul transport scenario was adopted, a
substantial portion of the public exposure would be avoided, since in this scenario, the slow
moving heavy haul truck transport would not move through a major population center.

Comment: NRC must consider potential Indian Tribe claims of authority to regulate
shipments across reservation lands.

Response: This analysis is a generic study that assumes certain routes for the purpose
of evaluating environmental impacts. Because the purpose of this study is neither to
propose nor approve routes, the NRC does not need to consider tribal claims of authority to
regulate shipments in the context of this analysis.

Comment: The beltway is a county road, not part of the Federal highway system; it is not
clear it can be used for shipments.

NUREG-1437, Addendum 1 Al-16


Supplemental Analyses for Cumulative Environmental Impacts. . .

ECHO CHECK

&& Edited Mon Jun 21 15:23:48 1999
&& _North_route_via_city_with_rx_life_extension_
TITLE RADTRAN 4.0 INPUT

FORM UNIT
DIMEN 31 8 3 101
PARM 13210

8

PACKAGE
LABGRP
SOLID GAS —-VOLATIL
SHIPMENT
LABISO
cRS1 MNS4 FESS
KR85 SR89 SR9O
RULO3 RU1 06 SB125
csi34 cs137 CEL41
PU238 PU2 39 PU240
M244
NORMAL
NMODE=1
9.000E-01 5.000E-02 5.000E-0:
4.000E+00 3.100E+00 0.000E+0
0.000E+00 3.000E+01 2.000E+0:
2.000E+00 8.000E-02 5.000E-0:
2.800E+03
ACCIDENT
SEVFRC
NPOP=1
NMODE=1
4.62E-01 3.02E-01 1.76E-01
5.71E-04 1.13E-04
NPOP=2
NMODE=1
4.35E-01 2.858-01 2.21£-01
6.72E-05 5.93E-06
NPOP=3
NMODE=1
5.83E-01 3.82E-01 2.78E-02
1.13E-05 9.94E-07
RELEASE
RFRAC
GROUP=1
0.00E+00 6.00E-08 2.00E-07
2.00B-05 2.00E-05
GROUP=2
0.00E+00 9.90E-03 3.30E-02
6.30E-01 6.30E-01
GROUP=3
0.00E+00 6.00E-06 2.00E-05
2.00E-03 2.00E-03
EOF
ISOTOPES -1 75278 1.00 13.000
R51 7.40E-16 SOLID 2
MNS4 4.80E+01 SOLID 2
FE55 3.82E+03 SOLID 2
FE59 3.845-10 SOLID 2
OSB 3.67E-04 SOLID 2
C060 1.20E+04 SOLID 2
KR85 1.96E+04 GAS 10
SR89 1.42E-05 SOLID 2
SR90 2.20E+05 SOLID 2
¥91 (5.81E-04 SOLID 2
2R95  1.788-04 SOLID 2
NB95 1.24E-02 SOLID 2
RUIO3 2.40E-08 VOLATIL 7
RULO6 4.04E+04 VOLATIL 7
SB125 5.80E+03 SOLID 2
TEI25M 1.63E+02 SOLID 2
TE127 2.098-01 SOLID 2
TE127M 2.12E-01 SOLID 2
CS134 1.09E+05 VOLATIL 7
CS137 3.21E+05 VOLATIL 7

FES9
yY91
TE125M
CE144
PU241

2 8.849E+01
0 -1.100E-02
1 0.000B+00
2 8.500E-01

co58
ZR95
TE127
pM147
AM241

4.025E+01
1.000E+00
1.000E+02
4.700E+02

4.03E-02 1.18E-02 6.4

5.06E-02 6.64E-03 1.7

co60
NB9S
TE127M
EU15S4
M242

2.416E+01
0.000E+00
1.000E+02
7. 800E+02

7E-03

4E-03

6.36E-03 7.42E-04 1.46E-04

2.00E-06 2.00E-06 2.00E-06

3.90E-01 3.30E-01 3.3:

2.00E-04 2.00E-04 2.01

1.00 0.00 VEGASI

OE-01

OE-04

NUREG- 1437, Addendum 1

A3-8


Supplemental Anatyses yur Cumuuuve cnvieronmentat impus. . .

period, these risks amount to very small annual risks; less than 0.0015 fatalities per year
(with or without license renewal).

The NRC staff also estimated the potential human health effects of vehicle emissions of
transport trucks and escort vehicles using conservative assumptions. DOE/EIS-0200-F (page
E-32) presents a risk factor for latent mortality from pollution inhalation for truck travel in an
urban area; 10 per 100 million truck-km (16 per 100 million truck-miles). DOE reports that no
similar estimates are available for rural and suburban areas. However, comparable estimates
would be much lower in suburban and rural areas because they are much less densely
populated than urban areas. To develop a conservative estimate, the NRC staff assumed
that escort vehicles had emissions as large as the large trucks that haul SNF. Further, the
NRC staff applied the risk factor to both the urban and suburban areas. The route with the
largest distance of combined urban and suburban travel was the south by the beltway route,
59.1 km (36.9 miles) (Table 1). For the license-renewal scenario, an estimate on the order of
75,000 shipments yields total vehicle travel distance of 17.8 million km (11.1 million miles)
including both repository-bound and return trips for both the transport truck and the escort
vehicle. Using the risk factor reported by DOE yields an expected 1.8 latent mortalities due to
pollutant emissions by the transport trucks and escort vehicles for the entire campaign.
Assuming a 40-year campaign, this estimate yields an expected 0.045 latent mortalities per
year.

To develop a conservative estimate of the potential impact of SNF transport in Clark County,
the NRC staff assumed that trucks would make 150,555 trips through the county over the
campaign, assuming the license-renewal scenario (approximately 75,000 shipments plus
return trips). An equivalent number of trips would be made by an escort vehicle. Using the
longest route (Table 1), the one-way distance traveled would be 230.1 km (143 miles) per
vehicle. Assuming all SNF transport occurs over a 40-year period, SNF transport in Clark
County would involve 0.86 million vehicle km (0.54 million vehicle miles) for the trucks and
the same number of vehicle kilometers for escort vehicles. The Nevada Department of
Transportation (NDOT) reports that in 1997 it maintained 839 miles of the 4559 miles of
improved road in Clark County, and that NDOT-maintained, Clark-County roads carried
8,611 million vehicle-km (5,382 million vehicle-miles) of travel, about 56 percent of the total
vehicle miles of travel in the county. Assuming that SNF shipments occur only on the NDOT-
maintained roads and that highway travel does not increase before SNF shipments begin,
commercial SNF transport (including both the trucks and the escort vehicles) would account
for only about 0.02 percent of the vehicle miles traveled each year on NDOT-maintained
roads in Clark County and slightly more than 0.01 percent of the total vehicle miles traveled
in the county in a year.

The use of public roads by trucks transporting spent fuel will be required to comply with State
of Nevada and local laws regulating vehicle weight and operation. All trucks are subject to
registration fees and fuel taxes that have been designed to cover the costs of maintaining
and repairing public roads. The use of roads for transporting spent fuel could result in
additional road repair and maintenance costs, but such use would also generate additional
revenues. Truck registration fees increase according to vehicle weight. The tax on diesel
fuel is also designed to recover the costs of maintaining public highways. Because state

‘State of Nevada Transportation Facts and Figures. Operations Analysis Division, Nevada Department of
Transportation, January 1999. Accessed at http://www.nevadadot.com/about/fact, July 23, 1999.

NUREG-1437, Addendum 1 20


Supplemental Analyses for Cumulative Environmental Impacts. . .

INCIDENT-FREE SUMMARY

INCIDENT-FREE POPULATION EXPOSURE IN PERSON-REM

PASSENGR
LINK 1 0.00E+00
LINK 2 0.00E+00
LINK 3 0.00E+00

RURAL 0.00E+00
SUBURB 0.00E+00
URBAN 0.00E+00

5.
3.
4.
5.
3.

4.

CREW

A3E+02
36E+02
37E+02

43E+02
36E+02
37E+02

TOTALS: 0.00E+00 1.32E+03

HANDLERS OFF LINK ON LINK
0.00E+00 1.22E+00

0.00E+00
0.00E+00

0.00E+00
0.00E+00
0.00E+00

0.00E+00

5.
-10E+00

7

1.
Ss.
7.

6

19E+01

22E+00
19E+01
10E+00

.02E+01

4.83E+01
1.15E+02
9.45E+02

4.83E+01
1.15E+02
9.45E+02

1.11E+03

STOPS
6.85E+02
5.28E+02
5.28E+02

6.85E+02
5.28E+02
5.28E+02

1.74E+03

MAXIMUM INDIVIDUAL IN-TRANSIT DOSE

LINK
LINK
LINK

1
2
3

2.69E-
2.69E-
2.69E-

02 REM
02 REM
02 REM

STORAGE TOTALS

0.
0.
0.

0.
-00E+00 1.03E+03
0.

0

EXPECTED VALUES OF POPULATION RISK IN PERSON-REM

GROUND

LINK 1 1.09E+01
LINK 2 2.45E+02
LINK 3 2,.58E+02

RURAL 1.09E+01
SUBURB 2.45E+02
URBAN 2.58E+02

TOTALS: 5.15E+02

INHALED
1.65E-01
3.61E+00

7.09E+00 2.00E+01

RESUSPD
4.66E-01
1.02E+01
3.32E+00 9.37E+00

1.65E-01 4.66E-01
3.61E+00 1.02E+01
3.32E+00 9.37E+00

CLOUDSH
5.17E-04 0
1.17E-02 0
1.05E-02 0

5.17E-04 0
1.17E-02 0
1.05E-02 0

2.27E-02 0

* NOTE THAT INGESTION RISK IS A SOCIETAL RISK;
THE USER MAY WISH TO TREAT THIS VALUE SEPARATELY.

-00E+00
-00E+00
-00E+00

-O0E+00
- 00E+00
.00E+00

-00E+00

OOE+00 1.28E+03
O0E+00 1.035+03
O00E+00 1.92E+03
00E+00 1.28E+03

00E+00 1.92E+03

-00E+00 4.22E+03

*INGESTION TOTAL

1.15E+01
2.S59E+02
2.716+02

1.15E+01
2.59E+02
2.71E+02

5.42E+02

NUREG- 1437, Addendum !

A3-26


Supplemental Analyses for Cumulative Environmental Impacts...

1. INTRODUCTION

1.1 PURPOSE OF THE ADDENDUM

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.

1.2 SCOPE OF THE ADDENDUM

In NUREG-1437, Section 6.3 (“Transportation”), the radiological and nonradiological
environmental impacts resulting from transportation of low-level radioactive waste and mixed
waste’ 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

‘Mixed waste is low-level radioactive waste that also contains chemically hazardous constituents.

1 NUREG-1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

CE141 2.71E-11 SOLID 2
CE144 2.215+04 SOLID 2
PM147 9.17E+04 SOLID 2
EUIS4 1.77E+04 SOLID 2
Pu238 1.72E+04 SOLID 2
PU239 7. O9E+02 SOLID 2
pu240 1.32E+03 SOLID 2
PuU241 2.88E+05 SOLID 2
AM241 3.17E+03 SOLID 2
M242 «1.14E+02 SOLID 2
M244 2.18E+04 SOLID 2

LINK 1 1.84E+02 8.80E+01 3.90E+00 4.70E+02 2.25E-07 R 1
LINK 1 3.14E+01 4.Q0E+01 4.64E+02 7.80E+02 2.25E-07 S$ 1
LINK 1 1.50E+01 2.408+01 2.53E+03 2.80E+03 3.60E-07 U1
PKGSIZ

VEGAS1 5.00
EOF

A3-9 NUREG-1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts.

ECHO CHECK

&& Edited Mon Jun 21 15:43:05 1999

&& _South_route_via_city_with_rx_life_extension_
TITLE RADTRAN 4.0 INPUT

FORM UNIT

DIMEN 31 8 3 10 18

PARM 13210

PACKAGE
LABGRP
SOLID GAS VOLATIL
SHIPMENT
LABISO
cRS1 MNS4 FESS FE5S9 co58 C060
KR85 SR89 SR9O y91 ZR95 NB9S
RU103 RU106 SB125 TE125M TE127 TE127M
cs134 cs137 CE141 CEL44 PM147 EU1S4
PpUu238 PU239 PU240 pu241 AM241 M242
M244
NORMAL
NMODE=1

9.000E-01 5.000E-02 5.000E-02 8.849E+01 4.025E+01 2.416E+01
4.000E+00 3.100E+00 0.000E+00 1.100E-02 1.000E+00 0.000E+00
0.000E+00 3.000E+01 2.000E+01 0.000E+00 1.000E+02 1.000E+02
2.000E+00 8.000E-02 5.000E-02 8.500E-01 4.700E+02 7.800E+02
2.800E+03

ACCIDENT

4.62E-01 3.02E-01 1.76E-01 4.03E-02 1.18E-02 6.47E-03
5.71E-04 1.13E-04

NPOP=:
NMOD)
4.35E-01 2.85E-01 2.21E-01 5.06E-02 6.64E-03  1.74E-03
6.72E-05 5.93E-06

NPOP=3
NMODE=1
5.83E-01 3.82E-01 2.78E-02 6.36E-03 7.42E-04 1.46E-04
1.13E-05 9.94E-07

RELEASE

RFRAC

GROUP=1
0.00E+00 6-00E-08 2.00E-07 2.00E-06 2.00E-06 2.00E-06
2.00E-05 2.00E-05

GROUP=2
0.00E+00 9.90E-03 3.30E-02 3.90E-O01 3.30E-01 3.30E-01
6.30E-01 6.30E-01

GROUP=3

0.00E+00 6.00E-06 2.00E-05 2.00E-04 2.00E-04 2.00E-04
2.00E-03 2.00E-03
EOF
ISOTOPES -1 75278 1.00 13.000 1.00 0.00 VEGAS1

CR51 7.-40E-16 SOLID 2
MNS4 = 4.80E+01 SOLID 2
FES5 3.82E+03 SOLID 2
FES9 3.84E-10 SOLID 2
CO58 3.67E-04 SOLID 2
CO60 1.20E+04 SOLID 2
KR85 1.96E+04 cas 10
SR89 1.42E-05 SOLID 2
SR90 2.20E+05 SOLID 2
y91 5.81E-04 SOLID 2
ZR95 1. 78E-04 SOLID 2
NB95 1.24E-02 SOLID 2
RU103 2.40E-08 VOLATIL 7
RU106 4.04E+04 VOLATIL 7
SB125 5.80E+03 SOLID 2
TE125M 1.63E+02 SOLID 2
E127 2.09E-01 SOLID 2
TE127M 2.12E-01 SOLID 2
S134 1.09E+05  VOLATIL 7
S137 3.21E+05 VOLATIL = 7

A3-15 NUREG-1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

1.
2.

10.

List OF FIGURES

Proposed Las Vegas beltway ........... 2... eee eee eee
Routes analyZed in this study .... 0.0.0... 0.6 cee cece ete eee eee

LIST OF TABLES

Transportation route parameters for RADTRAN analysis ...............-+-
Radionuclide inventory for the SNF shipments ............-.----0 ee eeee

Estimated cumulative radiation exposure resulting from SNF

transport in Clark County ........ 0... cece cence nee

Cumulative radiological transportation risks resulting from SNF

transport in Clark County ........ 20.0.0 e eee cen eee

Total non-radiological truck fatalities, injuries, and accidents

resulting from SNF shipments .......... 00.6 c ccc eee eee eee eects

Estimated cumulative radiation exposure resulting from transport

of SNF and DOE radioactive waste in Clark County .............-. 2.00055

Cumulative radiological transportation risks resulting from transport of

SNF and DOE radioactive wastes in Clark County ............500 0 0c eeeee

1990 distribution (in percent) of racial and ethnic population groups

in Clark County, Nevada .......... 6. cece cc cece eee ett eee

Ethnic and racial groups (in percent) living within 0.5 mile (0.8 km)

of the transportation routes ....... 6... cece ect et eee

Fraction of persons along the transportation routes

who are in poverty (percent) ........ 6... cece ccc ee eee eee eens

-9

Vii NUREG- 1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

INCIDENT-FREE SUMMARY

INCIDENT-FREE POPULATION EXPOSURE IN PERSON-REM

PASSENGR CREW HANDLERS OFF LINK ON LINK STOPS STORAGE TOTALS
LINK 1 0.00E+00 8.46E+02 0.00E+00 1.19E+00 7.53E+01 1.07E+03 0.00E+00 1.99E+03
LINK 2 0.00E+00 3-18E+02 0.00E+00 4.64E+01 1.08E+02 5.28E+02 0.00E+00 1.00E+03
LINK 3 0.00E+00 2.53E+02 0.00E+00 4.16E+00 5.47E+02 5.28E+02 0.00E+00 1.33E+03

-46E+02 0.00E+00 1.19E+00 7.53E+01 1.07E+03 0.00E+00 1.99E+03
-18E+02 0.00E+00 4.64E+01 1.08E+02 5.28E+02 0.00E+00 1.00E+03
-53E+02 0.00E+00 4.16E+00 5.47E+02 5.28E+02 0.00E+00 1.33E+03

RURAL 0.00E+00
SUBURB 0.00E+00
URBAN 0.00E+00

P NWO

TOTALS: 0.00E+00 1.42E+03 0.00E+00 5.17E+01 7.31E+02 2.12E+03 0.00E+00 4.32E+03

MAXIMUM INDIVIDUAL IN-TRANSIT DOSE

LINK 1 2.69E-02 REM
LINK 2 2.69E-02 REM
LINK 3 2.69E-02 REM

A3-13 NUREG-1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

ECHO CHECK

&& Edited Mon Jun 21 15:51:08 1999
&& _South_route_via_beltway_without_rx_life_extension_
TITLE RADTRAN 4.0 INPUT

FORM UNIT

DIMEN 31 8 3 10 18

PARM 1 3 210

PACKAGE
LABGRP
SOLID GAS VOLATIL
SHIPMENT
LABISO
R51 MNS4 FESS FES9 Coss co60
KR85 SR89 SR90 yo ZR95 NB9S5
RU1O3 RULOG SB125 TE125M E127 TE127M
8134 cs137 cE141 CE144 PM147 EU154
PU238 PU239 PU240 PUu241 AM241 242
M244
NORMAL
NMODE=1
9.000E-01 5.O00B-02 5.000E-02 8.8495+01 4.025E+01 2.416E+01
4.000E+00 3.100E+00 0.000E+00 1.100E-02 1.000E+00 0.000E+00
0.000E+00 3.000E+01 2.000E+01 0.000E+00 1.000E+02 1.000B+02
2.000E+00 8.000E-02 5.000E-02 8.500E-01 4.700E+02 7.800E+02
2.800E+03
ACCIDENT
SEVFRC
NPOP=1
NMODE=1
4.62B-01 3.02E-01 1.76E-01 4.03E-02 1.18E-02 6.47E-03
5.71E-04 1.13E-04
NPOP=2
NMODE=1
4.35E-01 2.85E-01 2.215-01 5.06B-02 6.645-03 1.748-03
6.72E-05 5.93E-06
NPOP=3
NMODE=1
5.83E-01 3.82E-01 2.78E-02 6.36E-03 7.42E-04 1.46E-04
1.13E-05 9.94E-07
RELEASE
RFRAC
GROUP=1
0.00E+00 6.00E-08 2.00E-07 2.00E-06 2.00B-06 2.00E-06
2.00E-05 2.00E-05
GROUP=2
0.00E+00 9.90E-03 3.30E-02 3.90E-01 3.30E-01 3.30E-01
6.30E-01 6.30E-01
GROUP=3
0.00E+00 6.00E-06 2.00E-05 2.00E-04 2.00E-04 2.00B-04
2.00E-03 2.00E-03
EOF
ISOTOPES -1 50185 1.00 13.000 1.00 0.00 VEGASi
R51 7.40E-16 SOLID 2
MNS4 4. 80E+01 SOLID 2
FESS 3.82E+03 SOLID 2
FE5S9 3.84E-10 SOLID 2
058 3.67B-04 SOLID 2
O60 1.20E+04 SOLID 2
KR85 1.96E+04 GAS 10
SR89 1.42E-05 SOLID 2
SR90 2.20E+05 SOLID 2
Y91 5.81E-04 SOLID 2
2R95 1. 78E-04 SOLID 2
NB95 1.24E-02 SOLID 2
RU103 2.40B-08 VOLATIL 7
RUIO6 4.04E+04 VOLATIL 7
SB125 5.80E+03 SOLID 2
TE125M 1.63E+02 SOLID 2
TE127 2.09E-01 SOLID 2
TE127M 2.12E-01 SOLID 2
S134 1.098+05 VOLATIL 7
CS137 3.21405 VOLATIL 7
NUREG-1437, Addendum 1 A3-24




Supplemental Analyses for Cumulative Environmental Impacts. . .

have not been tested. It also assumes that these cask and truck systems will be available in
sufficient quantity for the shipments. The commentor seeks assurance that the assumed
truck cask system is feasible and that DOE’s proposed regional service contractor approach
would feasiblely result in the use of such a system for all shipments in the potential truck
shipment campaign.

Response: The analysis done by the NRC staff assumes that an adequate number of
certified casks would be available. Addendum 1 used extremely conservative assumptions
regarding SNF shipments and casks to ensure that the analysis would lead to maximum
dose estimates. For example, the analysis of incident-free transportation impacts assumes
the use of legal-weight trucks for shipment of the SNF, which results in more and smaller
shipments. For the accident analysis, the use of the largest-capacity casks was assumed in
order to maximize the amount of SNF that would be involved in the accident. These
parameters were intended to bound the parts of the analysis, not to describe parts of the
actual SNF shipment protocol such as the specific casks that will be used.

Comment: The analysis appears to assume that oldest spent nuclear fuel would be
shipped first to the repository. If so, how will institutional measures achieve this sequencing?
If they do not, how will the maximum potential radioactive risk in shipment and storage or
disposal be addressed?

Response: The spent fuel will be shipped in casks certified by the NRC. In fact, the
current practice of NRC issuing certificates of compliance for casks used for shipment of
power reactor fuel is to specify 5 years as the minimum cooling period in a certificate.

Comment: Addendum 1 uses national accident rate statistics. State and/or local rates
would be more appropriate.

Response: For the analysis of radiological accidents, data specific to Nevada were used
in the RADTRAN computer code runs. However, for the analysis of non-radiological
accidents, the NRC staff required data regarding not only accident rates but also injury and
fatality statistics. Those data were not available except from the U.S. Department of
Transportation.

Comment: Water resource supplies within boundaries of the State of Nevada belong to
the public. All waters are subject to appropriation for the beneficial use only under state law.

Response: The water resources of the state will be unaffected by the transport of SNF
through Clark County.

Comment: Report failed to provide conditions for informed consent which requires
disclosure to those affected, their understanding , and voluntary acceptance.

Response: NRC regulations already contain values that the NRC considers to be
acceptable environmental impacts from the shipment of SNF and other radioactive waste. In
Addendum 1 the NRC staff is, in part, ensuring that the overall impacts of the transportation
of the additional SNF that will be generated as the result of nuclear power plant license
renewal are bounded, given the best information the NRC staff has at this time, by those
values previously found acceptable. The values specified in the regulations are supported by
analysis and were adopted into the regulations only after providing opportunity for public

NUREG-1437, Addendum 1 Al-14


Supplemental Analyses for Cumulative Environmental Impacts. . .

Clark County

California

Figure A.2. Routes analyzed in this study. 1 = from the northeast through
downtown (I-15 to 95), 2 = from south through downtown (I-15 to 95), 3 = from the northeast
using the Beltway (I-15 to 1-215 to 95), 4 = from the south using the Beltway (I-15 to 1-215 to
95).

NUREG-1437, Addendum 1 10


Supplemental Analyses for Cumulative Environmental impacts. . .

Comment: There was insufficient consideration of routine transportation radiological risks
due to use of an average dose rate lower than the regulatory limit.

Response: The RADTRAN analysis reported in the final Addendum 1 has been modified
to use the most conservative assumption that the radiation levels for all shipments are at the
regulatory limit of 0.1 mSv/hour [10 mrem/hour] at 2 m [6.6 ft] from the shipment vehicle
surface. As noted in Section 2.2.3 of Addendum 1, this assumption is sufficiently
conservative to bound the analysis of routine transportation radiological risk and allow a
reasonable assessment of that risk. Actual average radiation levels and associated doses
would be much lower because shipments must be designed so that the regulatory limits are
not exceeded. The use of the regulatory limits in the revised analysis results in higher dose
estimates for incident-free transportation. However, these revised estimates are still small as
defined in 10 CFR Part 51, Subpart A, Appendix B. Consequently, the conclusion regarding
the radiological risks of routine transportation remains valid.

Comment: There was insufficient consideration of routine transportation radiological risks
to members of the public residing, working, or institutionally confined at locations near
shipping routes.

Response: The analysis encompasses members of the public residing, working, or
institutionally confined at locations near shipping routes by assuming that the resident
population along the transportation routes is exposed to every shipment. The text of
Sect. 2.3 of Addendum 1, has been revised to state this assumption and its effects on the
revised analysis more clearly. In addition, more conservative assumptions of truck speed
have been used in the revised RADTRAN analysis conservatively thus extending the
exposure time to individuals along the transportation route. These assumptions further
ensure that members of the public cited by the commentors would be encompassed by the
dose and risk assessments. As expected, the use of these more conservative assumptions
leads to higher estimates of radiation dose to the public. However, these revised dose
estimates remain well below regulatory limits for members of the public and small compared
to natural background and other sources of radiation exposure.

Several commentors indicated that Addendum 1 should focus on unique and location-
specific circumstances of the transportation routes and population centers. However, the
analysis in Addendum 1 is generic and was designed to support only the limited scope of the
decision regarding this rule change. The NRC believes that the routes chosen represent a
conservative analysis due to the higher number of people who live along these routes.
Because the purpose of this rule is to provide a generic analysis for the limited purpose of
determining the likely impact of transportation during the license renewal term, the large
analytical effort required for the identification of specific population locations and traffic
circumstances is not warranted within the context of the current rule. Although the
comments raise valid issues, those concerns should be resolved within the context of
studying, and making decisions concerning, the suitability of the candidate repository site at
Yucca Mountain and regulatory requirements governing transportation of spent fuel.

Comment: There was insufficient consideration of radiological risks resulting from traffic
gridlock incidents.

Response: Traffic gridlock incidents are not specifically analyzed in NUREG-1437
because of the limited scope and generic nature of the analysis (see response to comment
on consideration of risks to members of the public, above). However, the revised RADTRAN

Al-5S NUREG-1437, Addendum |


Supplemental Analyses for Cumulative Environmental Impacts. . .

ample protection of the public health and safety and the NRC reviews and approves the
selected routes.

The analysis in Addendum 1 shows that even with conservative assumptions, the
cumulative radiological and non-radiological accident risks of SNF transport in Clark County
are small. However, there are a number of opportunities to further reduce human health
impacts. These include transporting SNF by rail rather than by truck. This would reduce
human health effects by reducing the number of shipments and the likelihood of accidents.
In addition, shipping SNF via the proposed beltway would reduce health impacts compared
to shipping via the current interstate highway system. The implementation of such mitigative
measures must await future decisions that fall well outside of the scope of this rulemaking.
In addition, for the purposes of individual license renewal rule decisions, no plant specific
mitigation measures were found appropriate for addresses the impacts identified in the
Addendum. The NRC staff notes that DOE addresses transportation impacts, mitigation
measures, and alternative transportation modes in its EiS for the proposed repository at
Yucca Mountain.

Issue 6—Socioeconomics
Comment: NRC failed to consider socioeconomic impacts .

Response: Several commentors raised an issue of public perception of risk of waste
shipments and its effect on tourism and property values. Under the National Environmental
Policy Act (NEPA), the NRC is obligated to consider the effects on the physical environment
that could result from the proposed action. Effects that are not directly related to the physical
environment must have a reasonably close causal relationship to a change in the physical
environment. The Supreme Court ruling in Metropolitan Edison Co. v. People Against
Nuclear Energy, 460 U.S. 766 (1983) has narrowly circumscribed, if not entirely eliminated,
an agency’s NEPA obligation to consider impacts arising solely from the public’s perception
that an agency’s action has created risks of accidents. Accordingly, it is not necessary to
consider the impacts on tourism and property values from the public’s perception of risk.

The socioeconomic impacts of plant refurbishment and continued operation during the
renewal period are discussed in the plant-specific supplement to the GEIS for each individual
license renewal applicant. The NRC recognizes that there will likely be increased costs in
the unlikely event of an accident. However, for the majority of transportation accidents that
may occur, the associated costs are small. For the most severe accidents analyzed by the
RADTRAN computer code, the costs could be substantial. Given the low probability of such
accidents, the socioeconomic impacts of transportation of SNF do not alter the
Commission’s conclusions regarding the impacts of this issue.

Issue 7—Higher Burnup Fuel
Comment: There was insufficient consideration of extended fuel burnup issues.

Response: Section 3 of Addendum 1 addresses the issues associated with extended fuel
burnup in detail. The NRC staff's analysis of higher burnup fuel examined the issues of
radiation doses due to higher dose rates during shipment, higher radiation doses in the event
of transportation accidents, and the potential for a criticality in the very unlikely event that
high burnup fuel geometry is altered during a transportation accident.

Al-9 NUREG- 1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

CE1l41 2.71E-11 SOLID 2
CEI44 2.21B+04 SOLID 2
PM147 9.17B+04 SOLID 2
BU154 1.77E+04 SOLID 2
PU238 «1.72E+04 SOLID 2
PU239 -7.09E+02 SOLID 2
Pu2z40 1.32E+03 SOLID 2
Pu241 2.88E+05 SOLID 2
AM241 3.17E+03 SOLID 2
M242 1.14 +02 SOLID 2
M244 2.18E+04 SOLID 2

LINK 1 1.84E+02 8.80E+01 3.90E+00 4.70E+02 2.25E-07 R1
LINK 1 3.14E+01 4.Q0E+01 4.64E+02 7.80E+02 2.25E-07 S 1
LINK 1 1.50E+01 2.40H+01 2.53E+03 2.80E+03 3.60E-07 U 1
PKGSIZ

VEGAS1 5.00
EOF

NUREG-1437, Addendum 1 A3-12


Supplemental Analyses for Cumulative Environmental Impacts. . .

employed by the NRC staff to analyze the cumulative effects of SNF transport in the vicinity
of the proposed repository due to the renewal of a nuclear power plant operating license.
Section 2.3 presents the results of those analyses, Section 2.4 discusses impacts of
additional radioactive waste shipments, and Section 2.5 presents a summary of SNF
transport impacts. Finally, Section 2.6 examines the potential for environmental justice
issues related to radioactive waste transport in Clark County, Nevada.

2.1 BACKGROUND ON THE PROPOSED HLW REPOSITORY

The Nuclear Waste Policy Act of 1982 (NWPA) gave the U.S. Department of Energy the
responsibility for finding a site for disposal of commercial SNF and other high-level waste,
and for building and operating an underground disposal facility called a geologic repository.
In 1987, Congress amended the NWPA and directed DOE to study only Yucca Mountain,
Nevada, to decide whether it is suitable for a repository for high-level nuclear waste. Under
the NWPA, DOE has been studying Yucca Mountain for 15 years as a potential geologic
repository for the disposition of the nation’s spent nuclear fuel and high-level radioactive
waste. However, a number of decisions remain to be made before Yucca Mountain could
ever be considered for development of a repository; any one of these decisions can stop the
approval process. The Secretary of Energy plans to make a decision in 2001 on whether to
recommend the site to the President for development as a repository. If DOE finds the
Yucca Mountain site suitable and recommends the site, then the President must decide
whether to recommend the site to Congress. If the President recommends the site and if
Nevada submits a notice of disapproval, then Congress must decide whether to allow the
recommendation of the President to take effect. Only if the decisions remaining to be made
ultimately support development of a repository at Yucca Mountain, then DOE would submit a
license application to the NRC. If the repository is licensed, then SNF and HLW would be
shipped to the site using only NRC-certified transportation packages.

2.2 APPROACH TO ANALYSIS

The staff's overall approach was to use NRC’s current knowledge base and transportation
experience, to develop assumptions that reasonably estimate and bound the risks
associated with the increased number of spent fuel transports that might occur if license
renewal of nuclear power plants were to occur. These assumptions are generic in nature,
meaning they could be applied to any licensed nuclear power plant. The NRC staff made a
number of ‘conservative’ assumptions, which means that the assumptions would lead to an
overestimate of what the NRC staff believes to be the actual impacts. Examples of where
the NRC staff believes conservative assumptions have been used appear later in this
section. The goal is for the results to be used by a license renewal applicant as it would any
other Category 1 issue.

In accordance with the NWPA, DOE is required to prepare an environmental impact
statement (EIS) for Yucca Mountain. The EIS will consider the proposal to construct,
operate, and eventually, close a repository at Yucca Mountain. See DOE Notice of Intent (60
FR 40164). DOE is expected to assess national and regional (i.e., within the State of
Nevada) transportation options that cover the full range of operating conditions relevant to

5 NUREG- 1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

Response: During the preparation of Addendum 1, the initial study area selected for
analysis emphasized the urban areas in and near Las Vegas. Route selections were based
in part on their proximity to those areas, not to county borders. However, in response to
public comments, the study area was expanded to include the entire county. Consequently,
the “entry" point for SNF shipments shifted to cities such as Mesquite.

Comment: Addendum 1 should discuss potential mitigation measures, not rely on the
DOE Yucca Mountain EIS for that discussion.

Response: The analysis in Addendum 1 shows that, even with conservative
assumptions, the cumulative radiological and non-radiological accident risks of SNF
transport in Clark County are small. However, there are a number of opportunities to further
reduce human health impacts. These include transporting SNF by rail rather than by truck.
This would reduce human health effects by reducing the number of shipments and the
likelihood of accidents. In addition, shipping SNF via the proposed beltway would reduce
heaith impacts compared to shipping via the current interstate highway system. The
implementation of such mitigative measures must await future decisions that fall well outside
of the scope of this rulemaking. In addition, for the purposes of individual license renewal
rule decisions, no plant specific mitigation measures were found appropriate for addressing
the impacts identified in the Addendum. The NRC staff notes that DOE will addresses
transportation impacts, mitigation measures, and alternative transportation modes in its EIS
for the proposed action to develop a repository at Yucca Mountain.

Comment: Addendum 1 does not mention that the proposed repository which is the
destination for shipments of spent nuclear fuel is in Nye County.

Response: A statement noting that the proposed Yucca Mountain repository is in Nye
County has been added to Addendum 1.

Comment: No statements of baseline conditions are given in Addendum 1.

Response: Addendum 1 uses background and natural radiation levels as the baseline
conditions against which dose estimates can be compared. Both are presented in
Addendum 1 and are based in large part on information published by the National Council on
Radiation Protection and Measurements.

Comment: The analysis in Addendum 1 is limited to human health effects. Other
potential impacts should be considered.

Response: Addendum 1 was prepared to provide information regarding a proposed rule
to determine whether the transportation of higher enriched, higher burnup fuel to a single
destination is consistent with the values of Table S-4. Because the pertinent section of
Table S-4 concerns impact values for human health effects, Addendum 1 concentrates on
potential cumulative impacts to human health. However, Section 2.3 of Addendum 1 has
been revised to look at the potentially most significant non-human health effect which is the
potential increase in traffic volume in Clark County as the result of the transportation of SNF.
The NRC staff conclusion is that the impacts are small.

Comment: The analysis assumes the use of the large-capacity GA-4/9 truck cask, which
has not been certified and must be used in combination with specially designed trucks that

Al-13 NUREG- 1437, Addendum |




Supplemental Analyses for Cumulative Environmental Impacts. . .

PASSENGR
LINK 1 0.00E+00
LINK 2 0.00E+00
LINK 3 0.00E+00

RURAL 0.00E+00
SUBURB 0.00E+00
URBAN 0.00E+00

TOTALS: 0.00E+00

INCIDENT-FREE SUMMARY

INCIDENT-FREE POPULATION EXPOSURE IN PERSON-REM

1.27E+03 0.00E+00
3.49E+02 0.00E+00
3.09E+02 0.01

1.93E+03 0.0

CREW HANDLERS OFF LINK
1.27E+03 0.00E+00 1.74E+00
3.49E+02 0.00E+00 4.97E+01
3.09E+02 0.00E+00 5.04E+00

OE+00 5.65E+01

1.74E+00
4.97E+01
OE+00 5.04E+00

ON LINK STOPS

1.13E+02 1.608+03
1.19E+02 7.915+02
6.68E+02 7.91E+02

1.13E+02 1.60E+03
1.19E+02 7.91E+02
6.68E+02 7.91E+02

9.00E+02 3.18E+03

MAXIMUM INDIVIDUAL IN-TRANSIT DOSE

LINK 1 4.03E-02 REM
LINK 2 4.03E-02 REM
LINK 3 4.03E-02 REM

STORAGE

0.00E+00
0.00E+00
0.00E+00

0.00E+00
0.00E+00
0.00E+00

0.00E+00

EXPECTED VALUES OF POPULATION RISK IN PERSON-REM

GROUND
LINK 1 1.56E+01
LINK 2 2.35E+02
LINK 3 1.83E+02
RURAL 1.56E+01
SUBURB 2.35E+02
URBAN 1.83E+02
TOTALS: 4.34E+02

INHALED
2.37E-01
3.46E+00
2.35E+00

2.37E-01
3.46E+00
2.35E+00

6.05E+00

RESUSPD

6.68E-01
9.78E+00
6. 65E+00

6.68E-01
9.78E+00
6.65E+00

1.71E+01

CLOUDSH

7418-04
1.12B-02
7.46E-03

7.418-04
1.12E-02
7.46E-03

1.94E-02

* NOTE THAT INGESTION RISK IS A SOCIETAL RISK;
THE USER MAY WISH TO TREAT THIS VALUE SEPARATELY.

* INGESTION
0.00E+00
0.00E+00
0.00E+00

0.00E+00
0.00E+00
0.00E+00

0.00E+00

TOTAL

1.65E+01
2.49E+02
1.92E+02

1.65E+01
2.49E+02
1.92E+02

4.57E+02

TOTALS
2.99E+03
1.31E+03
1.77E+03

2.99E+03
1.31E+03
1.77E+03

6.07E+03

NUREG- 1437, Addendum |

A3-4


Supplemental Analyses for Cumulative Environmental Impacts. . .

The hypothetical maximally exposed individual would for incident-free transport receive

0.40 mSv [40 mrem] for the duration of shipments, about 0.16 percent of the average

70-year dose from background sources.'’ The maximally exposed individual radiation dose is
based on a hypothetical individual member of the public located in the open (i.e., without the
shielding offered by buildings or vehicles) 30 m [98 ft] from the highway during the entire
duration of shipments (a very conservative assumption). This dose is the estimated risk from
incident-free transport.

The above estimates of radiation dose are consistent with the doses reported in 10 CFR Part
51, Table S-4, Table S-4 reports estimates of 0.04 person-Sv [4 person-rem] per reactor
year for transportation workers, and 0.03 person-Sv [3 person-rem] per reactor year for the
general public. Assuming that 100 nuclear power plants operate for 60 years, Table S-4
leads to estimated occupational and general public doses of 240 person-Sv

[24,000 person-rem] and 180 person-Sv [18,000 person-rem] for transportation workers and
the general public, respectively. Comparing these dose estimates with the highest
corresponding doses in Table 3 shows that the estimated cumulative dose to the general
public from incident-free transportation of all SNF through the Las Vegas area is less than 25
percent of the cumulative dose from ail fuel and waste transportation calculated from

Table S-4. In light of the many conservative assumptions made in this analysis, the NRC
staff concludes that the radiological impacts of the shipment of SNF are small and are
acceptably addressed using the generic impacts methodology of Table S-4 for individual
nuclear power plant operating license renewal purposes.

2.3.2 Nonradiological Risks

The NRC staff assessed the impacts of nonradiological truck accidents that may occur

during the transport of SNF to the repository. A nonradiological accident is a truck accident in
which the property damage, injuries or fatalities are caused by the force of the impact; no
release of or exposure to radiological materials occurs as a result of the truck accident. Data
on national accident statistics have been compiled from a number of sources by the U.S.
Department of Transportation (DOT), Bureau of Transportation Statistics, between 1975 and
1995. Since 1990, data have been collected on the number of accidents, injuries, and
fatalities per 100 million truck-miles (DOT 1999). Based upon the accident rate data from
1990 to 1995, the average rate of large truck accidents is 145 per 100 million truck-km [233
per 100 million truck-miles], the average rate of injury is 13 per 100 million truck-km [21 per
100 million truck-miles], and the average fatality is 0.26 per 100 million truck-km [0.42 per
100 million truck-miles]. On the basis of these statistics—along with the HIGHWAY computer
code route data—the expected number of nonradiological accidents, injuries, and fatalities is
calculated as shown in Table 5 for shipments during the 40-year (without license renewal)
and 60-year (with license renewal) repository operations period. Over a 40- or 60-year

"' The background radiation dose is assumed to be 3.6 mSv/year [360 mrem/year], the current estimate
given for average background radiation dose in the U.S. The value is based upon the following assumptions
from the National Council on Radiation Protection and Measurements as summarized in Eisenbud and Gesell
(1997). Doses are given in mSv/year:

Cosmic radiation that reaches the earth at sea level 0.27
Radiation from the natural elements in the earth 0.28
Radon gas in the home from ground sources 2.00
Radiation in the human body from food and water 0.39
Average medical exposure 0.25 to 0.55
Consumer products (¢.g., smoke detectors) 0.10

19 NUREG-1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

ECHO CHECK

&& Edited Mon Jun 21 15:00:18 1999
&& _North_route_via_beltway_with_rx_life_extension_
TITLE RADTRAN 4.0 INPUT

FORM UNIT

DIMEN 31 8 3 10 18

PARM 13210
PACKAGE
LABGRP
SOLID
SHIPMENT
LABISO
cR51
KR85
RU1O3
cs134
PU238
M244
NORMAL
NMODE=1
-000E-01
-000E+00
-000E+00
-000E+00
-800E+03

9
4
0
2
2

4.62E-01
5.71E-04
NPOP=2

4.35E-01
6.72E-05

GAS VOLATIL

MN54 FESS.
SR89 SR90
RULO6 SB125
csi37 CE141
PUz39 Pu240

FES9
yo
TE125M
CE144
PU241

5.Q00E-02 5.000E-02 8.849E+01
3.100E+00 0.000E+00 1.100E-02
3.000E+01 2.000E+01 0.000E+00
8.O00E-02 5.000E-02 8.500E-01

3.02E-01 1.76E-01
1,13E-04

2.85E-01 2.21E-01
5.93E-06

3.82E-01 2.78E-02

1.13E-05 9.94E-07
RELEASE
RFRAC
GROUP=1
0.00E+00 6.00E-08 2.00E-07
2.00E-05 2.00E-05
GROUP=2
0.00E+00 9.90E-03 3.30E-02
6.30E-01 6.30E-01
GROUP=3
0.00E+00 6.00E-06 2.00E-05
2.00E-03 2.00E-03
EOF
ISOTOPES -1 75278 1.00 13.000
R51 7.40E-16 SOLID 2
MNS4 4.80E+01 SOLID 2
FESS 3.82E+03 SOLID 2
FES9 3.84E-10 SOLID 2
O58 3.67E-04 SOLID 2
C060 1.20E+04 SOLID 2
KR85 1.96E+04 GAS 10
SR89_ 1.42E-05 SOLID 2
SR90 2.20E+05 SOLID 2
Y91 5.81E-04 SOLID 2
2R95 1.78E-04 SOLID 2
NB95 1.24E-02 SOLID 2
RULO3 2.40E-08 VOLATIL 7
RU106 4.04E+04 VOLATIL 7
SB125 5.80E+03 SOLID 2
TEL25M 1.63E+02 SOLID 2
TE127 2.09E-01 SOLID 2
TE127M 2.12B-01 SOLID 2

Coss
ZR95
TE127
PM147
AM241

4.025E+01
1.000E+00
1.000E+02
4.700E+02

4.03E-02 1.18E-02 6.4

5.06E-02 6.64E-03 1.7

6.36E-03 7.42E-04 1.4

2.00E-06 2.00E-06 2.0!

3.90E-01 3.30E-01 3.3

2.00E-04 2.00E-04 2.0

1.00 0.00 VEGAS1

co60
NB9S
TE127
EU154
M242

2.416E+01
0.000E+00
1.000E+02
7. 800E+02

TE-03

4E-03

6E-04

OE-06

OE-O1

OE-04

NUREG- 1437, Addendum 1

A3-2


£-7V

| uinpusppy ‘Lev 1-OFYNN

Route 1 (continued).
RADTRAN Input Data Rural Suburban Urban

Weighted Population

People/sq. mi. 10.0 1200.4 6557.7
People/sq. km. 3.9 463.5 2531.9
Distance Total
Miles 114.2 19.5 9.3 143.0
Kilometers 183.8 31.4 15.0 230.1
Percentage 79.9 13.6 6.5
Basis (people/sq. mi.) <139 139-3326 >3326 Estimated 2020 Population

Note: Due to rounding, the sum of the mileage in the individual
population categories may not equal the total mileage shown
on this report.

Route 2, From I-15 south of Las Vegas through the spaghetti bowl.

HIGHWAY 3.4

FOIE ISOOI SISO IOISIIOIIISOSI ISOS DISSE IOS UOIIIUIIOISIOSI SGC SI IOS ISI OGIO III IG I

CANVI15 NIPTSLOA NV to MERCURY S U95 LOCL NV

JOOS SSIS UO SSIS IEEIISIISI IOI ISDS OSI USIISOTISIIDOSIGUEIISIIDIS ETI ISIE ISI SOI IGUIIO SII ISONIC III IDO

Leaving : 6/17/99 at 11:34 PDT Arriving: 6/17/99 at 13:18 PDT
Total Road Time: 1:45 Total Miles: 103.0

Route Type: C with 2 Driver(s) Time Bias: .70 Mile Bias: .30 Toll Bias: 1.00
The following constraints are in effect:

Route avoids links prohibiting truck use

Route avoids ferry crossings

Mileage by Highway Sign Type:
Interstate: 42.0 U.S.: 61.0 State: .0 Turnpike: 0
County: .0 Local: .0 Other: 0

Mileage by Highway Lane Type:

Limited Access Multilan 54.0 Limited Access Single Lane: +0
Multilane Divide: 49.0 Multilane Undivided: £0
Principal Highways: Through Highways: .O0 Other: .0

++ -szondiu] jUaMUONAUT aduDnUND 4of saskjouy joIUuauayddng


Supplemental Analyses for Cumulative Environmental Impacts. . .

at exactly the regulatory limit. Based on shipping experience, actual radiation levels are
expected to be lower than the regulatory limit level that was assumed in this analysis.

The NRC staff made the conservative assumption that the transport crew consists of four
people, two in the cab of the truck and two in an escort vehicle. The NRC staff assumed that
each of these persons would be exposed at the 0.02 mSv/hour (2 mrem/hour) regulatory limit
(found at 49 CFR 177.842) that applies in the cabs of motor vehicles. The people in the
vehicle would realistically be expected to receive substantially less dose than the escort
drivers because the occupants of the escort vehicle would be farther from the SNF package
than the drivers. The NRC staff also made the conservative assumption that the escort
vehicle and its two occupants would accompany the truck the entire time it was in Clark
County. This assumption results in the situation where the escort vehicle accompanies the
truck for a longer distance than required by NRC. Consequently, these assumptions lead to
an overestimate of the doses to the transport crew.

Table 1. Transportation route parameters for RADTRAN analysis

1990 population * Future population?
Roadway Average Average
population population population
density Distance density Distance density
zone® (km) (persons/km?) (km) (persons/km?)
Rural 217.6 1.9 183.6 3.8
From Suburban 1.3 89.8 23.0 453.3
northeast Urban 0.0 NA 12.2 2505.6
using
beltway Total? 218.9 218.9
Rural 204.5 1.7 183.8 3.9
From Suburban 14.3 604.6 31.4 463.5
northeast Urban 11.3 2,231.8 15.0 2531.9
through
downtown Total® 230.1 230.1
Rural 141.5 2.2 118.0 6.2
Suburban 15.4 431.8 25.1 371.2
From south Urban 8.9 2259.6 22.7 3210.3
through
downtown Total? 165.8 165.8
Rural 149.8 3.8 118.0 6.2
Suburban 24.8 342.9 33.2 491.3
From south Urban 2.6 1764.7 25.9 2498.0
using
beltway Total? 177.0 177.0

4Based on the HIGHWAY computer code analysis of 1990 Census data.

°Based on NRC staff estimate of future population densities along routes. The NRC staff used
these values in the RADTRAN computer code analyses.

“Rural” is defined as populations less than 54 persons/km? (140 persons/mi’). “Suburban” is
defined as population densities between 54 and 1,284 persons/km? (140 and 3325 persons/mi’).
“Urban” is defined as population densities greater than 1,284 persons/km? (3325 persons/mi?).

“Totals may not match sums of entries because of rounding.

NUREG-1437, Addendum 1 12


Supplemental Analyses for Cumulative Environmental Impacts. . .

appears feasible, it has not yet been approved by NRC. A totally new cask specifically
designed for hignh-burnup fuel is another possibility. It would only be conjecture to discuss the
results of such a cask design effort, but the modified cask basket described in Broadhead et
al. indicates that such a design could have little impact on the cask payload. Thus, for higher
burnup fuel that is allowed to coo! for at least five years before shipping, reasonable, cost-
effective measures can assure that radiation limits from SNF casks can be met without
increasing the number of SNF shipments. Consequently, the NRC staff concludes that use of
higher burnup fuel would not lead to incident-free transportation impacts that are larger than
those predicted by Table S-4.

To answer the question of how higher burnup fuel would affect accident doses, the NRC staff
used the characteristics of 5 percent enriched fuel that had been burned for

62,000 MWd/MTU in its RADTRAN analysis to estimate health risks associated with
accidents that release radioactive materials from a transportation cask (Table 2). The results
of the analysis (Tables 3 and 4) show that higher burnup fuel has doses and health risks that
are less than 15 percent of incident-free doses and health risks, and small as characterized
by Table S-4.

The NRC staff also examined unlikely accident scenarios involving higher burnup fuel to
determine if they could lead to a nuclear criticality event. The NRC staff examined two
scenarios: failure of fuel cladding and failure of a portion of the neutron absorption material
while the fuel remains in its original position. Because fuel rods are arranged in near
optimum configurations for establishing and maintaining nuclear fission reactions, if the fuel
cladding failed, the cask filled with water, and the fuel pellets crumbled into a pile or any
other arrangement, the fuel would be farther from criticality than while they were in their
original arrangement. Thus, failure of fuel cladding could not cause a criticality event.

The second hypothetical accident scenario has the neutron absorption effect at the end of
the cask basket somehow lost while the fuel lattice structure remains intact. In this scenario,
the fuel would remain in its optimum (for criticality) configuration, but the cask basket
material which absorbs neutrons is removed from 15 cm (6 in.) of the end of the fuel rods.
Analysis of several burnup levels showed that nuclear criticality would not occur, even if the
cask were filled with water. Consequently, the NRC staff concludes that higher burnup SNF
offers no greater criticality concerns, even in the event of unlikely occurrences.

3.3 CONCLUSIONS

Most nuclear plants are now operating with higher enriched fuel irradiated to higher burnup
levels than anticipated by the analyses that led to the impact levels identified in Table S-4.
The NRC staff has extensively studied the environmental impacts associated with fuel
enrichment up to 5 percent uranium-235 and fuel burnup to 60,000 MWd/MTU and has
found that these impacts are no greater than and likely less than the impacts described in 10
CFR 51.52(c), provided that higher burnup fuel has been removed from the reactor for at
least five years before it is shipped off site.

The analysis described above showed that higher enriched, higher burnup fuel would not
increase incident-free-transportation or transportation-accident impacts, and that criticality
could not occur during transportation of higher burnup SNF under any foreseeable
circumstance. The higher burnup levels are associated with uranium-235 enrichment levels.

29 NUREG-1437, Addendum |


Supplemental Analyses for Cumulative Environmental Impacts. . .

comment as part of the NRC's rulemaking process. As such, the NRC has followed all
applicable legal requirements and appropriately carried out its responsibility to consider the
environmental impacts of its license renewal decision.

Comment: The NRC staff uses “flawed” science as evidenced by factors including a
questionable definition of risk which fails to account for severe accidents, use of misleading if
not false average radiation dose rates, manipulation of dose rate data to obtain acceptable
results and lack of empirical data especially that applicable to transportation of SNF.

Response: The decision before the Commission is whether the impacts of license
renewal are so severe that they should preclude the option of license renewal. As such, the
Commission has considered a reasonable estimate of impacts and not included remote and
speculative scenarios that do not add to our regulatory decision (see also response to
comment on severe accidents, above).

In the analyses described in Addendum 1 the NRC staff uses dose rates that reflect the
applicable regulatory limit rather than average dose rates. Even with these very conservative
assumptions for dose rates, transportation modes, transportation routes, and a number of
other factors, radiation impacts on the transport crews and the general public were not only
found to be within all regulatory limits but small as well and there was no need to adjust the
assumptions.

Throughout Addendum 1 the NRC staff discusses the assumptions that were made and
where applicable the empirical data used to support those assumptions is referenced. With
respect to making judgements about the shipment of spent fuel the NRC staff has the benefit
of data from over 40 years of experience in shipping SNF in this country as well as overseas.

Comment: High level waste management and transportation should not be a generic
issue and Yucca Mountain should not be used for the study as DOE is behind schedule and
it is not an approved site for SNF.

Response: Given that the potential environmental impacts of the transportation of SNF
resulting from license renewal are similar for all nuclear power plants who seek to renew
their operating licenses, and that the NRC staff's analysis contained in Addendum 1
concludes that the impacts are likely to be small, the Commission feels it is appropriate to
reclassify the issue as a Category 1 issue. Use of Yucca Mountain, Nevada for purposes of
the staff's analysis, as the destination of the SNF is appropriate as it is the only site presently
under study. It must be emphasized that this generic environmental impact statement is
required to make use of the best information available and at this time the assumption that
Yucca Mountain is the destination is reasonable for purposes of the staff's analysis. If in the
future, conditions change, the assumption made for this analysis may need to be
reevaluated.

Comment: Need to consider the intermodal option being considered by Congress for
Caliente, Nevada.

Response: Rather than speculate on which transportation option or options will ultimately
be selected, the NRC staff has chosen a mode and routes to Yucca Mountain which in its
judgement will have the greatest potential environmental impacts in order to do a bounding
analysis for the purpose of this rulemaking.

AI-15 NUREG- 1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts...

Because doses fall off quickly with distance from the route, persons close to the route
receive and account for much more of the population dose than those who live some
distance from the route. The contributions to population doses from exposure to persons
living more than O.8 km [0.5 mile] from the route is negligible. Thus, the affected population
was assumed to be residents of and visitors to Clark County, Nevada within 0.8 km [0.5 mile}
of the route assumed to be followed by the trucks transporting SNF.

2.3 CUMULATIVE HEALTH RISKS OF SPENT FUEL TRANSPORTATION

Health risks associated with SNF transport include both those associated with radiation
exposure and the nonradiological risks associated with the assumed movement of trucks
carrying SNF through the Clark County, Nevada area (i.e., traffic accidents).

2.3.1 Radiological Risks

Radiation exposure can occur in two ways—exposure to radiation emitted by the SNF cask
during routine (incident-free) transport and exposures in the event of an accident that leads
to release of radioactive material. For incident-free transportation, the NRC staff used the
RADTRAN computer code to calculate total body doses to the transport crew and the
general public. The radiation source is characterized for the RADTRAN computer code by
the radiation dose rate at 1 m from the package surface.

Potential radiological accident effects include both acute fatalities resulting from very high
radiation exposure (that might occur in the unlikely event of failure of an SNF shipping
container or cask), and the LRFC resulting from radiation exposure that occur some time
after the postulated accident. Accident risk is estimated by summing the product of estimated
dose and the associated probability of occurrence for each of the accident-severity
categories analyzed by the RADTRAN computer code.

The cumulative radiation exposure estimated by the NRC staff is provided in Table 3. The
corresponding transportation health risks are provided in Table 4. Radiation doses to the
population and transport crews were converted to LRFC using the risk coefficient suggested
by the National Academy of Sciences (ICRP 1991; NAS 1990). It is important to note that
LRFC figures represent cumulative health risks to the entire population exposed to radiation
from the shipments. More simply put, the LRFC figures represent the additional number of
total potential fatalities assumed within the Clark County population due to the shipment of all
of the SNF over the entire life of the transportation campaign to the repository. Table 4
shows that, using the bounding assumptions for this study, between 2 and 3 excess fatal
cancers are predicted. The sum of incident-free and accident risks is 2.592 LRFC for the
southern route using the beltway; other scenarios have lower estimated risks. More simply
put, the LRFC figures represent the additional number of total potential fatalities assumed
within the Clark County population due to the shipment of all of the SNF over the entire life of
the transportation campaign to the repository. Table 4 shows that, using the bounding
assumptions for this study, between 2 and 3 excess fatal cancers are predicted. The sum of
incident-free and accident risks is 2.592 LRFC for the southern route using the beltway over
the entre life of the transportation campaign to the repository; other scenarios have lower
estimated risks.

15S NUREG- 1437, Addendum 1


Supplemental Analyses JOr Cumutanve Environmentat impacts. . .

CE141 2.71E-11 SOLID 2
CEl44 2.21E+04 SOLID 2
PM147 9.17B+04 SOLID 2
EUI54 1.77B+04 SOLID 2
PU238 1.72E+04 SOLID 2
PU239 7.09E+02 SOLID 2
PU2Z40 -1.32E+03 SOLID 2
PU2Z41 2.88E+05 SOLID 2
AM241  3.17E+03 SOLID 2
M242 1,14B+02 SOLID 2
M244 2,.18E+04 SOLID 2

LINK 1 1.18E+02 8.80E+01 6.20E+00 4.70E+02 2.25E-07 R 1
LINK 1 3.32E+01 4.O0E+01 4.91E+02 7.80E+02 2.25E-07 S$ 1
LINK 1 2.59E+01 2.40E+01 2.50E+03 2.80E+03 3.60E-07 U 1
PKGSIZ

VEGAS1 5.00
EOF

NUREG- 1437, Addendum 1 A3-22


Supplemental Analyses for Cumulative Environmental Impacts. . .

Jon C. Porter, Nevada State Senator

Kristin Shrader-Frechette, Professor, University of Notre Dame

Southern Company (Southern Nuclear Operating Company, Inc.)

State of Florida, Department of Community Affairs, (cover letter and six

comment forms from reviews coordinated by the Florida State Clearinghouse)

State of Nevada, Agency for Nuclear Projects (two submissions)

. State of Nevada, Department of Transportation. Submitted by the Nevada
State Clearinghouse

. State of Nevada, Division of Water Resources. Submitted by the Nevada
State Clearinghouse

. State of Utah (2 submissions). Comments submitted on behalf of the State by

Harmon, Curran, Spielberg and Eisenberg, LLP

Tennessee Valley Authority

TU Electric

Virginia Power

White Pine County, Nevada, Nuclear Waste Project Office (2 submissions)

Abigail Johnson, Yucca Mountain Information Office

eoeceee

RESPONSES TO COMMENTS

The written comments have been summarized and grouped into issue categories. As a
result of the NRC staff's review of all written comments, some modifications and clarifications
have been incorporated into Addendum 1—notably, the use of more conservative
assumptions in the analyses and a fuller explanation of those analyses. In addition, the rule
language has been edited for clarification. The NRC staff has also prepared responses,

given below, to the issues raised by the commentors.

Issue 1—Public Notice

Comment: The titles of the notices published in the Federal Register were inaccurate and
misleading because they do not clearly indicate the subject matter of the proposed rule and
Addendum 1 that addresses transportation of spent nuclear fuel.

Response: The NRC believes that the titles properly reflect the regulatory action being
taken. As required by NRC regulations,” a notice of the proposed rule and a Notice of
Availability of Addendum 1 were published in the Federal Register (64 FR 9884 and 64 FR
9889, February 26, 1999). While the notice’s title did not include the specific term
“transportation” the titles define the subject matter of the regulation to be affected; the title of
the proposed rule is “Changes to Requirements for Environmental Review for Renewal of
Nuclear Power Plant Operating Licenses.” The title of the Notice of Availability is “Changes
to Requirements for Environmental Review for Renewal of Nuclear Power Plant Operating
Licenses, Availability of Supplemental Environmental Impact Statement.” Addendum 1
supplements specific sections of NUREG-1437, Generic Environmental Impact Statement for
License Renewal of Nuclear Plants (May 1996). This limited function is indicated by the title
of Addendum 1, Generic Environmental Impact Statement for License Renewal of Nuclear

1710 CFR 2.804, “Notice of proposed rulemaking” and 10 CFR 51.117, “Draft environmental impact
statement-notice of availability.”

NUREG- 1437, Addendum 1 Al-2


Supplemental Analyses for Cumulative Environmental Impacts. . .

INCIDENT~FREE SUMMARY

INCIDENT-FREE POPULATION EXPOSURE IN PERSON-REM

PASSENGR CREW HANDLERS OFF LINK ON LINK STOPS STORAGE TOTALS
LINK 1 0.00E+00 8.14E+02 0.00E+00 1.82E+00 7.24E+01 1.03E+03 0.00E+00 1.92E+03
LINK 2 0.00E+00 3-81E+02 0.00E+00 4.44E+01 1.30E+02 7.91E+02 0.00E+00 1.35E+03
LINK 3 0.00E+00 5.74E+02 0.00E+00 1.20E+01 1.24E+03 7.91E+02 0.00E+00 2.62E+03

RURAL 0.00E+00 8.14E+02 0.00E+00 1.82E+00 7.24E+01 1.03E+03
SUBURB 0.00E+00 3.81E+02 0.00E+00 4.44E+01 1.30E+02 7.91E+02
URBAN 0.00E+00 5.74E+02 0.00E+00 1.20E+01 1.24E+03 7.91E+02

-00E+00 1.92E+03
-00E+00 1.35E+03
.00E+00 2.62E+03

20°

TOTALS: 0.00F+00 1.77E+03 0.00E+00 5.83E+01 1.44E+03 2.61E+03 0.00E+00 5.88E+03

MAXIMUM INDIVIDUAL IN-TRANSIT DOSE

LINK 1 4.03E-02 REM
LINK 2 4.03E-02 REM
LINK 3 4.03E-02 REM

EXPECTED VALUES OF POPULATION RISK IN PERSON-REM

GROUND INHALED RESUSPD CLOUDSH *INGESTION TOTAL
LINK 1 1.63E+01 2.47E-01 6.99E-01 7.75E-04 0.00E+00 1.73E+01
LINK 2 2.10E+02 3.09E+00 8.74E+00 1.00E-02 0.00E+00 2.22E+02
LINK 3 4.36E+02 5.60E+00 1.58E+01 1.78E-02 0.00E+00 4.58E+02

RURAL 1.63E+O1 2.47E-01 6.99E-01 7.75E-04 0.00E+00 1.73E+01
SUBURB 2.10E+02 3.09E+00 8.74E+00 1.00E-02 0.00E+00 2.22E+02
URBAN 4.36E+02 5.60E+00 1.58E+01 1.78E-02 0.00E+00 4.58E+02

TOTALS: 6.63E+02 8.94E+00 2.53E+01 2.85E-02 0.00E+00 6.97E+02

* NOTE THAT INGESTION RISK IS A SOCIETAL RISK;
HE USER MAY WISH TO TREAT THIS VALUE SEPARATELY.

A3-17 NUREG-1437, Addendum 1


[ winpusppy ‘Ler1-DFaNN

eV

Route 1. From I-15 northeast of Las Vegas through the spaghetti bowl.
HIGHWAY 3.4

AZNVI15 LITTOVER NV to MERCURY S$ U95 LOCL NV

JODOSIDSIS OUI SI IOUS OSIIOCIIOUIIOITIGCOIIOOIOIIUOIIOOSI IOI ISOBIISUISIO UIST IS SI SSIS EI ISG JOSI IGE UE IOC ITE ine

Leaving : 6/17/99 at 11:33 PDT Arriving: 6/17/99 ot 13:47 PDT
Total Road Time: 2:14 Total Miles:

Route Type: C with 2 Driver(s) Time Bias: .70 Mile Bias: .30 Toll Bias: 1.00
The following constraints are in effect:

Route avoids links prohibiting truck use

Route avoids ferry crossings

Mileage by Highway Sign Type:

Interstate: 82.0 ULS.: 61.0 State: .0 Turnpike: a)
Count: +0 Local: 0 Other: 20
Mileage by Highway Lane Type:
Limited Access Multilane: 94.0 Limited Access Single Lane: .0
Multilane Divided: 49 Multilane Undivided: +0
Principal Highways: 20 Through Highways: :0 Other: 20

State Mileage

NV 143.0
+0 AZNVI15 LITTOVER NV +0 0:00 6/17/99 at 11:33
82.0 I15 LAS VEGAS T15 I515 NV 82.0 1:08 6/17/99 at 12:41
61.0 U95 MERCURY Ss U95 LOCL NV 143.0 2:14 6/17/99 at 13:47
- MILEAGE WITHIN DENSITY LEVELS -
<0.0 5.0 22.7 59.7 139 326 822 1861 3326 5815

State Miles 0 -5.0 -22.7 -59.7 -139 -326 -821 -1861 -3326 ~5815 -9996 >9996

NV 143.0 31.6 44.5 27.2 73 3.6 4.8 4.8 4.9 5.0 5.6 2.2 1.5
Route
Total 143.0 31.6 44.5 27.2 13 3.6 4.8 4.8 4.9 5.0 5.6 2.2 1.5
Percentages

22.1 31.1 19.0 S.1 2.5 3.4 3.4 3.4 3.5 3.9 1.5 1.0
Basis: Estimated 2020 population

++ -sqaoduy pojuaumuonauq aaunjnuny sof sasxjouy joiuauajddng


Supplemental Analyses for Cumulative Environmental Impacts.

ECHO CHECK

28 1999

&& Edited Mon Jun 21 15:

&& _South_route_via_city_without_rx_life_extension_

TITLE RADTRAN INPUT
FORM UNIT
DIMEN 31 8 3 10 18

PARM 13210

PACKAGE
LABGRP
SOLID GAS VOLATIL
SHIPMENT
LABISO
R51 MN54 FESS FES9 cose C060
KR85 SR89 SR90 yo. ZR95 NB9S
RULO3 RU106 SB125 TE125M E127 TE127M
S134 ¢s137 CE141 CE144 PM147 EULS4
PU238 PUz39 PU240 Pu2d1 AM241 M242
cM244
NORMAL
NMODE=1
9.000E-01 5.O000E-02 5.000E-02 8.849E+01 4.025E+01 2.416E+01
4.000E+00 3.100E+00 0.000E+00 1.100E-02 1.000E+00 0.000E+00
0.000E+00 3.000E+01 2.000E+01 0.000E+00 1.000E+02 1.000E+02
2.000E+00 8.000E-02 5.000E-02 8.500E-01 4.700E+02 7.800E+02
2.800E+03
ACCIDENT
SEVFRC
NPOP=1
NMODE=1
4.62E-01 3.02E-01 1.76E-01 4.03E-02 1.18E-02 6.47E-03
5.71E-04 1.13E-04
4.35E-01 2.85E-01 2.21E-01 5.06E-02 6.64E-03 1.74E-03
6.72E-05 5.93E-06
NPOP=3
NMODE=1
5.83E-01 3.82E-01 2.78E-02 6.36E-03 7.42E-04 1.46E-04
1.13E-05 9,94E-07
RELEASE
RFRAC
GROUP=1
0.00E+00 6.00E-08 2.00E-07 2.00E-06 2.00E-06 2.00E-06
2.00E-05 2.00E-05
GROUP=2
0.00E+00 9.90E-03 3.30E-02 3.90E-01 3.30E-01 3.30E-01
6.30E-01 6.30E-01
GROUP=3
0.00E+00 6.00E-06 2.00E-05 2.00E-04 2.00E-04 2.00E-04
2.00E-03 2.00E-03
EOF
ISOTOPES ~-1 50185 1.00 13.000 1.00 0.00 VEGAS1
CR51 7.40E-16 SOLID 2
MNS4 4. 80E+02 SOLID 2
FES5 3.82E+03 SOLID 2
FES9 3.84E-10 SOLID 2
cO58 3.67E-04 SOLID 2
CO60 1.20E+04 SOLID 2
KR85 1.96E+04 GAS 10
SR89 1.42E-05 SOLID 2
SR9O0  2.20E+05 SOLID 2
Y91 5.815-04 SOLID 2
ZR95 1.78E-04 SOLID 2
NB95 1.24E-02 SOLID 2
RU1O3 2.40E-08 VOLATIL 7
RULO6 4,04E+04 VOLATIL 7
SB125 5.80E+03 SOLID 2
TEL25M 1.63E+02 SOLID 2
TE127 2.09E-01 SOLID 2
TE127M 2.12E-01 SOLID 2
S134 1.09E+05 VOLATIL 7
CS137 3.21E+05  VOLATIL 7
NUREG-1437, Addendum 1 A3-18


Supplemental Analyses for Cumulative Environmental Impacts. . .

of the scope of this rulemaking. DOE will address transportation impacts, mitigation
measures, and alternative transportation modes in its EIS for the proposed repository at
Yucca Mountain.

Table 6. Estimated cumulative radiation exposure resulting from transport
of SNF and DOE radioactive waste in Clark County?

Radiation exposure (person-Sv)’

Transport
Incident-free transport accidents
Crew* Public ? Public
Highest values from Table 3 21.3 43.7 B13
Doses from DOE HLW shipments 6.8 13.9 259
Doses from DOE LLW shipments 75.8 156.0 28.9
Doses from DOE SNF shipments 1.9 4.0 0.74
Maximum cumulative dose from all radioactive
waste shipments 84.0 218.0 40.3

* Transportation doses were calculated using the RADTRAN computer code( version 4.0.19.SI, dated
March 16, 1999). Access to the RADTRAN computer code was furnished on TRANSNET computer system by
the u . Department of Energy's Transportation Technology Center at Sandia National Laboratories.

1 person Sv = 100 person-rem.

° Transport crew size was assumed to be 4 persons (2 people in the truck and 2 people in the escort
vehicle). Crew dose is for the time spent driving In Clark County, approximately 166 to 230 km (approximately
100 to 145 miles); the dose involved in driving to Clark County is not included.

°The incident-free dose to the public does not include the dose to the crew.

Table 7. Cumulative radiological transportation risks resulting from transport of
SNF and DOE radioactive wastes in Clark County?

Estimated lifetime risk of fatal cancer?

incident-free risk Accident risk.

Crew? Public? Public
Highest values from Table 4 0.85 2.19 0.41
Risks from DOE HLW shipments 0.27 0.69 0.13,
Risks from DOE LLW shipments 3.0 7.8 15
Risks from DOE SNF shipments 0.8 0.2 0.09
Maximum cumulative risk from all radioactive
waste shipments 3.9 10.9 24

* Transportation risks were calculated using the RADTRAN computer code (v. 4.0.19.SI., dated March 16,
1999). Access to the RADTRAN computer code was furnished on TRANSNET computer system by the U.S.
Department of Energy's Transportation Technology Center at Sandia National Laboratories.

> For crew members, the dose conversion factor was 0.0004 estimated lifetime risk of fatal cancer (LRFC)
per person-rem, and for the public, 0.0005 LRFC per person-rem.

° Transpost crew size was assumed to be 4 persons (2 people in the truck and 2 people in the escort
vehicle). Crew dose is for the time spent driving in Clark County, approximately 166 to 230 km (approximately
100 to 145 miles); the dose involved in driving to Clark County is not included.

° The incident-free risk to the public does not include the risk to the crew.

23 NUREG-1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

CFR
cm
DOE
DOT
EIS

GEIS

HLW
in
km

LRFC

mrem
mSv
MTHM

MTU

NRC
NWPA
SNF
Sv

ACRONYMS AND ABBREVIATIONS

Code of Federal Regulations

centimeter

U.S. Department of Energy

U.S. Department of Transportation

environmental impact statement

Federal Register

foot

Generic Environmental Impact Statement for License Renewal
of Nuclear Plants (NUREG-1437)

high-level waste

inch

kilometer

pound

lifetime risk of fatal cancer

meter

millirem

millisievert

metric tons of heavy metal (a conventional unit for
high-level nuclear waste)

metric ton [i.e., 1000 kilograms (about 2200 pounds)]}

metric tons uranium

megawatt-days

U.S. Nuclear Regulatory Commission

Nuclear Waste Policy Act

spent nuclear fuel

sievert

ix NUREG- 1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

Also, the need for and scope of the current rule amendment were identified within the
context of a preceding rulemaking that specified the plant-specific content of the
environmental review of applications for the renewal of individual nuclear power plant
operating licenses. The previous final rule was published in the Federal Register first on
June 5, 1996 (61 FRR 28467), and again with minor modifications on December 18, 1996 (61
FR 66537). The Commission stated in the December Federal Register notice, “as part of its
efforts 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.”

Issue 3—Transportation Analysis

Comment: NRC failed to consult relevant Yucca Mountain transportation risk and impact
studies.

Response: The publications cited by commentors have been reviewed for information
that may be of direct use within the limited focus and purpose of the current rule. Most of the
information in these documents was found to be potentially more relevant to a detailed site-
specific review of Yucca Mountain than to the generic analysis for this rule. That information
has been brought to the attention of those organizational units within the NRC responsible
for activities relating to DOE’s study on the Yucca Mountain site so they can appropriately
consider the information in any future prelicensing activities involving Yucca Mountain.
Specific to the current rule, the demographic data used as inputs to the RADTRAN computer
code, which was used to generate the impact analysis in Addendum 1 were more current
than data used in many of the studies cited by the commentors.

Comment: NRC failed to consult the full spectrum of transportation mode and route
scenarios.

Response: The purpose of this rule and associated analysis is to reach conclusions
regarding the likely environmental impact of license renewal. As noted above, this
amendment is an addition to generic assessments of license renewal environmental impacts
already codified in the Commission's regulations at 10 CFR Part 51, Subpart A, Appendix B.
It is not an environmental impact statement for a repository at Yucca Mountain for which
DOE is responsible and, as such, does not delve into the expansive range of different
transportation modes and route scenarios that would be considered in the context of a
decision on Yucca Mountain as the possible site for the facility itself. Instead, the NRC has
sought to determine a conservative estimate of the likely impacts from transporting fuel and
waste generated, during the license renewal term, in the vicinity of a potential repository. In
doing so, the NRC considered only those transportation modes and route scenarios that
would likely result in the greatest impacts. For the proposed rule, the NRC staff—in
consultation with the DOE staff—determined that truck shipments through densely populated
areas of Clark County, Nevada, would have the highest potential impacts among the
alternative transportation scenarios and modes that would receive serious consideration in
decisions relating to the suitability of the site undergoing study for a repository at Yucca
Mountain. The NRC continues to believe that using these route scenarios and modes to
generate conservative estimates is reasonable for the purpose of this rulemaking.

NUREG- 1437, Addendum 1 Al-4




Supplemental Analyses Jor Cumulative Environmental Impacts. . .

5. REFERENCES

AIF/NE SP-032 1985. The Environmental Consequences of Higher Fuel Burnup, Atomic
Industrial Forum, Inc., June.

Broadhead, B. L., C. V. Parks, D. S. Joy, and J. S. Tang 1992. “Preliminary Assessment of
the Benefits of Derating A Cask for Increasing Age/Burnup Capability,” p. 2182 in
Proceedings of the Third International Conference on High Level Radioactive Waste
Management, Las Vegas, Nevada, April 12-16.

Clark County 1997. World Wide Web page: www.co.clark.nv.us/PUBWORKS/
beltway.htm, Clark County Department of Public Works, accessed Sep. 30, 1997.

DOE (U.S. Department of Energy) 1992. Characteristics of Potential Repository Wastes,
Office of Civilian Radioactive Waste Management, Washington, D.C.

DOE/RW-0472. Topical Report on Actinide-Only Burnup Credit for PWR Spent Nuclear Fuel
Packages, Revision 2, U. S. Department of Energy, September 1998.

DOE/EIS-200-F. Final Waste Management Programmatic Environmental Impact Statement
for Managing Treatment, Storage, and Disposal of Radioactive Waste. U.S. Department

of Energy, Office of Environmental Management, Washington, D.C., May 1997.

DOT (U.S. Department of Transportation) 1999. Table 3-22, Truck Occupancy Safety Data,
World Wide Web page: www.bts.gov/programs/ btsprod/nts/chp3/tbI3x22.html, accessed
June 26, 1999.

Dyer, G.J., and W.J. Reich, 1993. Transportation Risk Assessment for the Oak Ridge K-25
Site Mixed Waste Disposal Initiative, ES/ER/TM-68, Oak Ridge National Laboratory, Oak
Ridge, Tenn., April.

Eisenbud, M. and T. Gesell. 1997. Environmental Radioactivity from Natural, Industrial, and
Military Sources. Academic Press, New York, NY, February, IBSN: 0122351541.

GA 1991. General Atomics, Final Design Drawing Package GA-4 Legal Weight Truck Spent
Fuel Shipping Cask, General Atomics Project 3462, Oct.

ICRP (International Commission on Radiological Protection) 1991. 1990 Recommendations
of the International Commission on Radiological Protection, \CRP Publication 60, Annals
of the ICRP, vol. 21, No. 1-3, Pergamon Press, New York.

Institute of Medicine, Committee on Environmental Justice, Health Sciences Policy Program,
Health Sciences Section. 1999. Toward Environmental Justice—Research, Education,
and Health Policy Needs. Washington, DC. National Academy Press.

Johnson, P. E., D.S. Joy, D.B. Clarke, J.M. Jacobi 1993. HIGHWAY 3.1-An Enhanced
Highway Routing Model Program Description, Methodology, and Revised User's Manual,
ORNL/TM-12124, Oak Ridge National Laboratory, Oak Ridge, Tenn.

Joy, D.S., and P.E. Johnson 1983. HIGHWAY, A Transportation Routing Model: Program
Description and Revised User's Manual, ORNL/TM-8759, Oak Ridge National
Laboratory, Oak Ridge, Tenn.

NAS (National Academy of Sciences) 1990. Health Effects of Exposure to Low Levels of
lonizing Radiation, BEIR V Report, National Academy Press, Washington, D.C.

Neuhauser, K. S., Cashwell, J. W., Reardon, P. C., McNair, G. W. 1984. A Preliminary Cost
and Risk Analysis for Transporting Spent Fuel and High-Level Wastes to Candidate
SAND89-2370, Repository Sites, SAND84-1795, Sandia National Laboratories, Oct.

Neuhauser K. S., Kanipe, F. L 1992. RADTRAN 4: Volume 3, User Guide, SAND89-2370,
Sandia National Laboratories, Jan.

NUREG-1437, Addendum 1 32


Supplemental Analyses for Cumulative Environmental Impacts. . .

Arizona-Nevada border to the northeastern part of the Las Vegas metropolitan area and then
follows the planned I-215 across the northern portion of Las Vegas. In the northwestern part
of the Las Vegas metropolitan area, the route exits |-215 and continues northwest on U.S. 95
out of Clark County. The route named "from the south using the beltway“ follows |-15 from
the California-Nevada border to Las Vegas, near the southwestern comer of the McCarran
International Airport and then proceeds west and then north on 1-215. At the junction with
U.S. 95, the route leaves I-215 and proceeds northwest out of Clark County.

2.2.2 Analysis of Routes Using the HIGHWAY Model

The total travel distance, the fraction of travel in each population density zone, and the
average population density of each zone are necessary inputs to the RADTRAN computer
code. HIGHWAY computer code was run using 1990 census block group data, the latest
suitable data available. For each route segment, the HIGHWAY computer code uses the
characteristics and populations of the census block to assign the segment to one or more of
12 population density zones. For each route segment, the NRC staff reassigned the route
segment to higher population density categories in an attempt to represent future population
growth of Clark County. The routing data from the HIGHWAY computer code, which makes
use of 12 population density zones, were collapsed into 3 zones (i.e., rural, suburban, and
urban) to simplify the analysis performed by the RADTRAN computer code. The results of
the process are displayed in Table 1. The columns entitled “1990 population” display the
input that the RADTRAN computer code would have considered based on 1990 Census
data. The columns entitled “Future population” display the input that was considered using
the RADTRAN computer code analysis for this Addendum. The parameters in the “future
population” columns are based only on the staff's anticipation of substantial future population
growth. Given that SNF shipments would occur over perhaps 40 to 60 years beginning about
2010, forecasting of population densities and highway routes are more reasonable
assumptions than relying on the populations reported in the 1990 Census.

2.2.3 The RADTRAN Model

The RADTRAN computer code (Neuhauser 1984, 1992) was used to model the incident-free
radiological exposure and the probabilities and consequences of radiological releases
resulting from accidents. The incident-free risks are dependent on the radiation dose rate
from the shipment, number of shipments, package dimensions, route distance, vehicle
speed, and population densities along the travel routes. The accident risks are dependent on
the radiological inventory, accident severity, probability of occurrence for each accident
category, and the amount of inventory of radioactive material released, aerosolized, and
inhaled, as well as the dispersibility of the material based upon the chemical and physical
properties. Selected information considered by the NRC staff in using the RADTRAN
computer code is given in Appendix 3.

For incident-free transportation, the RADTRAN computer code calculates total body doses
for the transport crew and for the general public. The NRC staff assumed that the radiation
source is characterized for the analysis by the radiation dose rate at 1 m from the
transportation package surface. The regulatory limit found at 49 CFR 173.441 is

0.1 mSv/hour [10 mrem/hour] at 2 m [6.6 ft] from the outer lateral surfaces of the vehicle.
The NRC staff assumed 0.13 mSw/hour [13 mrem/hour] at 1 m [3.3 ft] rate because it
corresponds to 0.10 mSv/hour [10 mrem/hour] at 2 m [6.6 ft], the regulatory limit. This
analysis used the conservative assumption that for all shipments the radiation level would be

Il NUREG- 1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

potential impacts to human health and the environment.® In its response to public scoping
comments, DOE indicated that its draft EIS transportation analysis would include both truck
and rail transport, and use Department of Transportation routing regulations and
representative routes and actual route characteristics. Thus, DOE’s expected transportation
analyses will be detailed; however, DOE does not plan to complete its final EIS until 2000.
DOE recently issued its draft EIS for a 180-day public comment period beginning on August
13, 1999.

This analysis aims to address the cumulative impacts of SNF transportation to a HLW
repository from a generic perspective.’ Because Congress, at this time, has directed DOE to
study only Yucca Mountain for the proposed repository, the NRC staff began with the
assumption that all GNF would be transported through Clark County, Nevada (i.e., the Las
Vegas area) en route to the repository. This assumption is conservative in several ways.
First, current law would not allow more than 70,000 metric tons of heavy metal (MTHM), with
an estimated -63,000 MTHM of that total being from commercial SNF, to be disposed of at
Yucca Mountain. Nevertheless, the NRC staff used estimates of quantities of SNF that would
need to be disposed of that are considerably larger than the 63,000 MTHM for the purpose
of evaluating the entire inventory of SNF produced by nuclear power plants. Second, there
are other routes to Yucca Mountain rather than through Clark County, but none of the other
routes would encounter as high a population as found in Clark County. The NRC staff also
adopted this assumption because—whether Yucca Mountain or another site is selected for a
repository— estimates of transportation impacts are maximized in the case where all SNF is
transported through a major metropolitan area. The NRC staff believes it important to
emphasize that, while conservative, the assumption may not be at all representative or
realistic.

Transportation to Yucca Mountain or another repository site may make heavy use of rail
transportation, for example, because rail transport is expected to be less costly than truck
transport. The overall radiological impacts of rail as compared to highway shipments may be
lower. In part, this is because of the higher capacity of rail cars which allow fewer shipments
and because population densities along most rail routes are typically lower than along the
interstate highways that trucks would use to transport SNF. Additionally, when non-
radiological accident rates between truck and rail shipments are normalized for payload size
and mileage, the accident rate for rail shipments is about 3 percent of the comparable
accident rate for truck shipments (Dyer and Reich1993). Evaluation of cumulative impacts in
the vicinity of Las Vegas carried out in this analysis, therefore, represents an upper bound
because it assumes all SNF would move by legal-weight truck rather than by rail or by a
combination of rail and truck to reach the repository.® Further, to ensure that the impacts

® DOE’s Notice of Intent indicates that its analyses of impacts of regional transportation issues will include
(a) technical feasibility, (b) socioeconomic impacts, (c) land use and access impacts, and (d) impacts of
constructing and operating a rail spur, a heavy haul route, and/or a transfer facility. 60 FR 40168.

7 After DOE’s publication of the final EIS for Yucca Mountain, the Commission will consider whether the
information contained therein would be considered new and significant in the context of decisions related to the
renewal of nuclear power plant operating licenses such that some additional action may be required.

® The NRC staff did not consider conservative analyses that would be outside the reasonable range of
assumptions, e.g., routing shipments on indirect routes through densely populated areas. While the NRC staff
did make many conservative assumptions, consistent with U.S. Department of Transportation regulations for
highway route controlled quantities of nuclear materials (49 CFR 397.101 ), the NRC staff assumed that the

NUREG-1437, Addendum 1 6


Supplemental Analyses for Cumulative Environmental Impa€ts.. .

CONTENTS

ABSTRACT 0. 5 cece cece ee nee e eee e teen eee nett eee teens iii
LIST OF FIGURES ........ cece ccc eee cent ee eens os) Vii
LIST OF TABLES .............5- wees .. Vii
ACRONYMS AND ABBREVIATION .......... 0.00. c cece eee ee eee nett eens ix
4. INTRODUCTION ....... 0... eee eee ee tet ttn ee 1

1.1 PURPOSE OF THE ADDENDUM .. 4

1.2 SCOPE OF THE ADDENDUM .. 4

1.3 BACKGROUND ...... 0... eee ete ee 2
2. CUMULATIVE IMPACTS OF SPENT NUCLEAR FUEL

4.

5.

6.

TRANSPORTATION ........ 0020 e cece eee eee eee eet n eee eee
2.1 BACKGROUND ON THE PROPOSED HLW REPOSITORY ......... _
2.2 APPROACH TOANALYSIS ... 2.2.00. 6 0. e cece cee eee eee
2.2.1 Transportation and Route Scenarios ................000- 2008
2.2.2 Analysis of Routes Using the HIGHWAY Model .............. --
2.2.3 The RADTRAN Model .......... 0... cee cece eee eet eee
2.3 CUMULATIVE HEALTH RISKS OF SPENT FUEL TRANSPORTATION
IN CLARK COUNTY, NEVADA
2.3.1 Radiological Risks ......
2.3.2 Nonradiological Risks
2.4 CUMULATIVE IMPACTS OF ADDITIONAL RADIOACTIVE WASTE SHIPMENTS 21
2.5 SUMMARY OF SNF TRANSPORT IMPACTS ............-2-06 0s eeeeeeee 22
2.6 ENVIRONMENTAL JUSTICE .. 2.0... cee eee eters 24

. IMPLICATIONS OF HIGHER BURNUP FUEL FOR THE

CONCLUSIONS IN TABLE S-4 1.2... eee een ett eens 26

3.1 BACKGROUND ........ eee ee nett eee t eens 26
3.2 ANALYSES ... 0.00. cece cece eee tenet t eee ttte ees 27
3.3 CONCLUSIONS . 2.22.6... cece cence nent ene tt ene 29
SUMMARY AND CONCLUSIONS ..... 0.0.0... 0 eee cece eee ete eens 30
REFERENCES ...... 00... c eee cece ete een te eer ttee nee 32
LIST OF PREPARERS ......-. 2... cece eee eee tne eee 34

APPENDIX 1: STAFF RESPONSES TO PUBLIC COMMENTS ON ADDENDUM 1

AND THE PROPOSED RULE ......... 2.000 c cece tenet eee cette eee Al

APPENDIX 2: LISTINGS OF HIGHWAY ROUTES EXAMINED IN

THIS STUDY ...- 0.0 eee e cece cee neetet ete nett e ee ttnee ee A2

APPENDIX 3: SELECTED PAGES FROM THE RADTRAN 4

COMPUTER CODE RUNS ....... 0.6 cece cece eee eet tt eens AS

v NUREG- 1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

APPENDIX 3

SELECTED PAGES FROM THE RADTRAN 4
CompPuTER CopE RUNS

A3-1 NUREG- 1437, Addendum 1


Supplemental Analyses Jor Cumutative environmentat impacts. . .

To put this risk into perspective, the average incidence of lifetime fatal cancer in the U.S. is
about 0.25 [25 percent]. Assuming a Clark County population of about 1,600,000 and an
average life expectancy of 70 years, this lifetime incidence of fatal cancer would correspond
to about 5,700 LRF'C/year. Also, in the Clark County area, the average radiation exposures
resulting from cosmic and naturally occurring terrestrial gamma radiation are 0.75 to

0.77 mSv/year [75 to 77 mrem/year].'° Assuming a Clark County population of about
1,600,000 this natural radiation leads to a risk estimate of about 60 LRFC/year. The average
annual excess risk to the Clark County population from SNF transport is less than

0.050 LRFC/year which is a risk estimate of 1,200 times less than the estimate for
background radiation and more than 100,000 times less than the average incidence of fatal
cancer due to all causes.

The highest estimated risk to the crews is 0.852 LRFC. This already-small risk would be
spread over the 40- to 60-year period during which SNF would be transported to the
repository. On an annual basis, the crew risk averages about 0.014 LRFC per year of SNF
transport as a result of radiation exposures.

‘0 This outdoor dose rate estimate was provided by H. L. Beck (H. L. Beck, Director, Environmental
Sciences Division, Environmental Measurements Laboratory, U.S. Department of Energy, New York, personal
communication via electronic mail to A. K. Roecklein, NRC, Rockville, Maryland., Nov. 4, 1998) and based on
extensive background radiation measurements summarized, in part, in NCRP Report No. 94, Exposure of the
Population in the United States and Canada from Natural Background Radiation, National Council on Radiation
Protection and Measurements, Bethesda, Maryland., Dec. 30, 1987.

NUREG-1437, Addendum 1 16


Supplemental Analyses for Lumutanve Environmentat impacts. . .

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/M'TU). 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.

1.3 BACKGROUND

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.

NUREG-1437, Addendum | 2


Supplemental Analyses for Cumulative Environmental Impacts. . .

laws regulate and tax trucks operating in the state, the NRC staff believes that trucks
transporting SNF will not cause damage and repair costs that are incommensurate with the
taxes and fees the operators must pay.

Table 5. Total non-radiological truck fatalities, injuries, and accidents
resulting from SNF shipments *

Scenario Fatalities Injuries Accidents

From northeast using beltway 0.057 2.87 31.8
without license renewal

From northeast using beltway 0.086 4.30 47.7
with license renewal

From northeast through downtown 0.060 3.01 33.4
without license renewal

From northeast through downtown 0.090 4.52 50.2
with license renewal

From south using beltway 0.046 2.32 25.7
without license renewal

From south using beltway 0.070 3.48 38.6
with license renewal

From south through downtown 0.043 217 24.1
without license renewal

From south through downtown 0.065 3.26 36.2

with license renewal
Estimates are based on mileages from the HIGHWAY computer code, and on
accident, injury and fatality rates from DOT (1999).

2.4 CUMULATIVE IMPACTS OF ADDITIONAL RADIOACTIVE WASTE SHIPMENTS

In addition to SNF shipments to the proposed repository at Yucca Mountain, DOE is planning
to ship quantities of high level waste (HLW) to the repository and may also ship substantial
quantities of low-level radioactive wastes (LLW) to the Nevada Test Site (NTS) for disposal.
These shipments would most likely be routed through Clark County, in a manner similar to
the routing of SNF analyzed above. To estimate the potential cumulative effects of
shipments to the NTS as well as the proposed repository, the NRC staff utilized information
published in DOE’s waste management programmatic ElS (DOE/EIS-0200-F) and DOE’s
programmatic spent nuclear fuel management EIS (DOE/EIS-0203-F). To assure that
cumulative impacts are not underestimated, the NRC staff selected those alternatives in the
EIS that led to the highest numbers of shipments to the NTS or Yucca Mountain.

DOE estimated that there would be up to 24,000 HLW shipments” to Yucca Mountain and
up to 268,000 LLW shipments" to NTS, and up to 6,815 SNF shipments to NTS."* DOE
assumed that the HLW shipments would have radiation doses equal to the legal limit

This estimate comes from DOE/EIS-0200-F; Table 9.16-1, Centralized Alternative.

“This estimate is composed of 257,000 truck shipments of LLW to the Nevada Test Site and 11,000
shipments of low-level mixed waste (DOE/EIS-0200-F; Table 7.16-2, Centralized-2 Alternative and Table 6.16-2,
Regionalized-3 Alternative).

‘SThis estimate comes from DOE/EIS-0203-F, Table 1-2, for the Centralization at NTS alternative.

21 NUREG- 1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

INCIDENT-FREE SUMMARY

INCIDENT-FREE POPULATION EXPOSURE IN PERSON-REM

PASSENGR CREW HANDLERS OFF LINK ON LINK STOPS STORAGE TOTALS
LINK 1 0.00E+00 8.14E+02 0.00E+00 1.82E+00 7.24E+01 1.03E+03 0.00E+00 1.92E+03
LINK 2 0.00E+00 5.04E+02 0.00E+00 7.78E+01 1.72E+02 7.91E+02 0.00E+00 1.55E+03
LINK 3 0.00E+00 6.55H+02 0.00E+00 1.07E+01 1.42E+03 7.91E+02 0.00E+00 2.87E+03

-00E+00 1.82E+00 7.24E+01 1.03E+03 0.00E+00 1.92E+03
-00E+00 7.78E+01 1.72E+02 7.91E+02 0.00E+00 1.55E+03
-00E+00 1.07E+01 1.42E+03 7.91E+02 0.00E+00 2.87E+03

RURAL 0.00E+00 8.14E+02
SUBURB 0.00E+00 5.04E+02
URBAN 0.00E+00 6.55E+02

ooo

TOTALS: 0.00E+00 1.97E+03 0.00E+00 9.03E+01 1.66E+03 2.61E+03 0.00E+00 6.34E+03

MAXIMUM INDIVIDUAL IN-TRANSIT DOSE

LINK 1 4.03E-02 REM
LINK 2 4,03E-02 REM
LINK 3 4.03E-02 REM

EXPECTED VALUES OF POPULATION RISK IN PERSON-REM

GROUND INHALED RESUSPD CLOUDSH *INGESTION TOTAL
LINK 1 1.63E+01 2.47E-01 6.99E-01 7.75E-04 0.00E+00 1.73E+01
LINK 2 3.68E+02 5.41E+00 1.53E+01 1.75E-02 0.00E+00 3.89E+02
LINK 3 3.88E+02 4.97E+00 1.41E+01 1.58E-02 0.00B+00 4.07E+02

RURAL 1.63E+01 2.47E-01 6.99E-01 7.75E-04 0.00E+00 1.73E+01
SUBURB 3.68E+02 5.41E+00 1.53E+01 1.75E-02 0.00E+00 3.89E+02
URBAN 3.88E+02 4.97E+00 1.41E+01 1.58E-02 0.00E+00 4.07E+02

TOTALS: 7.72E+02 1.06E+01 3.00E+01 3.418-02 0.008+00 8.13E+02

* NOTE THAT INGESTION RISK IS A SOCIETAL RISK;
‘THE USER MAY WISH TO TREAT THIS VALUE SEPARATELY.

A3-23 NUREG- 1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts...

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.?

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’ 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

? 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 piant 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.

%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.

3 NUREG- 1437, Addendum 1


S-tV

| winpuoppy ‘Lev l-OaanN

Route 3. From I-15 northeast of Las Vegas using bypass.

HIGHWAY 3.4

TESS IS SEIS IOSD I JOSS SG SITIO OGG EIS SIDS IOS ISSO OPI ISU IOEIDISEISESIIEISIOEIEI IIE III III

AZNVI15 LITTOVER NV to MERCURY S$ U95 LOCL NV

JORSSISISIIIO IIS ISISIS SISSIES SIDS IO OSISISIISSSIIOISSSIISS EI ISSISTIT SEI ISS ISIOSII SECIS SII GEIS SIS IIE IO IIE

Leaving : 6/17/99 at 11:33 PDT Arriving: 6/17/99 at 13:38 PDT
Total Road Time: 2:06 Total Miles: 136.0

Route Type: C with 2 Driver(s) Time Bias: .70 Mile Bias: .30 Toll Bias: 1.00

The following constraints are in effect:
Route avoids links prohibiting truck use
Route avoids ferry crossings

Mileage by Highway Sign Type:
87. U.S.: 49.0 State: -0 Turnpike: +0
8 Local: +0 Other: +0

Mileage by Highway Lane Type:
Limited Access Multilane:
Multilane Divide

Principal Highways:

87.0 Limited Access Single Lane:
49.0 Multilane Undivide
Through Highways: .0 Other: +0

oo

State Mileage

-0 AZNVI15 LITTOVER NV 10 6/17/99 at 11:33
74.0 115 N LAS VEGAS NE 11S 1215 NV 74.0 6/17/99 at 12:33
13.0 1215 LAS VEGAS NW 1215 U95 NV 87.0 6/17/99 at 12:45
49.0 95 MERCURY Ss u95 LOCL NV 136.0 6/17/99 at 13:38
MILEAGE WITHIN DENSITY LEVELS ------~--------~----------------------
<0.0 5.0 22.7 59.7 139 326 e212 1861 3326 5815
State Miles i) -5.0 -22.7 -59.7 -139 -326 -821 ~1861 3326 ~5815 -9996 >9996
NV 136.0 31.6 44.5 27.2 7.3 3.5 4.3 3.1 3.1 3.8 4.7 1.7 1,2
Route
Total 136.0 31.6 44.5 27.2 7.3 3.5 4.3 3.1 3.1 3.8 4.7 1.7 1.2
Percentages

23 32.7 20.0 5.4 2.6 3.2 2.3 2.3 2.8 3.5 1.3 0.9
Basis: Estimated 2020 “Population

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Supplemental Analyses for Cumulative Environmental Impacts. . .

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CE144
PM147
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PU239
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VEGAS1

EOF

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3.21E+05
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9.17E+04
1.77E+04
1.72E+04
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1.32E+03
2.88E+05
3.17E+03
1.14E+02
2.18E+04

5.00

VOLATIL
VOLATIL
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SOLID
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SOLID
SOLID
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SOLID
SOLID
SOLID
SOLID

RRO VNNVNYNYNNNVG

1 1.84E+02 8.80E+01 3.80E+00 4.70E+02 2.25E-07
LINK 1 2.30E+01 4.00E+01 4.53E+02 7.80E+02 2.25E-07
1 1.22E+01 2.40E+01 2.51E+03 2.80E+03 3.60E-07

Ri.
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A3-3

NUREG- 1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

sets of highway segments or intersections contained in the data base, a feature the NRC
staff utilized to analyze the downtown routes.

The selection of preferred routes assumes that each shipment consists of highway-route-
controlled quantities of radioactive materials. Travel time is optimized based on maximum
utilization of the interstate highway system, with preference given to bypasses around major
cities, except where alternate routes have been designated by state officials. Selected
information considered by the NRC staff in using the HIGHWAY computer code is given in
Appendix 2. These inputs and outputs provide a detailed listing of each highway route as well
as mileage and population density zones considered in the analysis.

A beltway is being constructed in Clark County (Clark County 1997) which is expected to
consist of three connected segments including a southern, western, and northern route;
these segments will create a freeway “ring” around the Las Vegas Valley to route vehicles
around, rather than through, the congested urban core (Figure 1). The southern segment of
the beltway is being built in sections, with each segment opening to traffic upon completion.
The first phase of the project, from I-15 to McCarran Airport (Airport Connector), was opened
in 1994. The second section, from Warm Springs Road to Windmill Lane, opened to traffic in
Oct. 1995. In Feb. 1997, the third portion of the project— from Windmill Lane to Eastern
Ave.—became fully operational. The fourth section of the southern beltway, Eastern Ave. to
Pecos Road, was completed in 1997.

The proposed northern and western beltway is expected to be a 10-lane facility with
adequate right-of-way to permit construction of a fixed guideway facility (e.g., a commuter
rail line). This is called the “ultimate facility” and will require a right-of-way width of 107 to
137 m [350 to 450 ft], plus land for interchanges or access to other transportation facilities.

Because the beltway is expected to be complete before the repository begins operation and
because regulations require that spent fuel shipments use bypasses where possible,
analysis of transportation on the route through downtown on the current interstate system
yields higher exposure estimates than might actually occur. In addition, there are two
plausible routes into Clark County; from the south on I-15, and from the northeast on I-15.
SNF from western and southwestern states would likely arrive via the southern route. SNF
from eastern states would likely arrive via the northeastern route. To ensure that the
conclusions of this analysis are conservative, the NRC staff analyzed scenarios in which all
SNF arrived via the northeastern route and scenarios in which all SNF arrived via the
southern route. The combination of the northeastern and southern scenarios, and the
downtown and beltway scenarios gives four transportation route scenarios that were
analyzed by the NRC staff.

The NRC staff analyzed the potential impacts of SNF transport along the four routes
(illustrated in Figure 2). The route named “from the northeast through downtown” starts at
the Arizona-Nevada state line and follows I-15 to near downtown Las Vegas and then
proceeds northwest on U.S. 95 beyond the northwestern corner of Clark County, Nevada.
The route named “from the south through downtown” starts at the California-Nevada state
line and proceeds north on I-15 to near downtown Las Vegas and then proceeds northwest
on U.S. 95 through the northwestern portion of Clark County. The other routes are similar to
the first two except each route will use the 1-215 beltway that is currently planned and under
construction around the north, west, and southern portions of the Las Vegas metropolitan
area. The route named “from the northeast using the beltway” follows !-15 from the

NUREG-1437, Addendum 1 8


Supplemental Analyses for Cumulative Environmental Impacts. . .

In comments on the draft Addendum 1, the public expressed concerns about radiation doses
to truck inspectors at ports of entry and doses to the public during periods when the
highways are particularly congested. While there are a number of ways to reduce the
magnitude of such exposures, the NRC staff introduced two additional conservative
assumptions into the RADTRAN computer code analysis to account for these concerns.
First, the NRC staff assumed that the trucks would travel at lower speeds than is typical for
interstate highway travel; 55 mph in rural areas, 25 mph in suburban areas, and 15 mph in
urban areas. Second, the NRC staff assumed that the trucks made stops at a rate of

0.011 hours/km of travel. Because each truck traveled at least 165.8 km (104 mi), every
truck was assumed to stop for at least 1.8 hours (109 minutes). Further, the NRC staff
assumed that for the entire stop period, 30 members of the public were located 20 m

(66 feet) from the truck, and that all members of the transport crew continued to receive

2 mrem/hour during the stop. As a practical matter, the NRC staff believe that these
conditions would seldom be exceeded for an individual shipment, and that typical shipments
would move at normal highway speeds throughout the urban and suburban areas, and that
shorter, less frequent stops would be the norm.

Each truck shipment of multiple fuel assemblies was modeled as a single package with a
homogeneous distribution of the radiological inventory. Both point- and line-source
approximations were used based upon the distance between the exposed individuals and the
radiation source, The characteristic dimension (known in the RADTRAN computer code as
the variable PKGSIZ) is the largest linear dimension of the configuration and is used in the
line-source approximation to calculate total dose; 5 m [16.5 ft] was the assumed length of the
source. The radiation dose to the public from the casks was assumed to consist entirely of
gamma radiation for calculation of the incident-free dose. This assumption is appropriate
since the regulatory limits were used and the neutron and gamma radiation is attenuated at
nearly identical rates up to about 700 m (2,296 feet) (neutrons are attenuated more rapidly
beyond 700 m).

For releases of radioactive material resulting from postulated accidents, the RADTRAN
computer code uses a dispersibility category to determine the fractions of the total inventory
that are aerosolized and respirable. The analysis reflects the dispersibility category for each
isotope and considered the release fractions based on the type of package as a function of
accident severity.

Accident risks include acute fatalities and latent risk of fatal cancer (from chronic exposure)
for both the current and future generations. The accident risk (expected value of dose from
accidents) is the summation of the products of estimated dose for each accident severity
category and the associated probability of occurrence for the category. To provide a
conservative estimate of potential accident effects, the NRC staff assumed high bumup fuel
(62,000 MWd/MTU). Table 2 lists the characteristics of SNF assumed for the accident
analysis.

Radiation exposures are reported as collective dose to a population (person-Sv [person-
rem]) and the dose to the maximally exposed individual (mSv [mrem]). Health risks from
exposure to radiation are reported as estimated lifetime risk of fatal cancer (LRFC) resulting
from incident-free transportation of SNF and from highway accidents involving potential
radiation releases. Expected fatalities from truck accidents not involving radiation releases
are also reported.

13 NUREG-1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

cumulative impacts are not underestimated, the NRC staff selected alternatives in the EIS
that led to the highest numbers of shipments to the Nevada Test Site and Yucca Mountain.
The results of the analysis indicate that the cumulative doses and expected cancer fatalities
resulting from the civilian SNF and the DOE shipments are small compared to the risk of
cancer from other caauses.

Comment: Commentors stated that cumulative impacts along the Wasatch Front must be
considered.

Response: The State of Utah maintains that a study similar to the one conducted for Las
Vegas and Clark County must be conducted for the cumulative impacts along the Wasatch
Front that would originate from the proposed Private Fuel Storage Facility to be located at
Skull Valley, Utah. Such an analysis is beyond the scope of this generic rulemaking because
the Commission directed that cumulative impacts attributed to transportation be analyzed
only in the vicinity of Yucca Mountain. However, the NRC is currently reviewing a site-
specific application for construction and operation of the proposed Private Fuel Storage
Facility at Skull Valley in a separate regulatory action. A site-specific study of the cumulative
impacts of transportation is part of that review. The study will be reported in a draft
Environmental Impact Statement to be published for public comment. Its availability will be
noticed in the Federal Register.

tssue 5—Legal Requirements

Comment: NRC failed to conduct a legally sufficient risk assessment. Use of a model
such as RADTRAN is not in and of itself sufficient to meet the requirements of the National
Environmental Policy Act. The NRC must consider consequences of low-probability, high-
consequence accidents not included in RADTRAN, including unique local conditions,
unforeseen events, sabotage, and human error in cask design. The NRC should adopt the
comprehensive risk assessment approach for SNF and HLW transportation described in
Golding and White, Guidelines on the Scope, Content, and Use of Comprehensive Risk
Assessment in the Management of High-Level Nuclear Waste Transportation (1990).

Response: See the response above regarding consideration of severe accident risk (low
probability, high consequence accidents) during transportation.

The NRC's regulatory program will continue to ensure that the risk of severe
transportation accidents are minimized. Physical security for spent fuel transportation is
regulated under 10 CFR 73.37. The regulatory philosophy is designed to reduce the threat
potential to shipments and to facilitate response to incidents and recovery of packages that
might be diverted in transit. Although the analysis supporting the current rule does not
account for the potential for human error, activities related to the design, fabrication,
maintenance, and use of transportation packages are conducted under an NRC-approved
Quality Assurance Program. This helps to provide consistency in performance and helps
reduce the incidence of human error. While a location-specific transportation risk
assessment is included in the DOE EIS for the decisions relating to a possible Yucca
Mountain repository, the NRC staff believes that the analysis conducted for this rulemaking
provides an adequate consideration of the impacts from license renewal. Further, through its
regulatory, licensing, and certification functions, the NRC has tried to ensure that
transportation of SNF is performed safely with minimum risk to the public, and that vehicle
crashes while transporting SNF do not result in severe accidents. Similarly, DOE is expected
to ensure that the routes and procedures chosen for SNF transport to the repository provide

NUREG-1437, Addendum 1 Al1-8


NRC FORM 335 US. NUCLEAR REGULATORY COMMISSION [1. REPORT NUMBER

(2-89) (Assigned by NRC, Add Vol., Supp., Rev.,
NRCM 1102, and Addendum Numbers, if any.)
$204, 5202 BIBLIOGRAPHIC DATA SHEET
(See instructions on the )
} . —— NUREG-1437, Vol. 1,
2. TITLE AND SUBTITLE Addendum 1
Generic Environmental Impact Statement for License Renewal of Nuclear Plants
Main Report 3. DATE REPORT PUBLISHED
Section 6.3--Transportation | . MONTH | YEAR
Table 9.1 Summary of findings on NEPA issues for license renewal of nuclear power plants
Final Report August 1999
4, FIN OR GRANT NUMBER
'5, AUTHOR(S) 6. TYPE OF REPORT
i]
Regulatory

7. PERIOD COVERED (inclusive Dates)

8, PERFORMING ORGANIZATION - NAME AND ADDRESS (if NRC, provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing addless, # contractor,
provide name and mailing address.)
Division of Regulatory Improvement Programs
Office of Nuclear Reactor Regulation
U. S. Nuclear Regulatory Commission
Washington, D. C. 20555-0001

‘9, SPONSORING ORGANIZATION - NAME. AND ADDRESS (If NRC, type “Same as above’, if contractor, provide NRC Division, Office or Region, U.S. Nuclear Regulatory Commission,
and mailing address.)

Same as above

10. SUPPLEMENTARY NOTES

11, ABSTRACT (200 words or fess)

This addendum to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, documents
the staff's analysis of the potential cumulative impacts of transporting spent nuclear fuel in the vicinity of a single high-level
waste repository, and summarizes the staffs analyses undertaken to determine whether the environmental impacts of the
transportation of higher enrichment and higher burnup spent nuclear fue! are consistent with the values of 10 CFR 51.52,
Table S-4. The intent of the study is a generic analysis of the cumulative impacts associated with transportation of spent
nuclear fuel as a result of nuclear power plant license renewal. The results of the analysis will be used to amend 10 CFR Part
51.53 and Appendix B to Subpart A of 10 CFR Part 51, and is not intended to support any other regulatory decision by the
NRC. This addendum also includes an appendix that summarizes comments on the draft of the addendum, and documents the
staffs responses to those comments.

12. KEY WORDS/DESCRIPTORS (List words or phrases that wil assist researchers in locating the report.) TS. AVAIABLITY STATEMENT
Generic Environmental Impact Statement unlimited
License renewal 14. SECURITY CLASSIFICATION
Nuclear Power Plant ‘(This Page)
Environmental Protection 4
Spent Nuclear Fuel unclassified

(This Report)
unclassified
15. NUMBER OF PAGES
76. PRICE

NRG FORM 335 (2-89) This form was electronically produced by Elite Federal Forms, inc.


Supplemental Analyses for Cumulative Environmental Impacts. . .

Table 8. 1990 distribution (in percent) of racial and ethnic population groups

in Clark County, Nevada
American Indian & = Asian & Pacific
White Black Alaska native Islander
Non-Hispanic 75.4 9.3 0.7 3.3
Hispanic 5.9 0.3 0.1 0.2
Total 81.3 9.6 0.8 3.5

Source: U.S. Census Bureau, 1990. Database COOSTF1A, Summary Level State—County.
http//venus.census.gov/cdrom/lookup

Table 9. Ethnic and racial groups (in percent) living within
0.5 mile (0.8 km) of the transportation routes

American Indian & Asian & Pacific
White Black Alaska native Islander

From the northeast using beltway

Non-Hispanic 82.9 6.1 1.0 1.8
Hispanic 4.3 3.6 0.1 0.03
From the northeast through downtown

Non-Hispanic 61.7 25.2 0.7 2.2
Hispanic 48 0.4 0.1 0.2
From south using beltway

Non-Hispanic 88.6 2.7 0.7 2.2
Hispanic 41 0.06 0.04 0.06
From south through downtown

Non-Hispanic 77.5 9.2 0.7 28
Hispanic 5.4 0.2 0.1 0.2

Source: U.S. Bureau of the Census. 1990. U.S. Census Database C9O0STF1A, 1990.

The NRC staff also examined the distribution of low-income populations. The 1995 median
family income for Nevada families was estimated to be $36,300; Clark County was slightly
above the State average with a median family income of $38,184 (U.S. Census Bureau,
http:/Awww.census.govdgi-bin/hhes/saipe93/gettable.p1, Table C95-32; accessed June 23,
1999). The estimated number of persons living below the poverty level for 1989 in Clark
County was 76,737, representing approximately 10.4 percent of the total population (the
figures are based on 1990 Census data). Compared to the U.S. average, the State of
Nevada has been substantially below the national average in percentages of people living in
poverty. For 1995 through 1997, 13.6 percent of the U.S. population lived in poverty, while
10.1 percent of the residents in Nevada lived in poverty (Bureau of the Census 1999).

25 NUREG-1437, Addendum |


Supplemental Analyses for Cumulative Environmental Impacts. . .

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informational drawing, http:/www.co.clark.nv.us/PUBWORKS/gif/beltmap.jpg (accessed Oct. 14,

1997).

9 NUREG-1437, Addendum 1


Supplemental Analyses for Cumulative Environmental Impacts. . .

APPENDIX 2

LISTINGS OF HIGHWAY ROUTES EXAMINED IN THIS STUDY

The following listings of the routes examined for this study have been captured from the
HIGHWAY computer routing model developed at Oak Ridge National Laboratory (Joy and
Johnson 1983, Johnson et al.1993).

A2-1 NUREG- 1437, Addendum I




Supplemental Analyses for Cumulative Environmental Impacts. . .

CE141 2. 715-11 SOLID 2
CE144 2.215+04 SOLID 2
PM147 9.17E+04 SOLID 2
EUIS4 1. 77E+04 SOLID 2
PU238 «1. 72E+04 SOLID 2
PU239 7. O9E+02 SOLID 2
PU240 1.32E+03 SOLID 2
PU241 2.88E+05 SOLID 2
AM241 3. 17E+03 SOLID 2
M242 1. 14E+02 SOLID 2
M244 2.18E+04 SOLID 2

LINK 1 1.18E+02 8.80E+01 6.20E+00 4.70E+02 2.25E-07 R1
LINK 1 3.32E+01 4.00E+01 4.91E+02 7.80E+02 2.25E-07 S 1
LINK 1 2.59E+01 2.40E+01 2.50E+03 2.80E+03 3.60E-07 U1
PKGSIZ

VEGAS1 5.00

A3-25 NUREG-1437, Addendum 1


Supplemental Analyses Jor Cumulative Environmental Impacts. . .

of up to 5 percent by weight. An increase in burnup from 60,000 MWd/MTU to 62,000
MWd/MTU will not significantly change dose levels associated with spent fuel transportation
and may slightly reduce the number of shipments. Therefore, the impacts identified in Table
S-4 bound the transportation impacts of higher enriched, higher burnup SNF. These
conclusions are applicable to any nuclear power plant license renewal application provided
higher burnup fuel has cooled at least 5 years before it is shipped off the reactor site.

4. SUMMARY AND CONCLUSIONS

This Addendum to NUREG-1437, Generic Environmental Impact Statement for License
Renewal of Nuclear Plants, May 1996 supplements the analysis 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.” This document addresses two questions generically. 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 NRC staff
found that the cumulative impacts of SNF transport to a single repository are small for all
plants shipping spent fuel with characteristics specified in 10 CFR 51.52(c), Summary Table
S-4 and for spent fuel enriched up to 5 percent uranium-235 with average burnup for the
peak rod to current levels approved by NRC up to 62,000 MWd/MTU, provided higher
burnup fuel is cooled for at least 5 years before being shipped off site.

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. The NRC staff analyzed the extent to which transportation of higher
burnup SNF would cause impacts that exceed those identified in Table S-4 for incident-free
transport, and for hypothetical accidents causing release of radionuclides. The NRC staff
found that even under conservative higher burnup conditions, the impacts of SNF transport
would not exceed those identified in Table S-4. Consequently, the NRC staff concludes that
Table S-4 applies to spent fuel enriched up to 5 percent uranium-235 with average burnup
for the peak rod to current levels approved by NRC up to 62,000 MWd/MTU, provided higher
burnup fuel is cooled for at least 5 years before being shipped off site.

The conclusions reached in these assessments provide the bases for revising the findings
and the category designation of the Transportation issue in Table 9.1, “Summary of findings
on NEPA issues for license renewal of nuclear power plants,” of NUREG-1437. The
environmental impacts associated with these issues are applicable to all plants, the impacts
are small, mitigation has been considered, and additional plant -specific mitigation measures
are not warranted. The findings and category designation for the transportation issue
(NUREG-1437, p. 9-15) is revised as follows:

NUREG-1437, Addendum 1 30


Supplemental Analyses for Cumulative Environmental Impacts. . .

Nevada State Demographer. 1998. Official Nevada Estimate and Projections, Nevada
Population Projections by County 1998-2004, (Final 6/1/98).

Nouri, A. 1998. Analysis of Phase II-B Results: Conceptual PWR Spent Fuel Transportation
Cask, OECD-NEA/NSC/DOC(98)1 (IPSN/98-05), Institute de Protection et de Surete
Nucleaire, May.

Nuclear Waste Technical Review Board 1997. Spent Nuclear Fuel: Balance Storage and
Disposal Needs, URL: http://www.nwtrb.gov/issues/spntfuel.html, accessed Oct. 14,
1997.

NUREG/CR-2325. The Transportation of Radioactive Material (RAM) to and from U.S.
Nuclear Power Plants, Draft Environmental Assessment, SAND81-0118, U.S. Nuclear
Regulatory Commission, Dec. 1983.

NUREG/CR-5009. Assessment of the Use of Extended Burn up Fuel in Light Water Power
Reactors (PNL-6258), U.S. Nuclear Regulatory Commission, Feb. 1988

NUREG-1437. Generic Environmental Impact Statement for License Renewal of Nuclear
Plants, U.S. Nuclear Regulatory Commission, May 1996.

Parks, C. V., J. V. Pace Ill, and O. W. Hermann 1987. “Characterization of Neutron Sources
from Spent Fuel Casks,” Tran. Am. Nucl. Soc., 55, p. 534.

Parks, C. V., 1989. Criticality Analysis Support for the Three Mile Island Unit 2 Fuel Removal
Operations, Nuclear Technology, 87, pp. 660-678, November.

WASH-1238. Environmental Survey of Transportation of Radioactive Materials to and from
Nuclear Power Plants, U.S. Atomic Energy Commission, Dec. 1972.

Westfall, R. M., 1979. Criticality Analyses of Disrupted Core Models of Three Mile Island Unit
2, ORNL/CSD/TM-106, Oak Ridge National Laboratory, December.

Westfall, R. M., R. Q. Wright, and J. Greenborg 1990. “Status of a Standard for Neutron
Skyshine Calculation and Measurement,” Trans. Am. Nucl. Soc., 62, p. 432.

UNSCEAR (United Nations Scientific Committee on the Effects of Atomic Radiation) 1988.
Sources, Effects, and Risks of lonizing Radiation, United Nations.

U.S. Dept. of Commerce. 1996. USA Counties 1996 CD-ROM. Bureau of the Census.
Washington, D.C.

U.S. Dept. of Commerce. 1990. U.S. Census Database C9O0STF1A, 1990. Bureau of the
Census. Washington, D.C.

U.S. Dept. of Commerce, 1999. Estimated Median Household Income by County Nevada
1995. Small Area Income and Population Estimates Program, Bureau of the Census,
Washington, D.C. (Estimates released February 1999).

U.S. Dept. of Commerce. 1999. Percent of People in Poverty, by State. Bureau of the
Census. Washington, D.C.

33 NUREG- 1437, Addendum 1