Recommendations for an Applicant to Calculate Activity Data for Greenhouse Gases Estimates
In 2009, the U.S. Nuclear Regulatory Commission (NRC) directed the NRC staff to address climate change issues and consider the impacts of the emissions of carbon dioxide (CO 2 ) and other greenhouse gases (GHGs) in its environmental reviews for major licensing actions (NRC 2009b). To implement this direction from the Commission, the staff issued guidance in 2011 and updated guidance in 2014 in Attachment 1 to Interim Staff Guidance COL/ESP-ISG-026 (NRC 2011; NRC 2014). This guidance provides a simpler method than the method described in RG 4.2 Rev. 3, that an applicant can use to meet the plant parameter envelope (PPE) value from the Generic Environmental Impact Statement for Licensing of New Nuclear Reactors (NR GEIS). NRC staff estimated the 97-year lifecycle GHG emissions from a reference 1000 megawatt electrical (MWe) light-water reactor (LWR) for various activities associated with construction, operation (including uranium fuel cycle), and decommissioning of nuclear power plants and presented the results in Appendix H of the NR GEIS. Appendix H of the NR GEIS includes estimates of direct emissions from construction equipment and emergency diesel engines in a nuclear facility and indirect emissions from workforce vehicular traffic, fuel transportation and the uranium fuel cycle. The NR GEIS Section 3.3 extended the estimates in Appendix H for the installation of two 1000 MWe nuclear reactors on the same site. Scaling factors were used to extrapolate the GHG emissions of a reference 1000 MWe reactor to a two-unit nuclear reactor plant (each reactor unit generating 1000 MWe). GHG emission estimates for building, operation, decommissioning and safe storage (SAFSTOR) for a two-unit nuclear reactor plant would be based on the plant’s physical size, and therefore estimates for these source categories were assumed to be twice the value of the reference 1000 MWe reactor. However, GHG emissions from the fuel cycle (including fuel transportation) were scaled upward by a factor of 3, based on plant efficiencies greater than the 80 percent assumption in Appendix H. Table 1 below shows the PPE emissions for two 1000 MWe nuclear reactors as provided in NR GEIS. The total GHG emissions for two 1000 MWe reactors were calculated as 2,534,000 metric tons (MT) of CO 2 equivalent (CO 2 (e)) based on a 97 year GHG life cycle period. The GHG emissions lifetime of 97 years for a reference nuclear reactor includes a 7-year building phase, 40 years of operation, 10 years of active decommissioning, and 40 years of SAFSTOR operations (NRC 2024). Construction equipment and vehicular traffic from workers commute would contribute to the GHG emissions during a 7-year building phase. Uranium fuel cycle, vehicular traffic, fuel and waste transportation, and testing of standby diesel generators would contribute to GHG emissions during the 40-year operations phase. While NRC’s regulations allow up to 60 years of reactor facility decommissioning, Appendix H estimated that most of the GHGs would occur over an estimated 10-year period during which to the licensee would engage in significant demolition and earth-moving activities, as discussed in Supplement 1 to NUREG-0586 (NRC 2002). Vehicular traffic by the workforce during a 40-year SAFSTOR period would additionally contribute GHG emissions. The carbon footprint for a 40-year SAFSTOR period was separately analyzed from the decommissioning activities as provided in Table YYYY-2 of the staff issued guidance in 2011 (NRC 2011).