# Appendix — Vermont Yankee Nuclear Power Corp. v. Natural Resources Defense Council, Inc.

> Briefs, arguments, decisions, and more.

URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385004_1660%3A05

## Record

- **Collection:** Supreme Court brief
- **Document type:** Appendix
- **Published:** January 1, 1978
- **Citation:** 435 U.S. 519

## Text

APPENDIX

VOLUME Il - RODAR, JR, CLERK |
Paces 401 - 1396

In THE

Supreme Court of the Anited States

Octrosper Term, 1976

No. 76-419

VERMONT YANKEE NUCLEAR POWER
CORPORATION,
Petitioner
v.

NATURAL RESOURCES DEFENSE COUNCIL,
INC., ET AL.,
Respondents

No. 76-528

CONSUMERS POWER COMPANY,
Petitioner
v.

NELSON AESCHLIMAN, et Au.,
Respondents

ON WRITS OF CERTIORARI TO THE UNITED STATES COURT OF
APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT

PETITIONS FOR WRITS OF CERTIORARI FILED
SEPTEMBER 21 AND OCTOBER 14, 1976
CERTIORARI GRANTED FEBRUARY 22, 1977

401

[SUMMARY OF APPLICATION

VERMONT YANKEE NUCLEAR POWER STATION
Ex. 3, pp. 2-5, AEC Dkt. No. 50-271]

SITE AND ENVIRONS

The site for the Vermont Yankee Nuclear Power Station
is located in the town of Vernon, Vermont in Windham
County on the west shore of the Connecticut River upstream
of the Vernon Hydroelectric Station. The site consists of
about 125 acres owned by the Vermont Yankee Nuclear
Power Corporation and a narrow strip of land owned by
New England Power Company and located between the
Connecticut River and the boundary of the Vermont Yankee
property and in which Vermont Yankee has perpetual
rights and easements granted by the New England Power
Company with the approval of the Federal Power Commis-
sion. The City of Brattleboro, Vermont is about five miles
upstream of the site. There are no residences on the site,
and the minimum distance from the reactor building to the
boundary of the exclusion zone, as defined in 10 CFR 100, is
910 feet. The nearest town with a population of 25,000 or
greater is Northampton, Massachusetts, about 30 miles to
the south. Much of the land around the site is undeveloped.
Most of the developed land is used for agriculture and dairy-
ing, with houses scattered or grouped in small villages. Ap-
pendix B appended hereto is a map showing the location of
the site with respect to adjacent areas (FSAR 2.2).

In July 1969 Vermont Yankee initiated a comprehensive
environmental radiation surveillance program designed to
monitor the atmospheric, terrestrial and aquatic environ-
ments in the vicinity of the station. This program was de-
veloped in cooperation with the Vermont State Department
of Health and reviewed by the Vermont Water Resources
Board.

402

It is Vermont Yankee’s intent that the environmental sur-
veillance program will be closely coordinated with condi-
tions of station operation by systematically correlating in-
formation developed through continuous in-plant monitor-
ing, effluent release records and environmental sample col-
lection and analysis. The primary purpose of the surveil-
lance program is to make station management and the State
Health Department aware of any conditions of station op-
eration which may have a significant effect on the environ-
ment. The operational surveillance program will be a

graded program subject to periodic critical review (FSAR
2.6).

Plant Design Bases Dependent Upon Plant Site
and Environs Characteristics

Information relating to the site and environs for the
Vermont Yankee Nuclear Power Station is presented in
Section 2 of the FSAR. The design features which were
dependent or affected by the site characteristics are sum-
_ marized below.

Condenser Off-Gas System

The condenser off-gases will be discharged to the atmos-
phere through deeay piping and a stack 308 feet above
grade. The off-gas system is used during normal operation.
It is expected that the release of gaseous radioactivity will
be kept within small fractions of the limits specified in 10
CFR 20 based on the use of the off-gas system. However,
to further minimize the release of gaseous radioactive
wastes, Vermont Yankee will modify the off-gas system to
provide additional holdup and subsequent decay of air
ejector off-gases. The design of this advanced off-gas sys-
tem is currently underway and fabrication and installation

403

will be completed by the end of the first refueling outage
(FSAR 9.4 and Appendix I).

Liquid Waste Effluents

Liquid effluents will be released from the radwaste dilu-
tion system at a point downstream of the aeration blocks in
the station discharge structure. The liquid waste treatment
system has been designed so that those liquid effluents
which are released from the station are always well within
the limits specified in 10 CFR 20. This is a batech-type sys-
tem wherein the wastes are separately collected and pro-
cessed based upon the most efficient methods, Batches of
liquid radwaste are sampled and analyzed prior to dis-
charge. If suitable for discharge, radwaste effluents are
released at a rate such that the resultant concentration at
the point of release will never exceed 10 CFR 20 nor the
applicable state release limit. During each release, a con-
tinuous radiation monitoring device is set to alarm upon
excessive activity concentration in the radwaste discharge
line. Diseharge records are maintained for all station
liquid radwaste effluents.

Wind Loading Design

Plant structures are designed to withstand the effects of
80 mph winds with gusts to 110 mph. Although the prob-
ability of a tornado occurring at the Vermont Yankee site
is small, all structures and equipment necessary to initiate
and maintain a safe plant shutdown are designed to with-
stand a tornado wind loading of 300 mph (FSAR 2.3 and

12.2

IHlydrology

The site is at mile 138.3 above the mouth of the Connecti-
eut River on the west bank on the pond formed by the

404

Vernon Dam and Ilydroelectriec Station. The maximum
recorded water level at Vernon was 231.4 feet mean sea
level which oceurred during the flood of March 19, 1936.
The minimum elevation of access openings to buildings
housing important equipment is. 252.5 feet mean sea level,
more than 20 feet above the maximum observed water level.
An analysis of water levels resulting from the probable
maximum flood, a postulated occurrence which is more
severe than the most significant historical event, has been
performed and shows that the station is suitably protected
against the maximum probable flood (FSAR 2.4 and Ap-
pendix IL).

Geology

The site area is overlaid by glacial deposits, with an
average of 30 feet of glacial overburden above the local
bedrock. Major structures of the station, including the
reactor building and turbine building, are supported on
rock. Seismic velocity measurements at the site verified
the hard massive nature of the bedrock and there were no
indications of deeply weathered or faulted zones (FSAR
2.5).

Seismic Design

The maximum acceleration at the bedrock surface of the
plant site from an earthquake is expected to be from 0.03g
to 0.04g. Although this acceleration is considered to be con-
servative, the seismic design for structures and equipment
important to safety are based on dynamic analyses using
acceleration response spectrum curves together with a
ground motion of 0.07g. The station is also designed so that
the plant can be shutdown in a safe and orderly manner
even if the ground acceleration were 0.14g (FSAR 2.5 and
12.2).

405
SUMMARY DESCRIPTION OF THE FACILITY

3.1 Lwrropuction

The nuclear steam supply system of the Vermont Yankee
Nuclear Power Station utilizes a General Electric boiling
water reactor identical in most design features to Monti-
cello Unit No. 1, the operation of which was recently author-
ized by the Atomie Energy Commission, The design of the
features of the Vermont Yankee facility is based upon
power technology attained during the development, design,
construction and operation of boiling water reactors of
similar types, including the Monticello facility. These fea-
tures include the basic fuel design, Zircaloy fuel cladding,
hydraulically operated control rods, in-core neutron moni-
toring instrumentation, pressure suppression containment
and radioactive waste control.

The following discussion summarizes the principal de-
sign features of the Vermont Yankee facility which are sig-
nificant to safety considerations. The FSAR and subse-
quent amendments present an extensive technical deserip-
tion and evaluation of this facility and FSAR references
elaborating on the discussion below are given in each sum-
mary. Appendix C of this testimony gives a comparison of
the significant station design features of Vermont Yankee
to other boiling water power reactor stations. A drawing
of a reactor and containment typical of the Vermont Yankee
plant is shown in Appendix D.

3.2 Reactor Primary System

The reactor is a single eyele, forced circulation, boiling
water reactor producing steam for direct use in the steam
turbine.

The fuel for the reactor core consists of slightly enriched
uranium dioxide pellets contained in sealed Zircaloy-2

406

tubes. These fuel rods are assembled into individual fuel
assemblies of 49 fuel rods each, Each complete core load-
ing consists of 368 fuel assemblies (FSAR 3.2),

Control of the reactor is achieved by movable control
rods. Reactor power level control is augmented by con-
trolling the recirculation flow rate through the reactor core.
The core is designed so that the reactor can be shutdown
from any point in its operating cycle by control rods alone,
Stored energy will be available from reactor pressure and
gas-charged accumulators to insert all control rods simul-
taneously for rapid shutdown of the reactor (FSAR 3.4).

In addition, there is provided a standby liquid control
system containing a boron neutron-absorbing solution which
is capable of shutting down the reactor and maintaining it
in a shutdown condition. This system is an independent
system that would be used to shutdown the reactor in the
unlikely event that shutdown cannot be accomplished with
the control rod system alone (FSAR 3.8).

The reactor pressure vessel contains the reactor core and
supporting structure, the steam separators and dryers, the
jet pumps, the control rod guide tubes, the feedwater and
core spray spargers and other components. The main con-
nections to the reactor vessel include the steam lines, reactor
coolant recirculation lines, feedwater lines, control rod drive
housings and other connections fortore cooling. Appendix
I. is a cut-away view typical of the reactor vessel and core
arrangement (FSAR 3.3).

Reactor Coolant will enter the reactor near the bottom of
the core and flow upward through the fuel assemblies. The
heat from the nuclear reaction will produce a mixture of
steam and water. The steam will be separated from the
water by means of steam separators and dryers located in
the upper portion of the reactor vessel, and will then pass

407

through steam lines to the turbine. The separated water
will mix with the incoming feedwater within the reactor
vessel and the total flow will be returned to the core inlet
through jet pumps located in the vessel. The motive force
for the jet pumps will be supplied by the water discharged
from two reactor coolant recirculation pumps. Variable
frequeney motor-generator sets supply power to the recir-
culation pump motors.

The design, fabrication, erection, testing, and certifica-
tion of the reactor pressure vessel are discussed in detail
in Amendment No. 13 to the license application (applica-
tion dated December 2, 1966, Docket No, 50-271).

The plant has removable insulation in specified areas
which permit direct inservice inspection of the exterior of
the reactor vessel and other primary system components.
This permits inspection of selected nozzle-to-shell welds,
inspection of reactor vessel studs, nuts and bushings, se-
lected sampling of high eyelie stress vessel welds. and
selected sampling of coolant system piping, pumps, valve
supports, and hangers. Inspection of the interior of the re-
actor vessel can be accomplished under water using re-
motely operable lights and visual aids such as boresecopes
and underwater TV cameras. (FSAR 4.2.6, 4.3.6, 4.4.8,
and Section 4.6 of the Vermont Yankee Technical Speei-
fications. )

3.3 Plant Containment System

The primary containment system, consisting of a steel
light-bulb-shaped drywell, a steel doughnut-shaped pressure
suppression chamber, and interconnecting vent pipes, pro-
vides the first containment barrier surrounding the reactor
vessel and reactor primary system. Any leakage from the
primary containment system is to the secondary contain-

408

ment system which consists of the reactor building, the plant
standby gas treatment system, and the plant main stack.
The integrated plant containment system and its associated
engineered safeguards features is designed so that off-site
doses resulting from postulated design basis accidents are
well below the reference values stated in 10 CFR 100,

3.3.1 Primary Containment System

The primary containment is designed to accomodate the
pressures and temperatures which would result from, or
occur subsequent, to, a failure equivalent to a double-ended,
circunferential rupture of a reactor coolant recirculation
system line within the primary containment resulting in
the loss of reactor water at the maximum rate. The pres-
sure suppression chamber is a steel, torus-shaped pressure
vessel approximately half filled with water, and... .

[USAEC STAFF SAFETY EVALUATION,
VERMONT YANKEE NUCLEAR POWER STATION,
Ex. 9, p. 5, AEC Dkt. No. 50-271)

. connected by vent pipes to the doughnut-shaped
steel water-filled suppression chamber (torus). The reactor
vessel and the recirculation water piping, valves and pumps
are housed in the drywell. The reactor is a direct-cycle,
foreed circulation, boiling water system which produces
steam at 1000 psig. The reactor core uses slightly enriched
uranium dioxide fuel in the form of pellets contained in
Zirealoy tubes. Water, which serves as both the moderator
and coolant, is pumped upward through the core where it
boils due to the heat produced in the core. Two recircula-
tion loops, each with a pump, provide the driving flow. The
resulting steam is supplied to the turbine, which is directly
coupled to the generator. After passing through the tur-
bine, the steam is condensed, partially reheated and re-
turned to the reactor.

409

SITE AND ENVIRONMENT
Site Description

The plant is located near the village of Vernon, Vermont,
slightiy less than four miles north of the Massachusetts
state line. It is on the west bank of the Vernon Pond. The
pond is formed behind the Vernon Hydroelectric Station
dam one-half mile downstream on the Connecticut River.
The west bank of the river forms the boundary between the
states of Vermont and New Hampshire flows in a south-
easterly direction in a narrow, steep-sided valley through
the Pisgah Mountains. The terrain rises steeply from the
valley floor in the vicinity of the plant and reaches the
same elevation as the plant stack at a point 6300 feet from
the plant. The site is bounded on the west by the village
and on the....

410

UNITED STATES OF AMERICA
ATOMIC ENERGY COMMISSION

IN THE MATTER OF

VERMONT YANKEE NUCLEAR Docket
POWER CORPORATION No. 50-271

(VERMONT YANKEE NucLEAR Power STaATIon)

ORDER DETERMINING OBJECTIONS
TO INTERROGATORIES

On April 30, 1971, Intervenor Natural Resources De-
fense Council (NRDC) submitted various interrogatories
to Vermont Yankee Nuclear Power Corporation, the Ap-
plicant herein. Objections to these interrogatories were
filed by the Applicant which emphasized the difference
between interrogatories and motions for production of
documents, as defined in the Federal Rules of Civil Pro-
cedure and as adapted by the Atomic Energy Commission
to its Rules for proceedings. Applicant, after stating its
general objection based upon this difference, then waived a
portion of its objection by agreeing to make requested docu-
mentary material available for inspection and copying by
the Intervenors.

The Atomie Safety and Licensing Board adheres to its
ruling respecting the general objection made by Applicant
to interrogatories submitted by New England Coalition on
Nuclear Pollution in its Order dated May 11, 1971, and
reasons therefor will not be repeated but are incorporated
as fully as though set forth herein.

et

411

Applicant, in addition to a general objection which is
sustained tothe extent of the Order respecting New Eng-
land Coalition on Nuclear Pollution interrogatories, also
made specific objections to two main categories of inter-
rogatories by NRDC which, however, were limited to one
subject respecting the transportation and disposal of high
level nuclear waste materials which will oceur after leay-
ing the plant site. The objection was upon the ground that
off-site activities respecting such waste materials were not
within the issues prescribed by the Commission for this
proceeding.

Upon a consideration of the interrogatories and objec-
tions thereto,

IT IS ORDERED, in accordance with the Atomic Energy
Act, as amended, and the Rules of Practice of the Commis-
sion, that the specific objection made by the Applicant
respecting the transportation and disposal of high level
waste products is sustained upon the ground that such
considerations are not within the issues prescribed by the
Commission for this proceeding, but rather are the sub-
jects for other licensing activities.

ATOMIC SAFETY AND LICENSING BOARD

By Samuei W. Jenscu, Chairman

Issued :
May 11, 1971
Germantown, Maryland

AEC Docket No. 50-271

APPLICANT’s ANSWERS TO

INTERROGATORIES OF

NaTuRAL Resources Derense CouNciL

SERVED ON

Vermont YANKEE NuCLEAR Power CorPoRATION

413

UNITED STATES OF AMERICA
ATOMIC ENERGY COMMISSION

IN THE MATTER OF

VERMONT YANKEE NUCLEAR Docket
POWER CORPORATION No, 50-271

(VERMONT YANKEE NUCLEAR POWER STATION )

AFFIDAVIT OF DONALD E. VANDENBURGH

Now comes Donald E. Vandenburgh, and being on oath,
deposes and says as follows:

1.

That he is a Vice President of Vermont Yankee Nu-
clear Power Corporation.

That attached hereto, are the answers to the inter-
rogatories propounded in the above entitled matter
to Vermont Yankee Nuclear Power Corporation by
Natural Resources Defense Council; and that there
is also attached certain “Supplementary Information
—IV Transportation: High Level Wastes from the
Plant” which should be considered as supplementing
the answers given with respect to Interrogatories
Nos. [V.1-6, [V.(DIS).2, 46.

That in the preparation of these answers, he has con-
sulted with the following individuals with regard to
the questions set forth next to their names below:

Name Numbers
R. M. Grube 1.1-7, V.1-18
R. J. Merlino IT.1-3, TV.1-22
IV(DIS) 1-8
W. P. Johnson IIT.1-9
J. W. Stacey IV(DIS) 9 and 10

414

4. That the answers attached hereto, are true and cor-
rect to the best of his knowledge and belief.

5. That on the advice of council and in view of the rul-
ings of the Board with respect to certain objections
sustained to the interrogatories, no answers are in-
cluded for questions 1.7 and IV.(DIS) 8.

DonaLp E. VanpENBURGH
DonaLtp FE. VanpENBURGH

COMMONWEALTH OF MASSACHUSETTS

Worcester, §.S. June 1, 1971

Then appeared before me, the above subscribed Donald
Kk. Vandenburgh and made oath that he is a Vice President
of Vermont Yankee Nuclear Power Corporation; that he is
authorized to subscribe to the answers of that corporation
to the interrogatories of the Natural Resources Defense
Council; that he has read the foregoing affidavit; and that
the statements set forth therein are true to the best of his
knowledge and belief.

Before me,

ArManpd R. Soucy
Armand R. Soucy — Notary Public
My Commission Expires September 9, 1977.

415

I. BASIC INFORMATION
QUESTION 1.1

How long is it expected that the Vermont Yankee plant
will run before being shut down for fuel reloading and
removal of high level wastes from the reactor core?

ANSWER IL.1

The first evele of plant operation is expected to run for
about 18 months before shutdown for refueling. At the
first shut down, about 4% of the fuel assemblies will be
removed and stored for reinsertion in a later cycle. At the
end of the second cycle of about 12 months, about 409% of
the fuel assemblies will be removed for shipment and re-
processing.

QUESTION 1.2

How often is it expected that refueling and removal of
high level wastes will be necessary?

ANSWER 1.2

For cycles subsequent to the second cycle, it is expected
that shutdowns for refueling and removal of spent fuel
assemblies will occur about every 12 months when about
25-30% of the assemblies will be removed.

QUESTION 1.3

Where will the high level wastes removed from the
reactor core be stored prior to their removal from the plant
site?

y
ANSWER 1.3

After removal from the reactor core, irradiated fuel as-
semblies will be stored in the spent fuel storage pool under
23 feet of water shielding. Spent fuel storage is described
in Section 10.3 of the VY FSAR.

416

QUESTION L4

llow long will the wastes be stored at the site before
they are removed?

ANSWER L4

Spent fuel assemblies are normally stored for a minimum
of 3 to 4 months prior to shipment to a reprocessing plant.
It is not expected they would be stored longer than a year
prior to shipment.

QUESTION 1.5

By what means of transportation will the wastes be taken
away from the plant? Lf this is expected to change during
the lifetime of the plant, describe each means and the period
over which it is expected to be used.

ANSWERS 1.5

The means of spent fuel transportation has not been
selected. VY facilities can accommodate both truck and
rail transportation. Any means of transportation will be
in compliance with government regulations. During the
lifetime of the plant, more than one means of transporta-
tion could be used.

QUESTION 16

lf the wastes are to be reprocessed, at what plant or
plants will this be done? If this is to change over the life
of the plant, specify the periods during which each re-
processing plant or plants is/are to be used.

ANSWER 16

It is planned that all VY spent fuel will be reprocessed.
A plant for reprocessing VY’s spent fuel assemblies has
not been selected. The following reprocessing plants are
now in operation, under construction, or planned for the

417

time period when the first batch of VY spent fuel will need
to be reprocessed.

1. The Nuclear Fuel Services, Inc. plant in operation,
at West Valley, New York.

2. The General Electric Co. plant under construction, at
Morris, Illinois.

3. The Allied-Gulf Nuclear Services plant, under con-
struction, at Barnwell, S.C.

4. The NUMEC Atlantic-Richfield plant, planned to be
located at Leeds, S.C,

Over the life of the VY plant, several different reprocess-
ing plants could be used.

QUESTION 1.7

If the wastes are to be reprocessed at a reprocessing

plant :

a.) Deseribe where the resulting reprocessed waste ma-
terials will be taken from the reprocessing plant. [n-
elude deseription of where reprocessed materials to be
disposed of are to be taken, and where any other
materials are to be taken. If this is expeeted to
change during the life of the plant, give this deserip-
tion for each relevant period.

b.) By what means of transportation will each segment
of the reprocessing wastes be taken to each of these
destinations? If this is to change over the period of
the plant’s life, specify the means during each phase
of the plant’s life.

ce.) Where will the waste products which must be disposed
of be taken? If this is to change during the life of the
plant, describe where the wastes are to be taken dur-
ing each phase of the plant’s life.

418

ANSWER 1.7

We are advised by legal council that in view of the
Board’s findings, no answer is required.

QUESTION. I1.1

Describe in detail the procedures to be used to remove
the radioactive materials from the reactor in order to
allow for refueling, including, but not limited to:

a.) How is the reactor core vessel to be opened and
processed to assure that no radioactivity escapes
from the containment vessel during this process?

b.) What is the chemical and radiological composition of
the materials which will be removed from the core at
that time?

ce.) What toxie chemical compounds will be present in this
process, in what quantities and proportions?

d.) What radioisotopes will be present in the material
removed from the reactor core at this time? List them,
including the quantity expected of each, the propor-
tion of the isotope to the total radioactive isotopes
present, the total amount of radioactivity represented
by each type of isotope (expressed in appropriate
nits), and the half-lives of each isotope.

ANSWER IL1

a.) The reactor is first shut down and cooled down. The
top of the primary containment vessel is removed to
expose the top of the reactor vessel. The bolted head
of the reactor vessel is removed and the area flooded
with about thirty feet of water. All subsequent opera-
tions are carried out under water. Core internals are
removed and stored under water. The spent fuel is
then removed and placed in special underwater storage
racks within the reactor building. New fuel is then

419

installed into the core and the previous steps are re-
versed to place the reactor in operation again.

Under normal conditions and operations, no radio-
activity will escape. The entire refueling area is sur-
rounded by the reactor building which is automatically
isolated should an incident oceur which results in the
release of any radioactive material. Section 14.6.4 of
the FSAR, discusses the postulated radioactive re-
lease in the event of a refueling accident.

b.) Entire sealed fuel assemblies are removed during

refueling. The chemical composition of the fuel is
basically unchanged, that is an oxide, which now con-
tains fission products which are listed in d.) below.

ce.) No processing takes place at Vermont Yankee and no

toxie chemical compounds are present.

d.) Attached are two lists which present the significant

radioisotopes one day after shutdown, which is the
earliest that fuel can possibly be moved. One list is
of fission products and the second is an estimate of
other significant radio-nuclides present in a single
spent fuel assembly. The normal refueling procedure
removes only about 4% of a core during each shut-
down (about 92 assemblies).

aonourt Sie =

BR83
BR84
BR85
BR&7
1129
I31A
131B
1132
1133
1134
1135
1136
KR3M
KR5M
KR85
KR87
KR88
KR89
XEIM
XK3M
XE33
XE5M
XE35
XE37
X38
SES81
SKh3M
SES3
SES4
RBSs
RBs9
RB90

420

VERMONT YANKEE
FISSION PRODUCT INVENTORY
1 Spent Fuel Assembly

1 Day Decay

HALF-LIFE CURIES AFTER
(SEC.) 1 DAY DECAY
0,829K 04 0.158E 02
0.198E 04 0,.278E-08
0.180K 03 0.000E 00
0.563K 02 0,000K 00
0.505E 15 0.433E—02
0.695E 06 0.896E 05
0.695E 06 0.126 05
0.828E 04 0.1351 06
0.755E 05 O.115E 06
0.315E 04 0.895 E-02
0.241E 05 0.197 05
0.840E 02 0.000E 00
0.686 04 0.685E 02
0.158E 05 0.114KE 04
0.3346 09 0.167 04
0.468E 04 0.270E 00
0.100E 05 0.356K 03
0.192E 03 0.000E 00
0.108E 07 0.6441 03
0.198K 06 0.559K 04
0.459 06 0.244E 06
0.935E 03 O.59RE 04
0.326K 05 0.293KE 04
0,234E 03 0.000K 00
O.101K 04 0.689 E-20
O.108K 04 0,134E-19
0.6726 02 0.000E 00
O.150K 04 0.387 K-13
O.119K 038 0.000E 00
0.108E 04 0.401E 03
0.900E 03 0.290E-23
O.161E 03 0.000E 00

0.361 E-05
0.635B-15
0.000E 00
0.000E 00
0.990E-09
0.204E-01
0,290 K-02
0,309 K-01
0.264E-01
0.204K-08
0.451K-02
0.000E 00
0.156K-04
0.260E-03
0.383 E-03
0.617 E-07
0813-04
0,000 00
0147-03
0.127K-02
0.559K-01
0.136102
0.671 E-03
0,000E 00
0.157 6-26
0.307 E-26
0.000E 00
0.886 K-20
0,000E 00
0.916E-04
0.663 E-30
0.000E 00

51

53

NUMBER ISOTOPE

RB91
RB92
SR89
SR9IO
SR91
SR92
SRI
SR94
Y90
Y9IM
Yo
Y92
Y93
Y94
Y95
ZR95
ZR97
NBOM
NB95
NB7M
NB97
MO99
M001
MO02
M005
TCOM
TOOL
TC2A
TC2B
TCOS
RUO3
RUO5
RU06
RUOT
RHSM
RH5M
RHO5
RELO6
RIH07

0.840E
0.800 E
0.441E
0.8841
0,350K
0.972E
0.420K
O.119K
0,.230K
0.300
0.529K
0.129K
0.359E
0.990E
0.630K
0.563K
0.613K
0.3231
0.302K
0.597
0.44418
0.244
0.900K
0.6931
0.1191
0.215K
0.8578
0.498
0.2691
0.597K
0.3445
0.161K
0.315K
0.287
0.341E
0.450K
0.1268
0.300E
O.131E

CURIES AFTER
1 DAY DECAY
0.231 K-25
0.000K 00
OAT9K 06
O.145K 05
0.4056 05
0.430E 03
0.000K 00
0.000K 00
0.1458 05
0.2566 05
0.223K 06
0.743E 04
0.444E 05
0.125K-20
0.000K 00
0.2346 06
0.848E 05
O.457K 04
0.2441
0.8346
0,929K
0.184

ESSS

0.477 K-32
0.000K 00
O75 06
0.502 6-22
0.480K-32
0.781 K-32
0.000E 00
O112K 06
O.883K 03
0.128 05
0,000K 00
O112K 06
0.853E 03
0.227K 05
0.1296 05
O0.169B-15

0.528E-32
0.000E 00
0.409 E-01
0.332 B02
0.926602
0.982K-04
0,.000E 00
0,000 00
0.332 6-02
0.586 6-02
0.511B-01
0.16902
0.101E-01
0.28727
0,000K 00
0.5385K-01
0.193E-01
0.104602
0.558E-01
0.190KE-01
0,.212K-01
0.421K-01
0.558E-30
0.0001 00
0,000E 00
0.401K-01
0.114K-28
0,000E 00
0.178E-—38
0,000K 00
0.257K-01
0.201 K-08
0.292 E-02
0,000K 00
0.257E-01
0.194E-03
0.521 K-02
0,.295E-02
0,388 6-22

91

5)
7
"9
101
102
103

105

107

110

SN27
SN28
SN30
SB27
SB28
SB29
SB30
SB31
SB32
SB33
TE7M
TETA
TE7B
TE9M
TERIA
TE9B
TEIM
TEIA
TEIB
TH32
TE3M
TE33
TEH34
CS37
CS38
CS39
CS40
CS42
BATM
BA39
BA40
BA4I
BA42
LA40
LA41
LA42
LA43
CE41
CE43

422

HALF-LIFE
(SEC.)
O.741E 04
0.341 04
O.156E 03
O.319K 06
0.597TE 03
O.151E 05
0.597E 03
0.138E 04
0.126E 03
0.245E 03
0.907E 07
0.338E 05
O.341E 05
0.285F 07
O.372E 04
0.372E 04
0.103E 06
0.150E 04
0.150E 04
0.280E 06
0.378KE 04
0.120E 03
0.263E 04
0.946E 09
0.192E 04
0.568E 03
0.660E 02
0.597E 02
0.156E 03
0.509K 04
O.110K 07
O.107E 04
0.660E 03
0.144E 06
0.136E 05
0.509E 04
O.114E 04
0.276E 07
O.11SE 06

CURIES AFTER
1 DAY DECAY

0.130E 01
0.340E-03
0.000E 00
0.443E 04
0.111 B-04
0.729E 03
0.15602
0.164E-13
0,000E 00
0.000F 00
0.133E 04
0.380E 04
0.797E 03
0.131KF 05
0.532E 03
0.130E 05
0.954E 04
0.469E-11
0.217E 04
0.131E 06
0.254E-01
0.128E-01
0.359E-04
0.144E 05
0.118E-07
0.000E 00
0.000F 00
0.000F 00
0.135E 05
0.217E 01
0.227E 06
0.189E-18
0.000E 00
0.239E 06
0.316E 04
0.199E 01
0.352E-17
0.228E 06
O.137E 06

0.297 E-06
0.779 E-.0
0.000E 00
0.101 E-02
0.255E-11
0.166 E-03
0.357 E-09
0.376E-20
0.000E 00
0.000E 00
0.304 E-03
0.870 E-03
0.182E-03
0.300 E-02
0.121E-03
0.299E-02
0.218E-02
0.107E-17
0.496 E-03
0.300E-01
0.580E-08
0.293E-08
0.821E-11
0.331 E-02
0.270E-14
0.000E 00
0.000E 00
0.000E 00
0.309 E—02
0.498 E-06
0.520E-01
0.432E-25
0.000E 00
0.547E-01
0.722 E-03
0.456E-06
0.804E-24
0.523E-01
0.314E-01

111 CE44
112 CE45
113 CE46
114 PR43
115 PR44
116 PR45
117 PR46
118 ND47
119 ND49
120 ND51
121 PM47
122 PM49
123 PM51
124 SM51
125 SM53

ISOTOPE
U-235
U-238
Pu-239
Pu-240
Pu-241

423

HALF-LIFE
(SEC.)

0.246E 08
0.180E 0°
0.840E 03
0.120E 07
0.105E 04
0.215E 05
O.144E 04
0.100E 07
O.719E O04
0.900E 03
0.794E 08
0.194E 06
0.100E 06
0.230E 10
0.169E 06

1 DAY DECAY

0.187E 06
0.000E 00
0.121E-25
0.222E 06
0.187E 06
0.937E 04
0.241 E-12
O.787E 05
0.966E O01
0.205 E-24
0.342E 05
0.302E 05
0.913E 04
0.110E 02
0.423E 04

TOTAL = 0.4375E 07

VERMONT YANKEE
Other Significant Radionuclides In
1 Spent Fuel Assembly

HALF LIFE
(Yrs)

7.1 X 10°
4.51 X 10°
2.44

5
Al
Bre .| =
aa
i :
L_

FROM FLOOR DRAINS, ETC.—————__——>

COOLING WATER

—

_—

‘Gaeta toe
i :
TOWERS !
|
eR J

atiaow
Fig. I-15. Schematic of Vermont Yankee Nuclear Power Station Liquid Radioactive Waste System.

SLUDGE, FILTER, CAKE, AND SPENT RESINS WILL BE DRUMMED FOR

STORAGE AND/OR BURIAL AS SOLID RADIOACTIVE WASTES.

NOTE 1:

527

The floor drain system collects liquid wastes from floor
drain sumps which are estimated to be 2000 gpd from the
reactor building floor drain sump, 1000 gpd from the radio-
active waste building floor drain sump, 2000 gpd from the
turbine building floor drain sump (all at a radioactivity of
1% of the primary coolant), and 3000 gpd from the drywell
floor drain sump (at the activity of the primary coolant).
These liquids are processed through a filter to the floor
drain sample tank, sampled, and released if the activity is
low in comparison to applicable regulations. If the radio-
activity content of the sample tank is such that a discharge
limit would be approached, the waste can be held in the
tank for a period of time to allow radioactivity reduction
through decay. If this delayed release is not practical be-
cause of the volumes of waste being generated, or because
the radionuclides are long lived, then the liquid in the
sample tank will be pumped through the equipment drain
system filter and demineralizer to the waste sample tank
for analysis. This waste may not be of sufficient chemical
purity to allow reuse within the reactor system. In this
case, the waste sample tank contents would be diluted and
discharged. The anticipated releases shown in Table III-1
are based on processing all liquid wastes from the floor
drains through the equipment drain system (with a decon-
tamination factor of 100) and releasing them.

Chemical wastes collect in the chemical waste tank. Sub-
sequent treatment is dependent upon the results of analysis
to determine chemical purity of the liquid. When this
shows that the waste ean be chemically neutralized suffici-
ently to allow treatment as a low purity waste, the contents
of the chemical waste tank will be directed, after neutraliza-
tion, to the floor drain collector tank for treatment as low
purity wastes as described above. If the chemical nature
or radioactivity content precludes treatment as low purity

528

waste, this liquid may be pumped into drums, mixed with
water-adsorbent material to remove free water and handled
as a solid waste. Detergent wastes are collected in the de-
contamination solution tank where they are sampled for
radioactivity content. These wastes will then be filtered,
diluted, and discharged. Table ITI-1 includes the calculated
releases from these sources.

b. Gaseous Wastes

During power operation of the Station, radioactive ma-
terials released to the atmosphere in gaseous effluents in-
clude fission product noble gases (krypton and xenon) ;
activated argon and nitrogen; halogens (mostly iodines) ;
tritium contained in water vapor; and particulate material
including both fission products and activated corrosion
products. Fission products will be released to the coolant
and carried to the turbine by the steam if defects occur in
the fuel clad or if uranium is present as an impurity in, or
on, the clad itself.

TABLE ItIl-1

Annual Release of Radioactive Material in Liquid Effluent
from Vermont Yankee Nuclear Power Station (100% Power)

Nuclide | Ci/year Nuclide Ci/year
8Sr 0.45 | ss9y 0.042
Sr 0.029 | 18a] 0.14
“Sr 0.00044 ||: 188] 0.00018
wy 0.10 | NC 0.25
vimy 0.028 | 18s 0.078
ny 0,22 | 13Cg 0.19
sy 0.0044 =| 8™Ba 0.036
Zr 0.0047 =| “Ba 0.65
"Zr 0.000079 | La 0.5
%Nb 0.0048 MiCe 0.0050
vmNb 0.000076 || Ce 0.00055
“Nb 0.0000079 || “Ce 0.0082
” 0.095 usp 0.0040
cose 0.001 || ups 0.0082
18 Ru 0.0034 “Nd 0.0016
Ru 0.0011 Cr 0.040
10m™Rh 0.0034 “Mn 0.0035
1O6Rh 0.000383 55Fe 0.18
6Rh 0.0011 Fe 0.0066
121m'Te 0.00097 - || "Co 0.42
127Te 0.0010 Co 0.044
120m Te 0.0091 VAN 0.000088
129Te 0.0058 60mZ 0.000021
i31mTe 0.0010 isTW 0.016
181Te 0.00019 || “Na 0.0021
182Te 0.040 32p 0.0015
130] 0.000096 Total Vb

ist] 1.2 D8 I “20

—- — — ———— - a _—-

530

The major source of gaseous waste activity during nor-
mal Station operation will be the off-gas from the steam
condenser air ejectors. Other sources include primary con-
tainment purge, the gland seal off-gas system and the reac-
tor building, raidoactive waste building, and the turbine
building exhaust systems. Figure III-16 is a schematic of
these systems.

Prior to release, the off-gases from the main condenser
air ejectors will be delayed for a minimum of 30 min in a
holdup pipe (to allow decay of activity of short-lived radio-
active noble gases) and filtered through high efficiency par-
ticulate filters and charcoal adsorbers. Release will be
through the main station 318-ft-high stack.

The reactor building exhaust system removes air from
the reactor building ventilation system and from the drywell
and torus purge exhaust system. This air, which normally
contains low concentrations of activity, is discharged to the
main station stack. The system is so arranged that the
exhaust air can be directed to the standby gas treatment
system (high efficiency particulate filters and charcoal ad-
sorbers in series) for release through the main station stack
if the activity level is high. The primary containment (dry-
well) is normally a sealed volume. However, during pe-
riods of refueling, maintenance, or whenever primary con-
tainment access is required, the potential exists for the re-
lease of airborne radioactivity to the environment. In such
cases, air is removed through the drywell and torus purge
system (prefilters and high efficiency particulate filters)
and discharged to the reactor building vent stack.

The turbine building exhaust system which is expected
to contain low concentrations of activity, primarily from
steam system leakage, draws air from the turbine building
and is discharged to the atmosphere through the main sta-
tion stack which is continuously monitored.

531

The steam/air exhaust from the turbine sealing system
passes through a gland seal condenser where the steam is
condensed and the non-condensables are exhausted to the
gland seal holdup line. The small quantity of radioactive
gases released by way of the gland seal off-gas system is
delayed for about 2 min to allow decay of the major activa-
tion gases ('®N and QO) prior to release through the main
station stack. All sources of gaseous wastes are continu-
ously monitored to assure that effluent releases are within
applicable standards.

On the basis of operating experience with reactors of
similar design, it is expected that the off-gas system de-
scribed above will keep releases of gaseous radioactive
wastes well within the limit specified in 10 CFR 20. In
order to reduce these levels to the lowest level practicable
during extended power operation, the applicant plans to
install additional gaseous holdup equipment. A modifica-
tion to the present system will provide recombination of the
hydrogen and oxygen formed in the reactor coolant, a con-
denser to remove much of the water vapor, and a charcoal
delay system to provide additional retention time for kryp-
ton and xenon and to provide additional adsorption of
iodines and particulates. The modified system is expected
to be operational by the time of the first refueling. The
staff anticipates that the proposed modification will result
in a reduction of off-gas activity (curies of noble gases)
released by a factor of at least 20 relative to a 30-min
holdup system and that ‘I from all gaseous sources will
he reduced to less than 0.6 Ci/year.

On the basis of experience at other operating plants, gas-
eous activity releases for Vermont Yankee are estimated at
3,000,000 Ci/year, prior to the installation of the modified
treatment system. However, based on commitments made
in the Technical Specifications to the operating license, the

533

actual effluents will be administratively controlled to an
annual average rate of 22,000 »Ci/see or about 700,000
Ci/yr. The expected distribution is shown in Table ITI-2.

ce. Solid Radwaste

Since both the condensate and reactor water cleanup sys-
tems use pre-coat Powdex type ion exchange resins, which
are not regenerated, most of the radioactivity from corro-
sion and fission products is collected and retained on these
resins. In addition, activity removed from the high purity
wastes by the liquid radwaste system demineralizer is also
retained. Therefore, the bulk of the solid radioactivity
wastes consists of spent ion exchanger resins, The remain-
ing solid wastes consist of filter sludges, air filters, and
miscellaneous paper and rags.

Normality 140.000 cfm From
Reactor Radwaste Turtere Bulloong

Fig. IIl-16

Ion exchange resins are dewatered in phase separators
and placed in shielded casks. Dry wastes are compacted
in drums. No solid wastes will be stored permanently at
the Station. All solid radioactive wastes will be packaged
and shipped offsite for disposal at an AEC licensed disposal
site in accordance with AEC and Department of Transpor-
tation (DOT) regulations.

t

Schematic Of Radioactive Gaseous Waste System Vermont Yankee Nuclear Power Station

a

.

t h |

|, |
i \e

534
SECTION IILE

TRANSPORTATION OF NUCLEAR FUEL
AND SOLID RADIOACTIVE WASTES

The nuclear fuel for the Vermont Yankee reactor is
slightly enriched uranium in the form of sintered uranium
oxide pellets encapsulated in zircaloy fuel rods, Each fuel
element is made up cf 49 fuel rods, is about 14-14 ft long,
and weighs about 680 lb. In each year of normal operation,
about 88 fuel elements will be replaced.

The applicant has indicated that unirradiated fuel for
the reactor will be transported by truck from Wilmington,
North Carolina, to the plant site, a shipping distance of
about 700 miles. The applicant has not stated where the
irradiated fuel or solid wastes will be shipped, but he did
indicate irradiated fuel will be transported by truck or rail
and solid wastes by truck. Distances of 900 miles for ship-
ping the irradiated fuel and of 500 miles for shipping the
solid radioactive wastes have been assumed.

1. Unirradiated Fuel

The applicant has indicated that unirradiated (cold) fuel
will be shipped in AEC-DOT approved containers which
hold two fuel elements per container. About three truck-
loads of 16 containers each will be required each year.

9. Irradiated Fuel

Fuel elements removed from the reactor will be unchanged
in appearance and will contain some of the original *°U
(which is recoverable). As a result of the irradiation and
fissioning of the uranium, the fuel element will contain large
amounts of fission products and some plutonium. As the
radioactivity decays, it produces radiation and “decay

one

“greens

535

heat.” The amount of radioactivity remaining in the fuel
varies according to the length of time after discharge from
the reactor. The fuel elements are placed under water in a
storage pool for cooling and radioactive decay prior to be-
ing loaded into a cask for transport.

Although the specific cask design has not been identified,
the applicant states that the irradiated fuel elements will be
shipped after a minimum 90-day cooling period in approved
casks designed for transport by either truck or rail. The
cask will weigh perhaps 30 tons for truck or 100 tons for
rail. Transport of the irradiated fuel will require an esti-
mated 15 truckload shipments per year with six fuel ele-
ments per cask and one cask per truckload or five rail ecar-
load shipments per year with 20 fuel elements per cask and
one cask per carload. An equal number of shipments will
be required to return the empty casks.

3. Solid Radidactive Wastes

The applicant estimates that the solid radioactive wastes
generated by the reactor will amount to from 1500 to 1800
ft®/year of resins, 65 ft* of which may contain up to 15
euries per cubic foot (Ci/ft*) and the rest, approximately
0.3 Ci/ft®. In addition, about fifty 55-gal drums of miscel-
laneous wastes will be generated each year. The resins will
be shipped in shielded casks weighing up to 45,000 lb when
loaded. The »pplicant estimates that 8 to 12 truckloads of
easks and drums of wastes each year will be shipped for
disposal — probably to West Valley, New York —a ship-
ping distance of about 500 miles.

536

SECTION IX

IRREVERSIBLE AND IRRETRIEVABLE
COMMITMENTS OF RESOURCES

The construction and future operation of the Vermont
Yankee Nuclear Power Station will use a certain amount
of air, water, and land. The plant site and the nature and
use of Vernon Pond will be affected. It is likely that the
plant site will be used for power production for a long
period. The staff believes that industry and population will
increase in the region, which will lead to increased commit-
ments of resources and perhaps irreversible changes in
natural areas around Vernon.

Long-lived radioactive materials will be produced by fis-
sion of nuclear fuel in the core of the reactor and neutron
activation of reactor parts near the core. The eventual dis-
posal and storage of radioactive materials will require a
certain amount of space, probably in an area remote from
this plant, for a very long-period of time, and could for all
practical purposes be considered as an irreversible commit-
ment of resources.

Other possible irreversible changes include the long-range
effects on fish population, discussed in Sect. V.C.4, and
transmission line requirements, in Sect. ITII.B.

Some of the 235U, 238U, and 23°Pu in the core of the reactor
will be consumed and must be considered an irretrievable
use of resources. Additional chemicals and fuels will be
consumed for operation of associated plant equipment, such
as emergency diesel generators and cooling towers. These
commitments are small compared with the need for produc-
tion of essential electrica! energy for this area.

Of the “60 acres of land used for plant buildings, it
would appear that only a small portion of this land (less

537

than 5 acres) beneath the reactor, control room, radwaste
and the turbine-generator buildings and the cooling tower
structures, would be irreversibly committed. Also, some
components of the facility such as large underground con-
erete foundations and certain equipment are, in essence,
irretrievable due to practical aspects of reclamation and/or
radioactive decontamination. The degree of dismantlement
of the plant, as previously noted, will he determined by the
intended future use of the site, which will involve a balance
of health and safety considerations, salvage values, and
environmental effects.

ENVIRONMENTAL SURVEY OF
THE NUCLEAR FUEL CYCLE
PREPARED BY
U. S. ATOMIC ENERGY COMMISSION

DIRECTORATE OF LICENSING, FUELS AND MATERIALS

November , 1972

039

SUMMARY
1. Background and Purpose

As part of the Federal licensing actions for individual
nuclear power plants, detailed environmental statements are
issued asepublic documents in conformance with the Na-
tional Environmental Policy Act (NEPA) of 1969. These
statements assess in detail the environmental impact asso-
ciated with the construction and operation of the specific
nuclear power plant, as well as the transportation of radio-
active materials to and from the plant. This document is
an environmental survey of the nuclear fuel cycle which
supports the individual nuclear power plants.

Detailed environmental reviews are carried out in the
separate licensing actions for each individual fuel cycle
facility involved in the handling of source material, or spe-
cial nuclear material, and for production facilities. Most of
the facilities discussed in this environmental survey were
constructed and Jicensed by the AEC prior to the enactment
of NEPA. Accordingly detailed assessments of environ-
mental impact have not been carried out on facilities that
predated the NEPA act. It is expected, however, that de-
tailed environmental reviews on the fuel cycle facilities
processing the bulk of the nation’s fuel material will be ac-
complished within the next few years as a result of planned
modifications and expansions of existing plants, and con-
struction of new ones. This environmental survey is not
intended in any way to replace or preclude these thorough
and meticulous analyses of individual plants.

2. Scope

This survey assesses the environmental considerations
related to the currently predominant nuclear fuel cycle for
uranium dioxide (UO) fueled, light-water moderated and

040

cooled nuclear power plants (LWR). In the United States,
about 99% of the electric power generated from nuclear fuel
incorporates this fuel cycle and a large percentage of the
plants that are under consideration for construction permits
or operating licenses will utilize this fuel cyele. In addi-
tion, estimates of the nuclear generation of electric power
indicate that this predominance of LWR use will prevail
through most of the present decade. Alternative nuclear
fuel cycles involving plutonium recycle in the present gen-
eration of LWR power reactors and the fuel cycles for gas-
cooled and fast breeder reactors will be considered in future
documents.

The specific components comprising the LWR supporting

fuel cyele are shown in Figure S-1 and include the following:

(a) Mining uranium ore.

(b) Milling and refining ore to produce uranium concen-
trates (U3Q0s).

(c) Production of uranium hexafluoride (UFs) from
uranium concentrates to provide feed for isotopic
enrichment.

(d) Isotopic enrichment of uranium hexafluoride to at-
tain reactor enrichment requirements using the gas-
eous diffusion process.

(e) Fabrication of nuclear reactor fuel including: con-
verting UF’, to uranium dioxide (UO¢), pelletizing,
encapsulating in rods and assembling fuel elements.

(f) Reprocessing irradiated fuel and converting uranium
to UF's for recycle through the gaseous diffusion
plant for re-enrichment.

(g) Radioactive waste management of high level and
other than high level waste, including long-term stor-
age of wastes.

(h) Transportation activities associated with moving ma-
terials to and from each of the above operations.

| UF, (natural)

Enrichment
(d)

UFs Enriched
(2-4% U-235)

(
i")
i
a)
=
®
—_— wt =
x
€£$ Es
> -—
eS
2
Ze
em

quivalent to the consumption of a 45 MWe coal-

”
4

116

Equivalent coal (MT x 10~%)

fired power plant
st SL ‘snipes ajrur-9¢ 60°0 tél
UIYM UoNeindod 10; waa-uew Ff St asop A\pog Z00°0 6ZI-1
914M — sjueid Surssao0rdas Jony Wory ATpedroursg | ose (s-O1 X) ¢g-ay
7X Lot (s—O1 X) wnt,

‘Punolsyorq [eanqeu oj PATJLAL OPNOStUTU |
St SNIper airui-¢ pe PuoANq oansodxa “uau0d 9t0'°0 wmiuRd()
“woo [edioutd yo OFTFILY Joys pur uoyreaquao Z0'0 0€S-UL
“U0d azNIIP 03 mug = ‘yuewernbas jeny fenuue 200 960-8
Jed war-uru 99°9 UF si[Nsoy [Tur Jo soyrur ¢ £8 Goa Uy
3 UrqyiM Punossyorq [BANj}VU aFvsVAR Jo %%> ayes (JuowUTeIjUa Suipnyjout) SoSB!)

osop [enuue WUNUWIXeyY — sym woz Ayjedroutsg
(Seto) TVOIDO'1IOIaV YY — SINE l4agy

‘quaUTUOITAUA
OF SjuanYe JuRoYrUsIs ou — sy ULOIy Ayjedrourry 000 16 Sprllog
‘JUOUTUOITA
“Ue 0} SjUeNWe jUBoYyIUsIs ou — A[uo sqrt wos OFE (e-O1 X) suornjog sfurprey,
UM] ®MW 000T poy jo 120)
wowasnbay jen4 jenuuy sed 330473 wnwxey

(Wuoweambey jong fenuuy y AT POW % pezyeurs0y))
apd) jong 4BapNny] 104 suo! Biapisuo,) [eusuUOIAU jo Arguing

(1409) —¢-S FIV

*sso001d pue asn sv3 pemyeu wor; ZT:
“UoTyBI9UAS JaM0d OJ [Ros juapeambe Jo uoysnquios uodn peseq syuenye poyeurnsy ,

3 Pi-, da
879 02 —*ON 0 at |
839 009 — *HIN Or "HN
‘IW TOYO CEI +8N
WOHNEP JO MTZ oy} pue uoLNpp aambed yey} 68 -10
S}U9N{T}SUOD IY, ‘spaepurys aiqisstuitod moyjaq Ss 4289
B[PAR] OF 403BM JO satpoq Sutataoaa Aq uornytp 0 epuon|y
[BUOT}IPpe aAta001 pure SUOT}RI}UIOUOD 9yNIIP ut 92 _*ON
jUasoid aie Yayo ;eyUOUUOITAUA WLIAPE JOZ [VY g's -'os
~“uajod & a4ny1ysU00 yeY} Sjuouodw0g = sdaqs Sut spinbrry

“Ss0001da1 pue ‘Uor}waraqey yang ‘jUoUTYoTIUa WoT
“Yseoy URWNY UO saya sey yey]

re [PA9] MOfOq-spaepuRis a}u78 Jo oSurs UTYIIM “QUOD L0 Sse!) 19410
—UOUTYOIIUS puw uoljonpoad 9 4 f) Wouy Ayyedroug
9STI S078 No Ie
L'8Z 09
eit Suoqivo01pAT]
‘IVIL B LOZ yueyzd 1
PeY-[BOO IWW CH wosyz SUOISSIWO 0} Ua]BVAIND| OLtT ON«
OOFF *os

(quawuUTe.jUa SuIpnypeut) sesey ;

(LIV) IWoOInaHD — sinaotaag

UM PMN 000T 12poy jo 1890)
qwowasnbey jen, jenuuy 10d 339443 wnwrey

(1usweambey jong enuuy yA] poy O71 Poz}[BuLr0y] )
ep) Jony avepony 407 SuoNesapisu0) [eusuu0eIAUY yo Areurung

(1409) — Ss FIGVL

£01 sa ns 9°€ _ I€ 89 ris (9-OT X Jos) sey [BanjenN

9LT — —) ae 690 Ell 9L0 §=6L60 60°0 (c-OL X LIN) [vog jue|vaInba
LIg — ae Lt Ole LZ LG GZ'0 (e—OL X 4y-M\_) A8u0ua [Polo
lang [S8s0y
Stell — — O0T os O6OIL Lt G9 Esl T9yWM [BIO
Esl ene —=— = — — — — €ZT PUNOIS 0} posaivyostcy
ésoIT — — 2 og OOOTT ~-— — SOfpog 1078 0} pasavyosicy
€9T ans —= —_ 06 Le ¢9 = It@ 0} posieyasicy
(9-OF x suojb) 499D A
2 LZ — —_ = — — — — LZ (9-0 X LW) poaow uapINqi9A_g
OF _ 60 £00 0 0 COO 8=— Z pepUWOY A[JUsURUTIOG
ST = os £00 60 60 £0 LI Bory peqinisiq
cP = = ie 910 9°0 &% 60 8€ Bory peqinysipuy
€9 - =) on 0 = 80 SZ ¢0 c¢ PeMPUWOD ATLIeI10duIa J,
(sasop ) puvy
Ld | uone, wow . 9 3u
~sodsues, = -aBeuew oondey on om me hom mn 8] VINOSAY jenjen
sem
H 9 4 a ¢« :% a v

mouranboy jong penuuy yA] [poy 0} Pozyyeurs0y)
apy jen J 782pony] 104 SuONelapisuo) [PusuMUOIAUy Jo Areuuing

Ves AIAVL

‘UMT PMW 000‘T [epour zo %L> OLEE (6-01 X oug) ‘IVA J,
‘JUSIUUOITAUD OY} 07 }UINYe JUBOYIUSIS Ou [PA9[ YSty ue} 19410
“Punoad 0} pournjas sSuyjie} ur papnjour-s[ptu wos ooer (paranq) sprjog
‘UM [pou 107 syusuTaimbaa [any [enuue “on
9% Jo Buysseoordaa [¥}0} Jog OZ YAO OL Jo %E> ' oe) scan
“OH}BI}U9UOD WNWIxeUl-sjuRid Sulssvvoided woiy
‘UM'T [Ppout 107 syuswambas
lous [enue 9% Surssvd0Id [8304 40F 06 UAO OL Jo _ oa ee ao
%0I> TOHB1}UIIUOd-syuL[d UuOIywolsqey ony wor 100 PEO UL
‘s}UsWedINber Jang jenuue :
z UAM'T [Ppout ¢-1Z Jo Surssod01d [u40} 405 06 HAD fn. th
OI Jo %c> UOHB1}UI99UOI-UOTONpoId % Fy wo J
‘WUOWUOITAUS UO Joa ou ‘aLOJoI9Y}
‘syUonye OU— puNnold 0} peuinjet pue sonbry 2 si9j}4ysnep Y umruesy
sdurie} ul pepnyout — Surprw Worf Aljedioutg
spinbry
UM1 2M 000T 12PpoW jo 1830)

jwewalNbey jon jenuuy Jed 3043 wwe
wowsimbey jong jenuuy UAT PPOW % poezyeurz0y
apd) jong 4vapony 104 SUON}B19pIsUuO’) [eusuUeIAUy jo Aasuruing
(‘u09) — ¢-g aTavV.L

oes £00 — 19 6 00ZE og 69 — (6-01 © nq) Wmsay

oz he 900 — £0 O0GT _ Aa] Ysty UBYY 49YIO
(paring) sptos
v = — F = -_ -= = - 901-8
100 — — —_— 10'0 — = ~— _- suaqysnep wintued) 10O
GG = = CZ -_ _ —~— _— —_ (¢—OF X) WNL
100 = — = 100 = aie = — FES UL
Lo 0 wit = = = -_ L130 = —_ O€o AL
Lz0°0 = = = = _ LZO'O = — 90G- PU
3 = = zoo coo Ee'0 re — SLOPSUUCT YP WNC |
spmnbr'|
£00'°0 — — 000 —- — = - = —- sotuRsnsue J,
01 a — — = _ — — sJONpol UOISST |
~ oni pe ISS]
12 600 = — 6O0v —_ = = _ —_ Tet
c00°0 _ —- 6000 -_ —_ - —_ —_ 62-1
a = ec- - - a = (¢—O1 X) S84M
Ll = a “cl o- anes paps = - (¢—OT X) WR
9400 = _ _— 2000°0 GO000 rloo 8600 - wnuBt}
600 nae = = = — = c0'0 = Oka UL
600 = — = -= ae -™ c0'0 “a 960-PU
€8 = = = _— aad = CTL - coo UL

(quowuTesjuo Suripnpur) sesey)
(sang) yoorbo/orpoy

12701 uoney quew 2uysseo “ge aw “poig Bul 2 k
am om = tA poig 3 SUNT UU (p,juoo) spuanyf
ayseM A Soa ieee
H 9 | 3 a ] 4 v

juowesmbey Png fenUUy YA PPO % Pe7teUION

apd) Jong sven, 104 SMONBAIpTsUo) jequawuosAuy jo Areuruing

(pu02) — ves ATAVL

ssoooid mosg %LL (F)

asn sed peingeu moss %Gz (£)

sud [sinjoU PUB [BOD FO UOLISNqQMIOd WOIF syuenge pourqmiog (2)

uorjeseued s9Mmod 10} [B09 juaypeamnba Jo worsNquIoD uodn posuq spuen ye pezeults” (t)

0006 — _- - 92 70 OF oooté — sprog’
¥'0 — _-_ —- — yo — — _ od
%% - — —_- -_ OFZ _a (¢—O1 X) SUOIINIOY SIULIBL,
es ee oo —

OBE es 9 ah NN ITE Ne ith tte

o89

chopped into short pieces, exposing the metal
oxides. The metal oxides are leached by hot nitrie
acid, leaving behind the chopped tubing (hulls).
The hulls are soaked in hot nitrie acid and water
to assure that essentially all of the uranium, trans-
uranies and fission products have been remeved.
The nitrie acid solution, containing uranium, trame-
uranies and fission produets. is adjusted chemically
and processed through solvent extraetion and ion
exchange systems. These process steps separate
the fission products, uranium, and plutonium, from
each other. The purified uraninm product is con-
verted to uranium hexaflueride (UFs) and is
shipped to the gaseous diffusien plant for reen-
richment. The purified plutonsum product will be
stored pending conversion to PuOs for use in future
plutonium reevele or breeder reactor fuel elements.

Fach of the plants has gaseous, liquid low-level and
solid wastes as illustrated in Table F-3. All gas-
eous effluents will be discharged to the atmosphere
via off-gas treatinent and filtering systems, which
are designed to remove over 99.9% of the radio-
active iodine gas and the radioactive fission prod-
uct and transuranie particulates. The plants re-
lease krypton 85 to the environment at rates rang-
ing from 0.1 to 0.4 Ci/see. Moreover, the MFRP
and BNFP facilities will also discharge tritium
oxide in water vapor to the atmosphere at rates of
0.007 to 0.018 Ci/see.** About 40% of the tritinm
from the NFS plant is released, with other treated
low-level wastes, to a creek which eventually flows
into Lake Erie about 39 miles from the site. NFS
is the only fuel reprocessing plant that adds radio-
activity to the liquid effluent from the plant. The

in
in impervi-

Solid Wastes‘)

Stored onsi

ous clay deposi

Stored onsite in

crums

Other Than High-Level
Tritium and
Ru-106 controlled
release to ereek
Stored onsite in

Liquid Wastes

TABLE F-3
IRRADIATED FUEL REPROCESSING PLANTS

MAJOR WASTE SYSTEMS**

Stored onsite as
neutralized liquid
in tanks in vault"?
Converted to solid.
Stored onsite in

Gaseous Effluents
To atmosphere via
Iodine Serubber,
HEPA filters, 61
meter stack
To atmosphere via

NFS
MFRP

underground lined

tanks in vault as

Iodine Serubber, sand

590 591
E $ MFRP and BNFP will discharge cooling water
, s effluent which under normal operating conditions
r g 5 B will not contain added radioactivity.
: : 3 : ; Each plant has provisions for complete contain-
s EE = .s ; ment of high-level liquid wastes in high integrity
Z: E Z¢ = # tanks in vaults or as an immobile solid as shown in
= ZEEE 5 E = ‘ Table F-3. The plans vary somewhat, but all result
% 2 = % { in total retention of the high-level wastes with no
g = é Fe = release to the environment. Within five vears all
S P z e: high-level liquids will be converted to solids and
r = z = 3 E specific activity solid wastes are packaged and
. > ae / shopped te conummercial burial grounds for long-
= g 2.63 E on =e 2 . 3 chemical effluents of fluoride bearing compounds.
z == E x S 5 = fg Re ae eta aes 96

W. D. Rows,
on behalf of the U.S, Environmental Protection Agency 151

Sreve J, Gapoier, P.E.,
St. Paul, Minnesota,
on behalf of the Mapleton Intervenors of Midland,

Michigan 165
Peren A, LInDLey,

Assistant to General Manager, Nuclear Fuel Division, 190

Westinghouse Electric Corporation 199

Antnony A, RomMan,
on behalf of the Consolidated National Intervenors and
the Union of Concerned Scientiats, 206
accompanied by

Dr. Eowanrp P. Raprorp, and 219

Dr. Henry W. Kenda 263

702
[62]
PROCEEDINGS

CHAIRMAN PAGLIN: Good morning, ladies and gen-
tlemen., May we come to order, This is an informal rule-
making hearing in Docket RM-50-3, which is being held
pursuant to notice of proposed rulemaking published in the
Federal Register on November 15, 1972, by the Atomic

‘nergy Commission, The Commission's notice of proposed
rulemaking concerns possible amendments to Part 50, Ap-
pendix D of its rules, which would deal specifically with the
question of consideration of environmental effects associ-
ated with the uranium fuel eyele and the individual cost/
henefit analyses for light water cooled power reactors.

In conjunction with this rulemaking, the Commission’s
Regulatory Staff at the same time issued for comment and
environmental survey of the effects associated with produe-
ing the annual requirements for uranium nuclear fuel of a
model light water cooled reactor, capable of producing
1,000 megawatts of electricity.

The environmental survey, which was to serve as the
basis for the rulemaking hearing, deseribes the effect of
each stage of the eyele, from the mining and milling of
natural uranium to the ultimate disposal of high-level
radioactive wastes resulting from reprocessing of the used

fuel,

The notice of rulemaking invited the comments of [63]
interested persons and scheduled an informal rulemaking
hearing on February 1, 1973, to permit the presentation of
views, both oral and written, on two alternative approaches
to consideration of the environmental effects of the ura-
nium fuel evele and environmental statements in terms of
possible amendments to Part 50,

703

The alternatives were set out in the Commission’s notice
of November 15. It is to be noted for the record that the
language of Alternative 1 is to be considered amended, in
accordance with a letter dated January 22, 1973, from Mr.
Murray of the Regulatory Staff, in the following respects :
The language to be amended appears in the right-hand
column of page 24192 of the Federal Register of November
15, 1972, and concerns the revision of language in the
penultimate sentence in paragraph (1).

The latter part of that sentence as amended will read,
“Activities as related to a particular light water cooled
nuclear reactor have been analyzed in the Commission’s
environmental survey of the nuclear fuel cycle, and if fae-
tored into the cost/benefit analysis, would be sufficiently
small as not to affect significantly the resultant conclusion.”

Thereafter in a supplemental notice of rulemaking issued
on December 27, 1972, the Commission set forth the pro-
cedural conditions which would be folléwed in this [64] in-
formal legislative type rulemaking hearing. It was speci-
fied, among other things, that since this would be part of a
rulemaking rather than an adjudicatory proceeding, the
provisions of subpart (g), “Rules of General Applicability,”
of Part 2 of the Commission’s rules of practice, would not
be applicable and that no discovery or cross-examination
would be utilized in this proceeding. However, the notice
provided that the participants in the hearing would be
subject to questioning by the presiding Hearing Board.

Thereafter, on January 17, 1973, and pursuant to the
supplemental notice, to authorization in the supplemental
notice, the Hearing Board named by the Commission con-
ducted a procedure planning session at which all partici-
pants in this proceeding were invited.

704

As a result of that session, a further notice of rulemak-
ing hearing was issued by the Hearing Board on January
19, setting forth, among other things, the schedules of ap-
pearances for participants who are to make oral presenta-
tions, in addition to written submissions, and a statement
of the understandings and agreements expressed by the
participants at that session.

There was attached to that further notice of hearing a
list of names and addresses of all of the participants who
had filed statements in this proceeding, and it was agreed
by those present that the written submissions to [65] be
offered by the participants would be provided to the other
participants in ths proceeding named on the list.

Subsequent to the issuance of the further notice of hear-
ing, certain changes were made in the schedule for appear-
ances set out in that notice by the agreement of the
participants and the consent of the Board. The principal
change is that the Consolidated National Intervenors and
the Union of Concerned Scientists will make their presenta-
tion on the afternoon of Thursday, February 1, that is
today, instead of their previously scheduled appearance on
Friday morning, it having been agreed among the perties
that they would exchange positions with the Thursday
afternoon scheduled participants.

Iu addition, I have been advised by Mr. Dzugan of the
Minnesota Pollution Control Agency that he will appear at
the conclusion of the session on Friday, February 2, in lieu
of his scheduled appearance this morning.

In commencing this rulemaking hearing, the Board has
determined the following documents shall be incorporated
by reference in the record of this proceeding, as though
they had been set forth at length at this point in the pro-

PE es “4

=)

705

ceeding, namely, the Commission’s notice of proposed rule-
making, published in the Federal Register on November 15
1972; the environmental] survey of the nuclear fuel te
soued by the Regulatory Staff of the Commission; the [66]
Commission’s supplemental notice of rulemaking hearing
issued December 27, 1972; and the further notice of rule-

mye | —— issued by the Hearing Board on January

[ would like now to call for the appearances of the par-
ticipants and their counsel, if they are accompanied by
counsel, in the order in which they appear in the January
19 further notice of hearing. And thereafter, I will ask for
appearances by any others who wish to make oral presenta-
tions and for whom provision has not been made in the
further notice of hearing. However, it is to be understood
of course, that these latter will be heard if time is ovell-

able in the sessions that have been scheduled for the next
two days. .

May I now, for the record, have the appearances of the
Regulatory Staff of the Commission.

MR. MURRAY: Mr. Chairman, my name is James
Murray; I am appearing as counsel for the Regulatory
Staff of the Commission. Our principal witnesses are with
me here at the table. We will have back-up personnel to
help them in response to any questions the Board may ask.
The principal witnesses are, immediately to my left, Mr.
S. H. Smiley, and two persons removed, Dr. Frank Pittman.

CHAIRMAN PAGLIN: Thank you, Mr. Murray.

Next on the schedule in the further notice is [67] listed
General Electric Company. We have been since advised that
they do not desire to make an oral presentation, but will

Z

706

be present for questioning. Is there an appearance for
General Electric?

MR. RESTRICK: John Restrick, counsel for General
Electric. We do have people here who can answer ques-
tions of the Board if they have any.

CHAIRMAN PAGLIN: Thank you, Mr. Restrick.

Next, U. S. Environmental Protection Agency. Is there
someone present from EPA?

(No response. )

CHAIRMAN PAGLIN: We wiil check later on. I men-
tioned, but I will have the appearance now, the Minnesota
Pollution Control Agenev, I believe Mr. Dzugan is here
now.

MR. DZUGAN: My name is Ken Dzugan, and I am here
on behalf of the Minnesota Pollution Control Agency.

CHAIRMAN PAGLIN: Mr. Steve J. Gadler.

MR. GADLER: Mr. Chairman, I am Steve J. Gadler.
I am here from St. Paul, Minnesota. I represent the Maple-
ton Intervenors and myself at this hearing.

CHAIRMAN PAGLIN: Thank you, Mr. Gadler.
Westinghouse Electric Corporation.

MR. DAUGHERTY: I am Thomas Daugherty, West-
inghouse, and our principal witness, Mr. Peter Linley, is

present.

CHAIRMAN PAGLIN: On behalf of the National [68]
Intervenors and Union of Concerned Scientists.

MR. ROISMAN: Anthony Z. Roisman. I am appearing
on behalf of the Consolidated National Intervenors and the

707

Union of Concerned Scientists. Our two technical witnesses
will be here this afternoon, Dr. Henry Kendall, Dr. Henry
Radford.

I would like to make a correction. In response to a ques-
tion by Dr. Geyer, we sent in a list of the participants, and
the name of the Mapleton Intervenors was included in that
list interested, inadvertently. As you heard, Dr. Gadler is
here and will be speaking on their behalf.

CHAIRMAN PAGLIN: Thank you, Mr. Roisman. The
record will be corrected accordingly.

Going hack up again, the Atomic Industrial Forum, Ine.?

MR. WIGGIN: I am Edwin Wiggin. I am with the
Forum; I will be making a statement tomorrow morning.
[ will he accompanied by counsel, who is not yet here.

CHAIRMAN PAGLIN: Thank you, Mr. Wiggin.

Next on our list is Exxon Nuclear Company. They have
also advised us that they do not desire to make an oral
presentation, but will have someone present. Are they
here?

MR. NILWON: Roy Nilson, representing Exxon Nu-
clear. We would like to have our written statement entered
[69] into the record.

CILAIRMAN PAGLIN: Yes. Exxon has submitted a
statement and it will be considered introduced into the
record at this point.

S. M. Stoller Corporation.

DR. GELLER: I am Leonard Geller from S. M. Stoller
Corporation. I will not be making an independent submit-
tal or oral presentation. I will, instead, be working with
the 14 utility group represented by Mr. Freeman.

708

CHAIRMAN PAGLIN: So, as I understand it, you will
not make an individual oral presentation?

DR. GELLER: That is correct.
CHAIRMAN PAGLIN: Thank you.

Now, skipping down, Baltimore Gas & Electrie Company
and the other named utility companies appearing jointly.

MR. FREEMAN: George C. Freeman, Jr., of Hunton,
Williams, Gay, Powell & Gibson of Richmond, Virginia,
appearing here on behalf of that group of utilities, accom-
panied by Mr. David Brollier of my firm. Also Dr. Leonard
Geller of S. M. Stoller Corporation is assisting us as a
technical expert.

CHAIRMAN PAGLIN: Next, the New York State
Atomic Energy Council. Do we have an appearance for
them this morning?

[70]

MR. CASHMAN: Thomas J. Cashman, appearing on
behalf of the New York State Department of Environ-
mental Conservation. I anticipate counsel from the Atomic
Energy Council will be here tomorrow. In view of the
changed schedule, I cannot guarantee he will make it.

CHAIRMAN PAGLIN: Thank you, sir.

That completes the list of participants named in the
notice of January 19 who sought the privilege of oral
presentation.

Are there any other persons present today who are not
listed, who were not here at the planning session on Janu-
ary 17, who would wish to make an oral presentation, pro-
vided time will be available? If so, can you state your
name and your affiliation?

709

MR. ROWE: I wasn’t here when you called the roll,
but W. D. Rowe from EPA.

CHAIRMAN PAGLIN: Thank you. You will be appear-
ing this morning, Mr. Rowe.

Mii. ROWE: Yes.

CHAIRMAN PAGLIN: Hearing no response to my

earlier question about additional oral presentations, we
will now move along.

The first appearance, on behalf of the Regulatory Staff
of the Commission, I will call on Mr. Murray.

MR. MURRAY: Yes, Mr. Chairman. Thank you very
(71] much. Mr. Smiley will present the opening statement
of the Commission, and followed by Dr. Pittman, who will
address himself to the subject of high level waste disposal.
Since we do have a number of back-up personnel here, who
will possibly be answering questions, I am wondering if I
shouldn’t submit, for the record, at this time, the statements
of qualifications of all of our people, including Mr. Smiley
and Dr. Pittman, and the back-up folks, and have them
incorporated in the record physically as if read.

CHAIRMAN PAGLIN: Without objection, Mr. Murray,
they will be accepted.

(The documents follow.)

sessouula |, “8Spty] AVE)
UOISSHUUIO) AZUL BMOPY “Sf

YQ Suotjeiedy,) espry YVO dA VUseIdey Ppt. LCE L-CCE1

‘suotBoydde vsussi] SUQVULAY PUR SUOIL[NLF01 SULGStqeyse UL est
10} uotjeejoid UoLQVIpEs UL sedupoosoid Suijeiodo PUB UOLIHUNUIUOD PUL 1OJ SUOL}
-saydde [jv jo worse [euYy 0} Sulssevoid pUL UORLU]AS [BIIUYIe) BI} JopSIUMUpY

CFCUE “IC “UOPsUT=z |

UOISSIMUO,) ADIVUL] DMOPY “S"_} YOUBIG] S[VLIAVIL
SUISUBIV'] [VLIIVIL JO UoIst ric] AVIHLN [Vidvdg PUB soINOS “Joll],) OLGI- L961

‘spaepurys A10jEjuse1 YyLM Aydu0.
0} Avenbepe i104) jo yurodpuyjs 04} UIOIJ [VI1o}VUL BATJIVOIPRI 194}0 PUB S}UsteIe
Janj JoyoveI po}eIpvss jo uorjejs0dsues} 10} sysva Suiddiys Jo susisep posodoid
jo jeaosdde pue uoneniers of} JojsIUNUpy “Ssvlt [Baty BURY} 1e}BeId Sol}
-Quenh ul [BLiezeul ABepouU [Biveds 10} SesUvII] FUIU1VOUOD SUOI}BIUNUTUIGD PUL 104
suorjeaydde [je uonse [euy 0} Sutssev0id puv UOIeN[ ers [BIIUYI} otf} Jo}SIUTUIPY

CEOS “O'C “WopSuryse yy

UOISSIUMMO) ABI0UTy IOP “SD youvig uonjepodsuviy
SUISUIIN'] S[BILIzV]_ JO WOISLaiy pue uornwaiqey [ony “Jely,) 6l6l-0L61

‘py Aoyog [eyuemuomAdy

VN 943 0} JuBusind sjuejd ajaXo jouy Jo joedun [eyUsUIMOIIAUS JO JUSUISSESsE

pues ‘advj}0gGNS [VLISNPU! JO SIV JsUIBZe UOI}I0}01d PUL UOISIAAIP JSUIBSE S]TVLIa}BUI

ivapuu juvpiodun A[p~eosiezVsjs FurpsveusZejes 10} sjoajyuos jo yesoidde ‘s1aure}
-u0d Suiddrys [eisszyeut satjovorpes jo perosdde ‘sseul feoIj11d BURY} 190}B813 Sar} Crtniinen BOWER. jon Pe MOM chisel atte nln iene KS

‘sa1sitid UTBe}] JO plvog UBolIoWY ay} Aq peytz1e9
‘AJOIOG IBIPUN UBoLeUTy puB (103
“dey wopduryse yy — oiounjjeg ‘juepiserg) Ajyowog soiskyg yyyeexy] Jo JaquUisyy

SIGL ©} OIG

6261 9} S96T

9}8P 0} 7161
MONGIYAd Xa
‘Sd
NOLLVOOGH

SAILADOS NOISSUAOUd

‘(yueserd — 276] Youvrp_) Sursuaory Jo awrojpoo1g ‘youvrg speueyey ‘Jory “¢
‘(Z16T YURW — OL6T

ABW) Buisusoy] s[wiseyeyY JO UoIsiarq “Youvig S[wisezey ‘Jory yuRsissy 7
‘(OL61 ABIq-996T

‘00([) Suisuvory syeiiezeyy Jo uorstaiq ‘youvrg sedojosy ‘1eMetAey loweg ‘T[

: UOISSIMIMIOD AZ1OUT] OTUIOZY “S"p

yUsseig
“996T “°C

739

738

‘SUOLJIPUOD OSUVdIT PUB SUOIPR[NZoA OPV YA oouwrpdurod Jo suzw}s our}
-ap 0} Svasuedl, OWY Jo sumaZoad Xjoyes uotjeipea oy} posrerdde pue pezoodsuy

JAVSA ‘AL UOLsoy souvydiuo,) Jo “Iq ysipeloodg UOTBIPCY

‘sjupjd uolpwoliguy [olf JO SpoodsU ApoJVs UOTPVIPBs JO UOLBULBA
YIM Poloouod su JAOJo AOlVIY “[BlLoyVUE Avopuu [Bideds puB odANOS JO ast
puv uoissessod 10} suoiworfdde osuodiT UOLR [BUY LOJ PoPBN[VAD PUB PoMIlADY

JUVSL
‘PUISUDOIT] S[VILOJVIY JO WOISLAIC] LOBUIDUY], DUISUVIU'] S[TVLLpPVIL “Ay

‘suotj Boy loeds
jRoluyoa} PUL SpaUpULS ‘Sopms popejot jo JuoUIdopsop oy} UL JSISSy — “SUOL
-waldde osusdt] Jo UOIpeN[BAo AjojUs olf} UL SBT pozi[Bioods UL «UB }SISSB [BOTU
-yoo} aptroad pue ‘soijtplovy Jo od} oso} 1OJ SJUOUIOZB}S [B}UOULUOITAUS a1vdeatg
‘Sarp[lovyJ Suissosoados ous puw sjuvypd worwolrqey ous Jo spodse |B] UeUIUOILAUO
pus AjJOJVS OY} YIM PoUVUOD 91V S}LOJJo Aseurid {solpLAow s[BiLoyVUl puB Sjenj
OJ WesZ01d Sursuddl] SOY } YA UOtjoouuoo UT jaoddns yeormyoo}, eptaoid
0} SUOIJOUNY OURAG, JO WOLeAIP [BOIUOo} PUB UOLBA}SIULLIPB LOF ajqisuodsey

Suisusov] JO 0}B10p 011]

S]BVlIO}VIY PUB spony] youvig jaoddug [eomyeay, ‘Jory,)
IG6I QUABA\ }B AT][O/) 2}B}Q “AGQeN uolyBoNpH ‘sedUalNg [BOISAY
LSPL-EL6/ 10

‘PIN ‘epseuyjeg ‘OUVSN
asSnouw ‘O ANV IAT

COGL °F EVEL

GL6L 9} CUGL

quoseid 0} 7161
MONTH A XOL
‘Ved
NOLLVJOOGM

"896T

‘royyne-00 ‘TZ YA OF suoynynboy juodsuvay, OAV MAN

ayy fo uornquamapduy

SNOILLVOITH Od

AABN “SD SG6T 0} 961
‘TM 8 JO UsISep [BOIUBYOOW

‘MOISTAICY IBeTon

N Couy ‘Burseusug] uorjsnquioy ‘1e0uIsUG SCG 0} SC6T

-dnoiZ oy} 10} sarnpoooid Suryst[qVyse Ul Pozstssy

‘UOISTAIT S10JOVOY [BABN “uy

‘Sul1s9ulsuy UOTSUqUIOo,) ‘Kyayeg [Boso[olpey 096T 3 SS6I

741

740

ALOjBLOGUT] [RUOHBN uorvyyoorgy dOUIBVI], SOISAY YR[BoT]

‘Soptus puv spiBpuyys

JO JueUIdO[vAVp oy} UI poysissy ‘suotvoljdde [Blajsupul pus |BoIpeu ‘yorResod

SUIpPNOU! ‘sasuvai"] [VIde}VP_ Joupoadrg a0] suotBol[dde jo UolenBrs [eoruydey,
ouBigy sedojzos]

HUSUI'] S[BLLOJVIY JO UOISLAICT JSIOISAU Y[VP]

‘sopmud

puke SplBpuBys jo jJusUdojorAog ‘sjue(d uoleoqeuy pony Ayjedioutid Surpuyour

juBjd ejoso jony Loy Syaoded [B}UoMUOAIAUa PUR suotjBoldde asuvsaly Jo syoadse
Oooo [RJUOMUOILAUO PUL AjoTVS [BILZo[oIpea oy} Jo SISA[BUB PUB UOT BNTBATT

youvig, jaoddng [eauyooy,
/UBIG, UOIBOLAGRY Jon y

PIG TE 9} SOG

OLG1L 9} FIGI

DUISUBT JO 0}B10}9011(] 19IUIBULT SSBd04 J ABOPOULN 2}BP 0} Y6I
CONG Ad XO
6L6T-8961 “L) PHO R)
‘DULLVOUIZUS PUB BdUAIDS ABa[INU UT Sasmnod ayUNpBIDH
Z961 OTBMBIA JO *() soIsAld ‘S'W
0961 aSal[O1F) sopRg SdIsAyg ‘oa
NOLLVOOGG
S|BLoJVWY puew sjony
youvig jsoddng jeoruyoey,
add “ff LYAdOou
; ica, | : ‘usISa(] ) 90}, TUIUIOS)
SIIPIPIOVY BAD [OU AvepUN Jo uoTBsed¢g pus worZoNI;SUO;) .
poaene aap eR a es

‘ ) ad v Zuiyjdasoe a10joq
"UOIPBIIA(Y) UOI}D9}OIg UONVIPRY oY} Ul JUOULUSISsSe JUOUBULI !
sconienr a10M noid Yyouvoses ASinipeyout BV pus uorjoss AI}sTUaYO wontons
ssao0d ‘dnoid Surnesodo 10jove1 uooNpord YALAe syUoUTUFIsse ZuruTe1y, “ureIO0I
SUUIBI} [BUOIVVIOA UO PAOTUBFT JB “0, d1LJOHT [B19UeF) YZTM UOTISsod poydeooy

‘O*-) OAPI] [B19UeL dOUTBL I, [wu0IyB,OY
spupoig oo} y plojueyy *‘PBINH “YI,
‘(AuLry "SA “9G6T

; Zurinp puv sqvy
0} | Woly potiag) ‘suoryeiedo souBUdyUIeU PUB UOT}ONA}SUOD SUI
lian (uaysorpea ‘garji[loey Zurssoooid umntuoznyzd ‘sorztplowy [[99 yoy ‘s10jOWIT 4B
jauuos.iod Suyesodo 10 syueutaambed uorjde}01d pu’ [O1}U0d UOTVWIPBL paqtoset

Or) DLIPOOTHT [B19Ua!)
SpNpoilg ouUloyY plojuURyT Su1ozuopy uUorjeipeyy “ysiperedg

"plojyueH
ye survadoid Aajouttsop youuossed Jo yonpuoo ur pozyedionsed ‘searyovid wory00}
-o1d pus aansodxa joeuuoss0d Ul SpUdd} JOOJOP 0} 9FVP PepsOIEI OSN PUB DAIIIZOI OF
seIpnjs poyonpuo,) ‘wesFo1d sp10001 UOTJBIPV PAOJUBFT PezdeIIP PUB pozyBN[BAagy

‘OD D11POTW [B19UIN
‘syonpolg o1ulo}y plojyueyy] Sp1000q] [BoIZoorpey ‘ystpetoedg

CSET 9} IC6T

PEGI 9} S61
pue

0961 03 9C6I

E96T 93 O96T

743

742

‘AU}SUPUL SUIpuBdxXo oi[} Ul suoLodsul Yous Suyoupuoo 10j Jpvys
¥ Dutjoojos puv weasoid ev Surdojeaep soy opqisuodsey “Burssavoidea jouy yueds
PUB ‘UOISLAAUOD [VIII ‘UOLWLIGRJ JON} UL posvsuo spyusjd pepnyour sip, “7
“[BOIFILO ABO[ONU [VJUIploow OJ [VUUoJOd V JUssoAd OF [BLLOPVUL d[ISSY JUSTOYNS Bur
~ABY ‘S9}B}Q Po}U_) olf} Ul SLOJOVOA UB} Lol}O ‘SetptTlOvJ PosuodT] [[V pe SuOTjIedsUT
AJOJVS AP[BO JO AVOPOUU FZuLoupuod soy opqisuodsey ‘ureazoad uotoodsur oy}
Surdoprop puv suotpodsur AjoJws APVoULIo Aveponu Zuyoupuood 10} ofqisuodsey

OVS! BOISEAC, eouetpdtuo, ) si[Bloods Uoloodsuy

‘ABLOUG JO WANOS VSB [BLLe}VUL VALOR
“OIPRA JO SONURBUD oFAR] ose YOUPM SLO} VL0U0T OLLI] VOULLIY} PUB [VLI0} BUT BATIOV
-O1ped JO SotUBUD osARL_ Jo juowdiys 10f Zusvyoud Jo woIRnpVro oy} 0} pepuez
“Xo oARY Soptiqisuodsed potiod siqy Suing ‘sjuepd Surssovoadea Bomteyo 104
s10zVi0do JO DSursuvdi] (¢) S[Vlo}VUL BALjPOvOIPes JO Fuse} puv juoswdoporop pur
AVIS LO} POSU SOLpI[loBJ [Joo JOY (Z) ‘spenf 1OJoved ABefonU poyVIpLLat ssodo1dod
YoryM vsoy} Surpnypour syuvjd Suissoesoid [Roiueyo puv uoiwoiqey vjato pouy (7) Jo
syOodsU AjJOJVS [VOITO[OIPBA oY} JO UOLIZVN[BA oy} PUL SISA[BUB oY} LOZ oFqIsUOdsey

OJAVS!) ‘As0zR[ NF
‘AIT S[VMOPVY Y spony Buissooidey Y "YRy jou ‘Jory,)

‘O]O,) ‘soure[y
ZS6I OyBIQ suBpy SOPVUIGYBIY Y Sois{t ‘AA} STUY, )

‘PIN “Bpsetpeg ‘OUVSN
GQOOMULIHO ‘d GUVHOIYN

Ee ere eee ee ee ee ee ee er van

EP et Se Re oo ee

*10}0BJUOD [VBNJ11}U9,) YOUT-YT B JO juawido[aaeq
‘RIPE ShOsUdZOI9jJoF{ Ul [OUI yrodsuvay, [votpuyAy V

SIG OF BYGI

qUuasadd 0} 296]
MONCTMAd XOL

Vd
NOLLVOOCH

SNOLLVOITANd

‘yuld suoty

-eiedas [vorulalporpvs 07 UoIzBaITdde 10J juoutdmbea pur sassavoid Jo yuourdopaaod
A10PVIOGV']T LIAL] YBUUBARYG JOIUIZUT [BOY )
‘suotpesedo But
-g39001da1 JO Saipnys [BoIUyPeT, ‘eFR1078 puv ydiaoa1 Jony UO soUBYSISSY [BOLUM],
JUB[_ J JAY YBUUBARY JosUuIZUG] [BoTUEY],)
Bpueys Ajozes
‘gorptpoey afoAo [ony JO Sususoi] JOJ VILe}110 puw spa ;
JO JoUIdopAep PUB ADIADY ‘“Sl}ITIOBJ ajaXo Jang IvopNU JO WOTBNTBAGT Ayayeg

oUBIG STON] Pe}BIPBil] |
: ‘uOn Nog, DAY Sf TOOUIFUG] [VOTWOY,)
puvyAreyy JO ApISIOATU/) quepuys
oA wys Apoyes

‘Sorp[IoBy ofa JaNJ JO Sursueol] 1OF Vi1o}110 puw spiepu
JO JUoMIdO[aAsp PUB MATADY “SOTPTO’J goo Jony ABeToNU JO TOIVBNLBAKT Ayayeg
yousig Sursseooiday pue mm
uORwOLAgRA PN] UONRNFyY “OAV S01 LOOUISUG] [BO!UOT,)
Zuiss9uSuy 1wajONN
puepAreyy Jo AyIsaoatuy) I Sur

a ONTSUT UBUI[N}{-0SOY Sui1dulsug] [Boruoty,)

LZFL-ELE (TOE) euoydeTay,
FELONS PuRArsyy “Bpsoyjieq
enusay yoo 8009
‘a¢ SUMIVTIO SVWOHL ‘V

Z96T 9} 8S6I

P96 9} 2961

COGT ©} F961
TL61 9} S961

9378p 0} TL6T
AONATHO AX
Td

‘Sa
NOLLVOOGA

745

744

‘SUI9JSAS IBOPINU UO SaIpNyg
SO}10FVIOGU] 0.171) S1ISLYg 1OIUEg

“SOIPLYS IiWOUOds apa. jaNy ! SUYUsuos vouRaNssY Ajipenb
‘Apujs uorwaqey [PU YPIXO PoxTU B AO} avo Fue ssov0.id-1vaponu UBIsop [wny
~daouo UN] Ue Aoy vouvansse Xpipeub SuIpLypout syooford suower uo poyso Ay

Aurduio,)
SuOSIB “W Ydley oy Jo Lavipisque
B® ‘uoTRLOd.10,) Uopany SUOSAR 199UITUL] ABOPONN AOTUY

‘SOI}I[LOBJ JO Sod AY 1ayQO
PUB UONBOLIGRY joNy 10} Sortpiony ajaro Ons JO Sursuoy ur soyedoyseg “S| ela, Byy
PUB sfony jo yoursg Dulssvoidey pur MONBOIGRT [OY 9} JO YRjs ayy ue—

S[BII9},BIY puv spony

GL6I 9) S96I

‘Sutsuaoi'y jo HRW OVS) JOMILADY Joo —yuasoid 0} ZT]
ATONATYA AXA

6261 APISIOATU) YOK MOV aouBul | ‘Vaw
0261 APISIOATU] YOK MAN Suleulsuy [worursy, ) ‘aK
0S61 AFojouypay, Jo aynyysuy S}JosnyoRsseyy Sultveutsury [woruray,) ‘S'd
NOILLVOONGH

puydreyy ‘epsoyjeg ‘onyen
MOVIE ‘WN NADTHLYM

*]ONj 10jOBaI JUadS Jo Zur
“889001 ad [BOIAYD Y}IM pozRiv0ssv sottayor Surssaevoid SHOLIBA puB UOIVBIEdO 10}
“OBIT “FULI9oUIFUS LOJA ‘UOIPBOLAGR] JoNJ ‘JUatUdOJarap Jang IvaPuUU UL PaaTOAUT

UOI}BIId(¢) SJoNpoOig atMOyy psozuByy
DL1}DI]Y [B1auaL

‘oJ 9WO1,9eds8 UOIZNaU 91qR}I10d B Surpnyout sad1A
“OP UOljJOp UOUBIPBL SNOLIBA UO FIOM Zurdoparop 10} afqisuodses sem pus 8780}
UOIJBOTTA [NU UOIjNOU ,jJUB[d-UI,, SNOAUINU JO JONpUOD ay} UT PeA[OAUT SBM ‘OST
‘yuerd uonwaiqey pus L19rooed uNUOyN] B Ut UOTPBRUIUA/dUITT IIay} 10J saanpso
oad SuypiiMm pus syuny Ajayes ApPRoNIWa IBopNU Surysjquyse 10; ajqrsuodse.a
‘AV WH Juoujurodde uv jo vowe;daooe [QUN EGET Wo1y ‘sessa00id uonjonpoid
UNIUBIn puB WNIMO nd puv suoyviedo uoKesedes [BoruIEYyd UT Jo8ULSUa 889001]

uoNnBIedg SyoNpoIg sIUIOJy prOjURTT
d11}09]] [B1dUaN JaaulZuy ssev01g

ty me aR ee BAS ae * Dims 4 or Vee ween an. 6

CG6T ©} ZG61

6S6T 9 SC6T

747

746

‘SuUIBIZOAC ABoponU 8, \uBdulo,) 04} Jo S}lofe DUyjoysvwu puw Zuru
~uurd ssoursng puy [VOLUYOO} OY} UL SOTpLALOR oy RAOd.JO0a tof o[qisuodsed XpLeeuttig

‘ouy ‘uoneuAy

UBOLIOWUY YV10N ‘DuUoyavyy 10J }MOPISAL] PLA 2}B.10dI0,) M4} OF JURSISSY [Bloedy
‘SONTATOB [BOIUYe} WOISTAIp {Bo[OUU [|B papvoyy

“L10,) MDW oY “UOISLAIG, avopon N ‘SLAG [BUY], JO 10}00A (|
UOMUOITAUS otf} puE oqud YY} Joojord 07 aysum VALIBVOIPRL JO JUotUATBUBTY

“UOISSIUIMIOY AZ10
“UG ONLOPY “gy ‘Wolyuyodsueay, PUL jUoeseURyY OSBAL JO UOISIAIG ‘LOPLI

T¥6T ‘YPAL JO “Ysuy ‘ssvyy AJ}SIWOY,) 21URTIOU ]
LEe6I “ATU/) }[IGtopue AUjstWeYy,) [wo
Ms Ajatoog [e110}ipr ATBLOUO] | uojisdy BJeq Ig
Aya1v0g SuULvouisuyy Aae10u0 H Iq Beg UB,
SHONOH
A}ISIBAIUL) [JeUI0,)
‘UOI}BI}STUIUIpYy Ssouisng
S961. PUB dITGN T JO JooysY ayenpesy jusuIdofarag aatuoexy
SULIa0UlZUy [BolUIaY,)
: Ul UOTOUTSIG YRIM
ZP6I ASojouyoay, Jo aynqysuy SUIAI}G Jaoulsug [RoURYoeTV an
NOLLVOOGa

puyAreyy ‘epsoyjeg ‘onrysa
SUAANAMOT YANOH

NN

‘SPGL-FPGL ‘A4}siuleyo WntuojynId UO saoded [BIIUT{I9} POYIssBlo suOLIWINN
‘$961 THEE ABI DOW ‘UOJLODOFY puvw uurz yp «VS'D ‘eMOg IBaPUN,,
SNOLLVJOIIUOd

"Yoo, JO "JSUT “SSRI AI}SIULY,) JO AOpONASU] CHGL 9} OFGI
SOL1OJIVIJOY JABYO,) STUB.) YoUBesey FPEL 9} EFGI

‘OHIG UOIJoNpOrg unt
“UO OY} JO JoFvuvyy Jo uorjtsod ur Suyevurujnod ‘ooforg quog owopy oy} 107
uniuozud Jo UOlwoLIgVy puv AdoAOdI4 ‘Fuissaovoid oy} ul seTipqrsuodset snoie

*‘SOTIOPBIOGBT OY IUslog SOWUIB]Yy SOo'T SPGL 9} PEL

‘PIGI-SGEI ‘JuoUIdoToAeq 1OzOReY Jo ‘AIG, ‘1OJaIIG
‘SC6I-LEGT ‘SUON Bley [BI4Qsupuy Jo “arg ‘10j0eI1g
‘LEGI-FS6I ‘Suojworyddy werpiary Jo “iq ‘10joeI1q Ayndag
‘POGL-SFGT “UOIjoNporg Jo uoIstAIg, ‘10jd0.11Gq Ayndaq

: Suipnypour ‘suoitsod snore,

“UOISSTUIWIOD) ASIOUT DIUIOZVY “Sf F9GI 3 SPGI

748

‘SJUNUIO}VIS [VJUNUIUOALAUS JO UOTPBIedeid BU}
SI JJBIS SRIMOPVIY PUB spony oY} JO YAO oy} JO yoodse jUBpLOdUTL Uy *S8}B}G otf}
Y}IA UoIR1vdoos 10} WRAZOAd SOP Y PY} JO UOFBAPSIUMUPL ot[} PUB Sesto] [BIL9}
-VUI IBajaUU UL SUOTSLAOAd SpaRBUTJeS Jo WoIsnpout 4.1odsuBt} LO} S[TBLL9}VUT BATPIB
-o1pva JO SuiSvyod oy} Sursuoot] ‘sTeLtoyVut 1vopouu [Bioods puv voino0s youpordAq Jo
JAOUXO PUB asn dYSoUtop oy} Buizisoyyne 10J opqisuodsol OspyY “Sot THOVJ jesodsip
aysBA puv syuyyd Fuissvdoided jong ‘syuRpd WoIBoLiqey pues Sutssovoad wniuoynyd
pue wmiuein ‘spud 9p ‘syHUE WMUBAN Surpupur syweyd gjoXo jong JO WoIRtedo
pue UoTNaAysuod 10J UIVATOA Fursuoot] S$, OEY Pl} SULLoySIULLUIPB LJ afqisuodsayy

‘Sursuoa"] JO ayV1ojpooligy *(Sutsusoi’] yuesel g
S[RIPVIY JO WOSIALT OY} APIONLIOJ) SpRLIOPV]Y PUB Sforyy 10f LOPLI Xyndeq -IL6I ‘AON
AONATHAd XA

751

S}SIWy,) JO epNzIsUyT UBolIoUTYy : MO[[eyL
(VSAM) IX BuULsig ‘uopisdy epquieTy itd
SdIHSMOTICd NV ‘SAUVAV ‘SHONOH

Cr6l Aajstueyy “SW
It6I Aajsueyy “Wa

(syySiep] ApISIeATU Ly) APISIOATUE) YLOX MON
NOILVOOGH
UOISSIWIUIOT) ADLIUG] OTULOPY “S *f)
Zuisusoi'] JO 93 B10}0I11T
S[BIL9}VIY PUL spon 10} IOxDoIIG] Ayndeq

AUTINS *H 'S

‘Spowog ABIX UBILTEMULY JO LOqQuiajt
"UOTI[UL OO6$
3 O WorjONLIysS
va sjoefoid avepuu (fF FUIpnpeu! SolztORy QOL UBYZ e10UT J ;
vee hon mn 103 ne en ‘Sui1ouiSue ABopuu Ut gouRulsojiod po}Btys
porch jo gavar CZ Suipuyout sivet Qg UB} 21001 suds souettedxe Suseoulsuy]

. ‘ S. soulsuy [BUOISSEJOI
“RIUBATASUUD PUB YO L MON JO $0}BIS Ul 1OOUISUT .
e Be SLNANAAUITHOV TIVNOISSUMO0Ud

-juouidopoAep puB Yo1vesed Pue

‘uotsjndoid avejonu ‘Suissov0.1d gpxo jouy avopoud ‘raaod agajouu a —
-gardde jo umazoods opin B poteAod PRU} suvisoid Avoput — hag 0 —
-pnyoul syoofoad Aaysupuy pue juoUIUIeAor oubiun AuBUl porpuni iY : weer
UOIJaU.A}SUOI-199UISUI-JO} {PTE Sty} JO SalpLATOV popes ayul 9} 1OF 9Tq!s

x ayy, A[Loulsoyy ) YOK MAN ;
agua oe hati mt ‘suoizelod() JO 1edBURB]T L961 9} S¥F6I
“UOT RZLUBTIO umeyo.jod api
7 ‘ s ‘Suruueyd Apiplows atngyny
- guy Jo uBaZoad AvopanT oy} LOF WLI 9S OPIS puv “SUI i]!
5 ‘moundeabe ‘suoipwoy ipo APLBJ ‘WOLpONA}SUOD yueyd Mou Soren
sueisoid jeydeo Ie jo WOIpNA}SUOD puw Sut10ul suo ‘Suiuuyjd 1oj apqisuodsey

SUF BV WOL] GPLIONYLNey WUIUBAN 10 [VACUO Ss oplLloupexdy UsyssuN} + opt
-OUPRXOY WU “Fo ‘SoplOUy OURT1OUT JO STSOYPUNS S WINIUBIN JO A.18A0001
UOTPIBA}XY JUVA[OS Ssvubiuyoo} WoINdsos AG splLongeXoy UNUUBIU WOIF Sal}
-Ludwut dBA} JO [BAOUAL “So :suBIDOAd VBpryyY YVQO Lo|}O SUOTOWIUU Popol — *

‘sotjiodoad Peusnun YyBLA s.eparod
AOT[V AO [VOU AAOPIVAJot J.LoAUOD OF ssovo0dd AOJPOREA OUTBY UO juojed pouss] = ‘F

‘OpLIONYVXoy WNIUBIN JO WOloNped 10} LOJOVIA BUTBY OUTLONY
-UdDOAPAY Vif} UO JUOPRA oISVG olf} SP[OF[ “AOJ WoL [BoltUlotja BSB pod Pup
PodAys of} Pedojorosgp ‘SoUTBa[]OO PLM SUOTB “Os[w splpOs Pog lf} JLOAUOD OF
JoPBed BV SV poy PLY oy} Zurdoporogp UL poajOaul svar ‘AjpRoyioody — ‘sewojou
-Y90} LOPIVEA OLIV PUL 10}VV}UOD PTOS-SVT OF SUOTNG!WOD juBjiodun epeyy “¢

‘sussvv01d JUvloyje ‘SULONUIZUOD
AQ @PLXOIP UUATUB.E PUL ‘opLIOUY [AUVAL “oPpLLOUBe1}o} ULLUBAL OF opLLOnpexXol|
Rg UNIUBAN JO UOISAIAUOD Vi[} YPLAL PoPBLOSs B JUGUICO[AAVP PUB YIVoset Popol — "G
‘OPLLOUPeXdY UNIUBILL OF So}PBI}
-UgdU0d 010 JO Buissovoid Jootrp UO WeRAZOId JUSUCO]aA9p PUB TPtBoset [BIO
-adS B PoP OSPY “SOLLAOV [BlMLOUIULOD PUB SOPS OPV 1oYZO YFLM JoRPWO
QIGBlopisuod PR}T “(CT-M) Bid UoOlsujpiq, SNOVsBy) OBPLY ARVO PY} FB osnypoRy
-NUBUL OpllOnpexoy WNIUBIN PUB OpLOUYR1}9} UUIUBIN LJ sassao0id snonulzUuod
Jo JuUsUICOpP.Aep of} YPM PozBloosse suvisoid Jof Bul [[@ peyodip puw poyVyiuy = *]
: SULMO[JOJ OY} epLjoUL oSpryy YVO 7B syuourystduooov sof eur aywedg
‘gessouua, |, ‘ASpiyy yVQ ‘uoryesodio,) epiq
-1B) WOIUL) “PUBL WOIsNJIC, SNOeSB{) ‘juotdopeacg Sutseeusuyy ‘yuepuezuLodug LOGI-GFG6I

>

‘Suu osuvs-Buoy oyesodisoo ut uoyediwy4eg—
‘gol0UaT¥ apIs}VO Loy}O PUB JOY ey} YpLM SulpBop Suipnyout ‘Aued
-WUW0d ay} JO SATPATOV Suisuooi"7] puw AyoJeg Ppuv IV[Vo}] t[} 1OJ Apiqisuodsay—

ee i

‘woryesodioo ay} JO Set Of} OF CVU JO diysuorpepet Surpujou! ‘SOIPLATPOR
quauidoparsp PUB YoIVEST [PIAL PopVLoossv Suiuuyd pue sisipeue suotye10dQ—
‘layed oBIpsve pasamod rvoponu oy} Turpujout ‘setAop owo
-1ULI9Y} PUB [BULIIY} UPL WOLJVIUOD Ut yom uatdojeasp Jo jaoddns jeomyoay—
“WOLPRIPBAAL VULLUBS AY SISot[JUAS—UIUICO]9.\0p joupoid puv sessovoid WOIPBI PBL] —
_ ‘Salajsupul voedso.1oe
PUB }JVAIAIB 9l[} LOJ juoutdoparep spoupodd [BpIUt LopMOd PUB ADAN]TBpOUl 1opmod
SuIpupout UY Spous ABO[OUU PLN poyVlvosse AT]BIedse ‘uUIO]aAep [BITAN]][ BPO —
‘SavAoo0d desos wuntuoynfd pue wind
“BIN Y}LA popPVLoossv SUOIFVLGdO JORAPUOD PUT YOAVOSAL JOBLPUOS Surpnypour (yu—
weisoid Suissvooided sjous IBopouu yuads
alan oQURY WBA PopBloossv LO]fo jusUIdOpOAep PUB YIBesel PwoIg Y—
emer bath ane jod-jos puv ‘suiziprosoyds ‘sisoyzAs vuiseyd ‘saul
-7800 ALOJVAJOAL SU SVIAL pozrpeweds yous ut yuourdo[esep Aajstueyo o1uBs.10uy—
‘ALelel Ol} 10J JAOJJo UOT}BOY
-yenboid jNysseoouls Suiphyour urvasoad yu UAT ABILOP UO! [UU pose
-Uvyy ‘suoizv.odo ofRos yopid puvw Youoy ‘A107B.L0qR] Suitvros ‘spunodutod WNULOYY
pue wniuBin ‘umiuoynyd uo puoutdolo.\0p yuoudmbe puv sseooid sjony 1BepuN—
' :popupaut sotpArjov [Bdloultg

752

‘spunodutod Uy, PUB () “Nd UO yuoudojorop
juowidinbe pus sseo0id sjonj cveponu possedutooue SOIPAIPOYV ‘SuIsusdl] Puw ApoFBS
‘yy[Boy 104 Sppiqisuodsat PUoULeTBUBU oyv10d.100 Surpuypour ‘suoipesedo uoijonpoad
jejuswdoparsp pue suoneaodo pred yopid 0} Yivosod o1suq Wor UIUAzedS BY} Sut
-19AOD SAIPLAIJOV JO OUR PBOAG BLOF APTA! suodsoa pet ‘Uspised gd olf} OF Zurjsodey

‘JHIWAN ‘quoutdojorod PUB YsBosoy ‘LoSVUBIT IL61-L961

755

754

. “UNISTag ‘S[ossnig,
“Y96 L doyle} og ‘AApsituol,) [BLYsupuy WO ssousuo,) [BUOIPBULOJUT TAX NX
OY} JW Poposord PUBL WOISN JIC, SOS!) ODSPLY YB oy} 3k saIpryg
(pp-o[Bog PUB AZPIGISBdS] SULLVOUITUG] ‘usuod to.) APLPPBIOA Pog-PIN| Ls» Ul

. ‘NUBULIOL) “YOtunyy
COGI ‘FZ Aoquiojdag-Og PUAVY ‘AAPSIlot,) SULTNO] yf LO WNISOCUIAG [BUOT}
-BUIO}UL PAL, PYF PB Poptosoad ,°S.LopMO NO]PY PUB [RJT ALopoRA Joy
VNU MWUPOA OF SOPLON]of OURTLOUZ O[1PBLO\ JO UOlpNpoy WB, “F
‘Qug| doqutopdog ‘Yok MON ‘DUA FV [BUOHBN Puce

ol} JV poplosodd *UBULITBE,) otf XY SPUSUULO,) ALOPONPOAZUT *AAZSTUUAT, )
AVBPUN of} Ul SopLLOUpy| PUB OULLON]Yf JO 98_) PttyUo MOLL» AMMUG "HS J

“9961 ‘og AR %,) “C SMOPSULYSB AL ‘suopiBubpvopp OLY UMOPUBULIS)
‘Surjooyy puoIdoparo(, SUqUy, SO[PY UopsBuny, puv UojsDuNy, *,oossou
“Ud, ‘PDPNYY YO “PUR] WOISUAIC, SUOOSBL) ODPL] YVQ ‘UOISLAL(, ABoPUN
‘uo1jyB10d1o,) eplqie,) UOLU() Aq ssoiso1g Jo ATBUUIny V,, ‘No[MUIg "ES 8

‘egg Arena
~qoyf ‘stouyt] “osworty,) “SUYoosT OLINTV jRUOIVN otf} YB poyuosoad *(G9G]
aun?) sTejyoyy Jo [BuNo Ll’ _Soljtodoig [BUSLUL) YPM SLopMOd [BION X10}
-aeajoy Jo uolpusvdoty,, “UBUYUBN TTL pee loyeig 9) ‘q‘Aqwg "HS ?P

' ‘0961 toqute}dog
yO KX MON “YOR MON SOV Je SurjooyY [12 OMGT PG} 38 poptosotd « SUOT}
-B10dQ Bulsso.t UNIUBAL) UL OULLONP YY [BPUSIoTH] JO gjoy yuBysoduty
OL ‘xoyyseg “}y ‘f pux ‘ppyepwy “OO ‘19yeig ‘) ‘d ‘AOTLUIG >
SPoy PozIpmpy, YP vuUdllod xy
jUB] | ABOPUN,, ‘AN HBg ‘Pusaambug ADIPNN ‘SIMIC wnisodurg Gu.) “4

‘1961 ‘AJoFBG pus Suisoeursug ‘AZojou

-YOOT, F IOA ‘AT S889 ‘Absaug svapnny we ssasbotd _{sutsseoos g WinTU

-BIf] Ul S10PIBOY SPLLOG-SBh),, ‘MolAad [BaI}LIo advd-)g UB Suipuyoul ‘sosag
Absaury AVIJMN Ul SSeADOId S80 UOWIRT1ag oy} Joy saajzdeye [RAS *B
:a1e AZojou

-yoo} oUILONY pure WULTBIN YPM Zurpeop suorjwarqud peytissejoun jo soydure
-X9 MO} Y “poylssepo viv pue (aatiieq) euBIquoUt worneiedes oy} AjAByNI}

-1vd ‘UOIsH YIP SNOYsRS UO a1B YOU JO AUBUT ‘sy1oder snozeumnd Patou Vy

‘asuq UoIZBaTTdde pvoig B AVAO OS Lolly pure soyos0o} eurseyd ZulAjoAut ‘UIBIs
-o1d uoronpoid-tutes pus jeyuoutttedxe juBoyiusis B peseuBl pus poyentuy

‘MAaISAS UOTPBIPUBUOD PUB Surddiays JUOAOS UO} B Sutsu
—- sases-jjo yueyd Suisssaooided Jous Wlodly UOUOX PUB U0 Ary PAIOROIPVA OTB
-yord 07 pur ayerndes 04 ssaooid & Jo JUdUICOTeAVp Pepnpoul OsTe weisoid ayy,
‘eZ-Y ye Buissovoaded [uy yueds uo wrerZoad sofeut B poseuvul puke peytB}S

‘9}0 ‘SULa}SAS ALOAOD0L PUB jesodsip opliongexey ture pus aULLON ‘SULd}SAS
Suiddeay eplionpexoy Wuluen ‘SuIOJSAS UOLPB[NIALVET 1OPBM “Fa ‘syuauodwoo
AAVIPIXNB opBoseVd WOISTFTP Surapoaut suressoid soy} SB [fo sv aouvttiojied
pus juowdoporep Jasnjgtp YIM po} Vloosse surersoid 0} SUOTINGIAZUOD [BL1eTV
“UBL PUB [BOTUIP} JUBOYIUTIS opeBul — JOLLceq uoryeredas sodozost WHIuBIn
ayy pedoporop FRY} UB} JUULaFRUBUL PUB [ROTUTPIEZ otf} JO LoquTout Aay B SB AY

{NO PalliBo SBM Surploul uorzyoalul pus LoJsuBs}
SB [JOM Sv Fuiquy JO WOIst.yXo WO YAOM [BIZLUL OG} JO BULOS ‘gray — A10zB10qB]
juatdoparop UOIPwoLIgRy A-}PM © jo wore Ip uresZord puvy yUdsUteTVUBUL 1OF
gjqisuodsod SBA yuejd uolonposd sonseid poyeutsony -19M B Jo UOTJOU.A}SUOD
JO} BILo}LIO UBIsep PEys | qeysol ‘Joyoru ‘Us}sBUN} JO uo1pisodep 1odea [Boruleye
‘uo1jonpoid wo10g pues uorzeredas edoyost UOL0q ‘sonbiuyooy snoiea Aq WBet7s

Development, The

echnical leader capacity for chemical proc-
handling and analytical methods.

Research Chemist, Standard Varnish Works, Staten Island, New York; worked

ion; was involved in t
on resin and paint synthesis for improving of properties.

Uranium and Fluorine Technology and Barrier
concentrating on UF's

Group Leader, U
Kellox Corporat
essing projects,

1944-1945

1943-1944

: taught under-

Graduate Assistant (Chemistry Department), New York University

1941-1943

graduate classes and assisted in undergraduate chemistry laboratories.

756

157

[72]
CHAIRMAN PAGLIN: Mr. Murray, you will have
copies available for any interested participants?

MR. MURRAY: Mr. Chairman, unfortunately, among
all of our other copying activities, we neglected to make a
great deal of copies for other people. We have a few. Of
course, they will be in the publie record.

CHAIRMAN PAGLIN: I was going to say, Mr. Murray,
should anyone have any questions about the qualifications

of the experts appearing on behalf of the Staff, we can loan
them our copies.

Thank vou. We will proceed. Mr. Smiley.

Iixcuse me. If there is any difficulty in hearing the wit-
ness in the back of the room, please let us know and we will
attempt to move the mike closer to him, or try to make it
possible so everyone in the room can hear him. Is this PA
system working? I get a nod of the heads from the back.

STATEMENT OF 8S. H. SMILEY, DEPUTY DIRECTOR
FOR FUELS AND MATERIALS — DIRECTORATE
OF LICENSING, REGULATORY STAFF OF THE
ATOMIC ENERGY COMMISSION.

MR. SMILEY: The licensing review of individual nu-
clear power reactors is governed by 10 CFR Part 50 of the
Commission’s Regulations. The AEC’s policies and pro-
cedures for implementing the National Environmental
Policy Act of 1969 are set forth in Appendix D to Part 50.
Appendix [73] D includes a requirement for a detailed
environmental report from the applicant containing a cost-
benefit analysis which should, to the fullest extent practic-
able, quantify and balance the various environmental, eco-

758

nomic, technical, and other factors involved in each pro-
posed facility.

On November 15, 1972, the Atomie Energy Commission
published for comment in the Federal Register a notice
that it is considering possible amendments to Appendix D
to deal specifically with how environmental effects associ-
ated with the uranimn fuel evele are to be considered in the
cost-benefit analyses for individual light water-cooled
nuclear power reactors.

The technical support for the amendments is contained
in a document entitled, “Environmental Survey of the Nu-
clear Fuel Cycle.” The survey sets forth the off-site en-
vironmental effects of the nuclear fuel eyele for today’s
reactors, which are uranium dioxide fueled and light water-
cooled, and is prepared so that the fuel cycle environmental
effects attributable to a single reactor can be evaluated.
The survey covers the environmental effects of the various
steps in the uranium fuel cycle which inelude uranium min-
ing and milling, production of uranium hexafluoride, en-
cirhment of the uranium in the isotope uranium-235, fabri-
cation of reactor fuel elements, chemical processing of
spent fuel to obtain reusable fuel material, management of
radioactive wastes, [74] and transportation.

The-following conditions were borne in mind in develop-
ing the premises for the survey:

(1) Each facility within the different components of
the fuel cycle (except uranium mining which is under the
jurisdiction of the U. S. Bureau of Mines) is or will be
the subject of detailed AEC safety and environmental
reviews in connection with the review of materials or
facilities license applications or other federal actions.
For example, a Safety Evaluation Report and an En-

759

vironmental Statement are prepared by the Regulatory
Staff in connection with each application to construet and
operate a spent fuel reprocessing facility. A safety re-
view is then made by the Advisory Committee on Reactor
Safeguards and the application is subject to hearings
before an Atomie Safety and Licensing Board.

(2) There are more than 150 nuclear power reactors in
operation, under construction, or planned in the United
States. Mach uranium mining or milling operation, ura-
nium hexafluoride production plant, isotope enrichment
facility and fuel element fabrication plant will contribute
fuel to a number of these reactors, but there does not
appear to be any way to ascertain with certainty which
fuel eyele facility will serve a given reactor or other li-
censed or nonlicensed (i.e, AEC operational) activity,
like the isotope separation plant.

(75]
” rr . ° . .
(3) There are a variety of ways of performing most
of the steps in the nuclear fuel cvele.

In recognition of the above points, the following deei-
sions were reached regarding the approach and content of
the survey:

(1) The survey was based on a “model” 1,000 mega-
watt electrical light water-cooled power reactor using
uranium dioxide fuel and having an estimated useful life
of 30 years. The annual fuel requirement for this
“model” reactor was taken to be an average of the
amount required for the initial fuel loading plus 29 an-
nual reloads. Recognizing that a typical boiling water
reactor and a typical pressurized water reactor may have
different annual fuel requirements, the amounts used in
calculating the 30-year average were conservatively

760

taken to be the higher of the two alternatives for each
year.

(2) Beeause for most steps of the fuel eyele a number
of plants utilizing a variety of processes and operations
are involved, a generic approach was used in assessing
the environmental effects of the fuel ecyele. For each
step of the fuel evele, a model facility was defined.

For those fuel evele steps where a single method or
type of facility predominates, this method or facility
was adopted as the model. For other fuel eyele steps,
again in the interests of conservatism, that mode of oper-
ation [76] imposing the most significant impact on the
environment was in most cases adopted as the model. For
certain steps, where only two or three facilities with
widely different modes of operation and environmental
impacts are involved, the model was based on a weighted
averaging of the facilities’ throughputs. The model fa-
cilities are thus not intended to represent particular
plants. Rather, they were defined so as to be representa-
tive of the industry, with a conservative bias in assessing
environmental impact. Effluent concentrations, radiation
dose rates, and human population densities appropriate
to the model fuel eyele facilities were then estimated
using the best available data from existing or planned
facilities.

(3) From a review of operations immediately “up-
stream” and “downstream” of each fuel cyele facility, only
the generation of electrical energy for the isotope enrich-
ment step was judged to cause significant environmental
effects. The environmental effects of the coal fired power
plants used in the grids supplying the power were there-
fore included in the survey. These coal fired plants are

761

the major source of gaseous effluents and use the bulk of
the water for the entire fuel evele.

(4) In each step of the fuel cycle the models were se-
lected to be representative of the industry today with
only minimal allowances for future technological ad-
vances [77] entailing lesser environmental impacts.

(5) The survey is not intended to relate to any specific
site characteristics. Meteorology, hydrology, seismology,
historical significance and site ecology are all analyzed in
detail by the AEC in connection with its review of license
applications for individual fuel eyele facilities.

(6) The survey does not attribute any benefits to the
fuel cyele since benefits are credited to the generation of
energy at the power plant which the fuel evele supports.

(7) Occupational health and safety relating to on-site
workers is not considered in this environmental survey
or in environmental statements or reports. Such con-
sideration is a major factor in the detailed safety reviews
that are undertaken by the AEC Regulatory Staff as an
integral part of the licensing reviews for individual fuel
eycle facilities. Applicants are required to engineer, con-
struct, and operate proposed facilities to limit the ex-
posure of workers to fractions of prescribed low levels
of radiation and potentially hazardous conditions. Dur-
ing the operation of the facilities, periodic checks by the
AEC Regulatory Operations Staff are carried out to
monitor the actual occupational conditions and assure
that workers are not exposed to unsafe or hazardous
conditions.

(8) Fuel cycles alternative to the uranium dioxide

[78]

cycle have not been considered since the light water re-

actors that are the subject of the proposed rulemaking
are not at this time using any other form of fuel. In the
future, some or all of these reactors may use uranium-
plutonium mixed oxide fuel. At that time, we would ex-
pect that a similar generie survey would address the
environmental effects associated with the use of that fuel.

Kach component of the fuel eyele was analyzed for off-
site environmental effects in a manner similar to the Com-
mission’s methods of assessing Environmental Impacts for
Nuclear Power Plants, and encompassed: Natural resource
uses including land, water, and fossil fuel; effluents inelud-
ing radiological, chemical, and thermal; accident consider-
tions: and transportation of radiological materials.

The results of these analyses have been normalized to the
annual fuel requirements of the model LWR and are sum-
marized in Tables 3 and 3-A of the Environmental Survey.
To place the resultant data in perspective, comparisons
have been made with the environmental impacts caused by
operations of comparable magnitude in other industries,
and with the requirements laid down in various federal,
state, and other regulations and standards.

The findings of the survey are summarized as follows:

Use of Resources
[79]

(1) Land

In meeting the annual fuel requirement for the model

reactor, about 63 acres of land are temporarily withdrawn
from active human use. The fencing required also restricts
migration of large animals. Approximately 18 acres are
transformed from their original state by the construction
of facilities. This disturbed area is less than 10 percent of
the equivalent annual commitment for coal mining for a
1000 MWE coal fired power plant. Less than five acres of

763

land are permanently committed to the production of the
annual fuel requirement for the model reactor.

(2) Water

Approximately 11.3 billion gallons of water are moved in
producing the annual fuel requirements for the model
LWR. Eleven billion gallons of this is required to remove
the waste heat from the coal fired power stations supplying
electrical energy to the enrichment facility. Assuming
once-through cooling at these power stations, all of this
water is returned to surface water bodies. The remaining
338 million gallons is required for cooling, processing, and
dewatering at other fuel eycle plants. The total of 11.3
hillion gallons required for the entire nuclear fuel evele
represents less than 4 percent of the water requirement
(approximately 300-400 billion gallons/year) of a 1000
megawatt electric light water reactor utilizing once-through
[80] ,
cooling.

(3) Electricity

The total electrical requirements to meet the annual fuel
requirement of the model reactor are 317 thousand mega-
watt-hours, which is less than 5 percent of the energy
(seven million megawatt-hours) which the reactor would
produce in a year’s operation. Over 98 percent of the elec-
trical energy required by the fuel cycle as a whole is util-
ized in the enrichment step.

(4) Natural gas

Approximately 100 million standard cubic feet (sef) of
natural gas are consumed. to produce process heat. Most of
this is used in the milling operation. This quantity of
natural gas could be used to generate roughly 10,000 mega-
watt-hours of electricity, which is less than 0.2 percent of
the annual output of the model reactor.

E fluents
(1) Chemical
(a) Gaseous

Assuming that the electricity requirements of the fuel
cycle facilities are supplies by coal fired power stations,
the combustion products of coal would comprise nearly all
of the airborne chemical effluents attributable to the nuclear
fuel eycle. Since the uranium enrichment step consumes
over 98 percent of the electrical energy required [81] by
the fuel cycle, these gaseous effluents are ascribed to this
step. To the extent that power is supplied by nuclear power
plants, the total quantity of sulfur dioxide, nitrogen oxides,
hydrocarbons, carbon monoxide, and airborne particulates
would be greatly reduced.

Fluorine is introduced into the fuel eyele for the produc-
tion of uranium hexafluoride and is removed from the fuel
material in the fuel fabrication step. Fluorine thus becomes
an airbore effluent from several steps of the nuclear fuel
cycle. Although most of the fluorine gaseous wastes are
effectively removed by serubber treatment systems, ap-
proximately 0.7 metric ton is released to the environment
as an airborne contaminant in supplying the annual fuel
needs of the model reactor. To put this quantity into per-
spective, the estimated fluoride release from the total nu-
clear industry in 1980 assuming an installed nuclear gen-
erating capacity of 140,000 megawatts, electrical, would be
less than 0.1 percent of the total fluoride released from four
other basic industries: phosphates, aluminum, steel, and
ceramics.

Measurements or calculations of airborne fluoride con-
centrations at the site boundaries of specific plants in the
nuclear fuel eyele are well below the levels observed to have

765

an adverse effect on human health, and are well within the
amounts permitted by existing state standards. State
standards are used for comparison because there are no
[82]

applicable federal standards.

At uranium mills and uranium hexafluoride production
plants, the combustion of natural gas for process heat re-
leases nitrogen oxide to the environment. Dispersion calcu-
lations show that annual mean concentrations of nitrogen
oxides from this source are within the 100 micrograms per
cubie meter established as the limit in Environmental Pro-
tection Agency air quality standards. That standard is in-
tended by EPA to protect the public from any known or
anticipated adverse effects associated with the presence of
oxides of nitrogen in ambient air.

CHAIRMAN PAGLIN: Mr. Smiley, may I just inter-
rupt you for a minute. I apologize for the gentlemen stand-
ing in the back. I understand that chairs will be brought in
very shortly, so if you will just bear with us, we will have
enough chairs to go around.

Would you continue, please, Mr. Smiley.

MR. SMILEY: I| have just completed discussing the
gaseous chemical effluents. Now I would like to comment on
the liquid effluents.

The largest quantity of liquid effluents, 240 thousand
metric tons of waste solutions per annual fuel requirement
of the model reactor, comes from the milling processes.
This waste is discharged to the tailings pond, and since it
does not normally contaminate unrestricted [83] ground or
surface bodies of water, it does not actually become an ef-
fluent stream.

766

The concentrations of fluorides, nitrates, and ammonia
contained in the liquid waste streams from fuel fabrication
plants are a possible source of adverse environmental
effect. Dilution of these constituents by the receiving body
of water by factors ranging from 10 to 1000 may be re-
quired to achieve drinking water source quality. The dilu-
tion factor needed depends on the flow rate of the receiving
body, its upstream quality and its downstream use. Efforts
are in progress to minimize these releases from existing
fabrication plants. Normally, sufficient dilution is easily

achieved.
(c) Solid wastes, non-radiological.

The greatest bulk of solid wastes is generated in open pit
uranium mining and milling operations. The barren rock
and earth which, in open pit mining, must be removed to
reach the minable ore constitutes a waste material only
temporarily, since it is returned to the barren mine as back-
fill. The major source of solid waste in the uranium fuel
cycle is the mill tailings, composed primarily of sandstone
and clays. Some 91,000 metric tons of such wastes can be
attributed to the annual fuel requirements of the model
reactor. They are pumped as a slurry to the tailings pond,
where they are permanently stored as solids in a chemical
[84]
form similar to their original condition, but containing
slightly less radioactivity since uranium has been removed.

(2) Radiological
(a) Gaseous

The most significant gaseous radiological releases occur
in the fuel reprocessing step. Nearly all of the krypton-85,
most of the tritium, and minute quantities of radioiodine,
other fission products, and transuranic particulates created

767

in the nuclear reactor fuel are released to the atmosphere
from the reprocessing plant operations.

The annual 20-mile population dose from reprocessing
operations attributable to the annual fuel requirements of
the model reactor is estimated to be 4.4 man-rem, or about
0.005 percent of natural background radiation.

Small quantities of uranium and its daughters are re-
leased to.the atmosphere in several steps of the fuel evele
Measurements of radon presence in an open-pit mine om
vealed no significant alpha concentrations. The site houn-
dary concentration of thorium-230 from the model mill pro-
ducing the fuel requirements for about five model reactors
is estimated to he approximately 15 percent of the amounts
permitted by AEC regulations (10 CFR 20). In all nr
eases the concentrations of uranium and its daughters are

estimated to range from 1-4 percent of the AEC limits for
unrestricted areas.

[85]
(b) Liquid

In the fuel reprocessing for the model reactor’s annual
fuel requirement, approximately 2500 curies of tritium
and 4 curries of ruthenium-106 are released in the liquid
effluent from the model reprocessing plant. Because of the
effect of dilution in receiving streams, measurements in
1971 indicated that the maximum off-site concentration of
each Species was less than 4 percent of the 10 CFR 20
limits. ;

Small quantities of uranium and its daughters are re-
leased in liquid effluents from each step of the fuel evele.
Estimates of the concentrations of radionuclides in effluent
streams from fuel cycle plants indicate that concentrations

are from 1 percent to below 10 percent of the 10 CFR 20
limits before dilution in receiving waters.

768

(ec) Solid

The most significant solid radiological waste consists of
the fission products separated from spent fuel in the re-
processing operation. These high-level wastes will be
stored on-site for a maximum of 10 years, and will ulti-
mately be shipped, probably by rail, to a federal storage
facility. This federal facility will store and manage high-
level solid wastes under constant surveillance for up to 100
years, or until such time as a more permanent federal
repositary can be established. The storage facility will
he designed to prevent the release of any radioactive ma-
terial [86] to the environment by any credible environ-
mental condition or human action. Dr. Frank Pittman,
Director of the AEC Division of Waste Management and
Transportation, will present further testimony regarding
the AEC program for safe handling of high level waste.

Fuel element hulls and other fuel element parts con-
tuminated with trace quantities of uranium, transuranics
and fission products will be buried on-site at the reprocess-
ing facility in a retrievable form. Other slightly radio-
active material, such as laboratory wastes, may be buried
on-site or at a commercial burial ground.

Wastes from uranium hexafluoride production facilities
and fuel fabrication plants amount to a few curies per
annual fuel requirement for the model reactor and are
packaged and shipped by truck to a licensed commercial
burial site. The geological and hydrological characteristics
of these burial sites are such that there will be little or no
migration of radioactive material from the site. The burial
sites are enclosed by fences and access is controlled.

The solid waste tailings from the milling operations,
which contain most of the uranium daughter products orig-

769

inally in the ore, are pumped to the tailings retention pond
and the activity is contained on-site.

(3) Thermal

Approximately 3.4 trillion Btu of waste heat are [87] dis-
charged to the biosphere in fuel cycle steps meeting the
model reactor’s annual fuel requirements. About 05 nee-
cent of this comes from the isotope enrichment step. For
purposes of comparison, the waste heat from the annual
operation of the model reactor itself is approximately 50
trillion Btu. Thus, the thermal releases from the support-
ing fuel cycle constitute less than 7 percent of the thermal
release from the model reactor.

Accident Considerations

The history of the nuclear fuel cycle to date indicates
that accidents in fuel cycle facilities which could result in
significant effects on the off-site environment are highly
improbable. This record of the commercial nuclear fuel
cycle industry has been accomplished by establishing safety
as a controlling factor in all operations.

Each applicant is required in his license application to
analyze potential conditions that could result in the release
of radioactivity beyond the plant confines. He is further
required, by proper design, construction and operation,
which are carried out under quality assurance programs,
to minimize the possibility of such releases. As a further
assurance, the AEC makes a detailed independent safety
evaluation of each commercial fuel cycle facility. This
evaluation includes at least the following elements:

[38]
(1) Site Analysis—The geography, meteorology,
hydrology, and other characteristics of the site are re-

770

viewed. In addition, severe natural phenomena pertinent
to the site are taken into account in evaluating the de-
sign of plutonium and reprocessing plants.

(2) Process Evaluation— The process flow sheet is
reviewed in detail to identify potential effluents and
safety problems during normal and abnormal operations.

(3) Structures, Systems, and Equipment — The
building itself, including significant features such as
modules, layouts, corridors and points of access and
egress, is reviewed for safety, emergency escape, limiting
the spread of contamination and prevention and control
of fires.

Ventilation, air cleaning, waste treatment, safety in-
strumentation and monitoring systems are analyzed for
suitability under normal and abnormal conditions.

Process and utility equipment are reviewed for ade-
quaey and reliability.

(4) Safety Programs — Among the safety programs
reviewed are those involving contamination control, ven-
tilation system performance, exposure assessment for
workers and control of such exposure. Effluents and
efiuent treatment and monitoring systems for both
liquid and gaseous streams leaving the plant are eval-
uated. Accident analyses that include consideration of
criticality, radiation safety, [89] and nonradiation safety
problems are performed. In plants handling special nu-
clear material, both liquid and solid systems are eval-
uated for criticality safety.

(5) Procedures — Each licensee is required to have
detailed operating and maintenance procedures rein-
forced by quality assurance programs. The training and

771

testing programs for operators are reviewed. Particu-
lar attention is given to fuel reprocessing plant opera-
tors, each of whom must be tested and licensed by the
AEC. The licensee must have in being a hazard review
committee or some similar organization that has respon-
sibility for review of new processes and plant changes.

And I might mention these committees must meet
regularly.

The licensee must also perform safety audits of opera-
tions and report the results to the AEC. License appli-
eants must submit plans for coping with emergency
situations. The AEC reviews these plans in detail.
Emergency plans required for plants handling special
nuclear material are spelled out in conditions attached to
the license. Emergency plans required for fuel reproces-
sing plants are specified in Appendix EF of 10 CFR 50.

(6) Materwals and Plant Protection Evaluation — The
AKC reviews in detail each applicant’s program for safe-

guarding special nuclear material against theft, diversion,
or [90] sabotage.

As a supplement to requirements for care in design, con-
struction, and operations of nuclear fuel cyele facilities,
each licensee is required to report to the cognizant AEC
Regulatory Operations office any incidents which cause or
threaten to cause unexpected events covered by AEC Regu-
lations. The information in these reports is used as a basis
for corrective action to prevent similar events from oceur-
ring in other plants and is taken into account in the licens-
ing reviews on new or modified facilities of a similar
nature. Such information is also evaluated to determine
the need for new or modified standards.

772

The effectiveness of these measures is demonstrated by
the fact that there have been no incidents in fuel cyele
facilities using slightly enriched uranium in this country
which have resulted in significant injury to or endangered
the health of any individual in the general public. Never-
theless, for each fuel eyele facility requiring an AEC li-
cense, a series of potential accidents with environmental
effects judged to range from trivial to serious is postu-
lated and evaluated in the safety analysis performed before
the individual facility license is issued.

Records to date indicate few, if any, of the routine type
accidents involving special nuclear material have had any
measurable effect on the environment. Thus, the review
[91]
of accidents for this “Environmental Survey of the Nuclear
Fuel Cycle” have been concentrated upon the most serious
accidents that either have occurred or that can realistically
be postulated. The estimated radiation exposures in unre-
stricted areas resulting from the most significant of these
accidents are summarized in Table S-5 of the survey.

Transportation

Fuel material shipments are priimarily made by truck.
The probability of an accident oecurring in truck transpor-
tation is small, varying from one in a million vehicle miles
for minor oecurrences to one in 100 million vehicle miles for
severe accidents.

Fuel materials are packaged based on the nature of the
contents. For example, material, such as yellow cake
(U;0s) which has low radioactivity per unit weight is de-
signed to retain the contents wider normal handling since
the potential exposure, even in a serious transportation
accident, is relatively small. Packaging for fissile material
sneh as uranivm dioxide and enriched uranium hexafluoride

773

is designed to retain the contents and prevent criticality in
both normal transport and in severe transport accidents.

Due to the massive weights of the packaging required,
future shipments of solidified high-level wastes are expected
to be made by rail. The accident rate for rail [92] ship-
ments is 0.8 per million car-miles. Solidified high-level
wastes will be packaged in containers designed to withstand
both normal transport and severe transport accidents with-
out loss of contents or significant reduction in shielding.

The publie will be exposed to a small amount of direct
radiation exposure during the normal shipment of solid
wastes. These dosages are estimated to be less than one
ten-thousandth of one percent of the natural background
radiation.

The report also contains an overview.

As has been discussed, the “Environmental Survey of the
Nuclear Fuel Cycle” relates the environmental aspects of
the nuclear fuel cycle to an individual model light water
reactor. To provide additional perspective, an overview
of the aggregate environmental effects from the total nu-
clear fuel eyele industry is presented for the years 1972
and 1980. For each of these years, industry demands, num-
bers of plants required for each step of the fuel eyele, and
estimated individual plant capacities are given. The aggre-
gate environmental impact of each step of the fuel evele
is then presented in a series of tables and accompanying
text.

Our evaluation indicates that the environmental effects
of the nuclear fuel cycle that are attributable to the model
reactor are small. As stated in the Federal Register [93]
Notice of Proposed Rulemaking (37 Fed Reg 24191), the

774

Commission is considering possible amendments to Appen-
dix D to 10 CFR Part 50 of its regulations. These amend-
ments would deal with the question

[Text truncated at 120,000 characters. The full text is on the page linked above.]

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385004_1660%3A05. Public record. Not legal advice.