CY-13-019, Comment (10) of Brantley Buerger of the Connecticut Yankee Atomic Power Company on the Retrievability, Cladding Integrity and Safe Handling of Spent Fuel at an Independent Spent Fuel Storage Installation and During Transportation
| ML13091A008 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 03/18/2013 |
| From: | Buerger B Connecticut Yankee Atomic Power Co |
| To: | Cindy Bladey Rules, Announcements, and Directives Branch |
| References | |
| 78FR3853 00010, NRC-2013-0004, CY-13-019 | |
| Download: ML13091A008 (5) | |
Text
Page 1 of 1 As of.: March 26, 2013 Received: March 18, 2013 Status: Pending-Post PUBLIC SUBMISSION Tracking No. ljx-849q-5rbw Comments Due: March 18, 2013 Submission Type: Web Docket: NRC-2013-0004 Retrievability, Cladding Integrity and Safe Handling of Spent Fuel at an Independent Spent Fuel Storage Installation and During Transportation Comment On: NRC-2013-0004-000l Retrievability, Cladding Integrity and Safe Handling of Spent Fuel at an Independent Spent Fuel Storage Installation and During Transportation Document: NRC-2013-0004-DRAFT-0004 1/! 7/~'/~5 Comment on FR Doc # 2013-00478 7~7/~ 3~j13
- zi Submitter Information
~J-,
Name: Brantley Buerger 171 k.,.
-~
Address: C)r~
362 Injun Hollow Road -] m
'0 C)
East Hampton, CT, 06424 m
Organization: Connecticut Yankee Atomic Power Company General Comment See attached file(s)
Attachments CY-13-019 Response to NRC's Request for Comments - Retrievability SUNSI Review Complete Template = ADM - 013 E-RIDS= ADM -03 Add=
https ://www.fdms.gov/fdms-web-agency/component/contentstreamer?obj ectld=09000064... 03/26/2013
- CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT 362 INJUN HOLLOW ROAD EAST HAMPTON, CT 06424-3099 March 18, 2013 CY-13-019 Cindy Bladey, Chief Rules, Announcements, and Directives Branch (RADB)
Office of Administration, Mail Stop: TWB-05-BO1M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001.
Connecticut Yankee Atomic Power Company Haddam Neck Plant Independent Spent Fuel Storage Installation NRC License No. DPR-61 (NRC Docket Nos. 50-213 and 72-39)
Subject:
Connecticut Yankee Atomic Power Company's Response to the NRC's Request for Comments Regarding Retrievability, Cladding Integrity and Safe Handling of Spent Fuel at an Independent Spent Fuel Storage Installation and During Transportation (Docket ID NRC-2013-0004)
Dear Ms. Bladey:
Connecticut Yankee Atomic Power Company (CY) appreciates the opportunity to provide comments in response to the subject request for comments regarding retrievability, cladding integrity and safe handling of spent fuel at an Independent Spent Fuel Storage Installation and during transportation. CY's responses to each of the subject section questions are-provided in the attachment.
If you have any questions regarding this information, please do not hesitate to contact me.
Sincerely, Brantley B ~erger, PE ISFSI Mankger Attachment CY's Response to the NRC's Request for Comment cc: W. M. Dean, NRC Region I Administrator M. S. Ferdas, Chief, Decommissioning Branch, NRC, Region 1 J. Goshen, NRC Project Manager, Haddam Neck Plant Document Control Desk, Washington, DC
ATTACHMENT TO CY-13-019 CY's Response to the NRC's Request for Comments A. Acceptance of Spent Fuel by a Future Disposal or Reprocessing Facility I. Should an enhanced regulatory framework assume the licensee receiving spent fuel for disposal will be able to site and design a repository for direct disposal of these high capacity canisters without repackaging?
Response
An as yet to be constructed federal nuclear waste repository or repositories will need to be designed to address the current and future inventory of commercial and defense spent nuclear fuel and Greater than Class C (GTCC) waste (SNF/HLW). Currently, there are over 1,700 dry storage systems with SNF/HLW deployed in the United States. At CY, there are 40 NRC licensed, NAC International Multi-Purpose Canister System (NAC-MPC System), dual-purpose (storage/transportation) canisters in dry casks storing spent nuclear fuel and 3 canisters in dry casks storing GTCC waste.
The enhanced regulatory framework should not assume anything beyond the fact that the U.S.
Department of Energy (DOE) has the obligation to take possession and remove all the SNF/HLW stored in the existing canister systems at the CY site under the Nuclear Waste Policy Act and the associated Standard Contract, and that the nation's nuclear waste management program and federal repository facility will need to address a broad spectrum of existing and future dry cask canister systems. CY will pursue re-licensing of the existing dual-purpose systems to ensure that the canisters storing the SNF and HLW can be safely stored and transported during the Certificate of Compliance renewal period. Accordingly, any rulemaking initiative to define specific assumptions associated with the design of a waste repository would place unnecessary limitations and preconditions on the back end of the fuel cycle.
- 2. Should an enhanced regulatory framework assume the repository licensee will be able to handle and repackage potentially degraded/damaged fuel on large production scales?
Response
See CY's responses to Questions A. 1 and A.4.
- 3. What effects, if any, would a canister-based retrievability policy have on a future reprocessing facility?
Response
CY does not believe that a canister-based retrievability policy would have any impact on a potential future reprocessing facility. Any such facilities would be licensed and designed to have the appropriate engineering and quality controls in place to safely handle canistered spent fuel.
- 4. What other factors, such as cost, dose, should be considered?
Response
Recent policy recommendations in the Blue Ribbon Commission on America's Nuclear Future Final Report (January 2012) and the DOE's report, "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste" (January 2013) propose that the spent nuclear fuel and GTCC waste stranded at stand-alone decommissioned reactor sites such as CY be removed and transported on a priority basis to a pilot consolidated storage facility. This consolidated storage Page 1 of 3
ATTACHMENT TO CY-13-019 CY's Response to the NRC's Request for Comments facility should be designed and licensed to handle and repackage potentially degraded/damaged fuel and address any retrievability, cladding integrity, and safe handling capability for spent fuel assemblies. Accordingly, it would be more cost effective and a more efficient location to repackage spent fuel assemblies, if that was required, than the stand-alone ISFSI sites, such as CY, that no longer possess either the capability or the licensing basis to retrieve spent fuel assemblies by normal means.
B. Spent Fuel Retrievability During Storage Given the uncertainty with the material properties of high bum-up spent fuel, it is unclear whether some spent fuel may degrade during storage periods longer than 20 years and subsequent transportation. The NRC would like external stakeholders to provide an assessment of:
- 1. Whether ready-retrieval of individual spent fuel assemblies during storage should be maintained, or
- 2. Whether retrievability should be canister-based.
Response
CY does not possess any high bum-up spent fuel assemblies, so this issue is not directly applicable.
However, CY did can the damaged spent fuel assemblies to ensure assembly-based ready retrieval for storage purposes longer than the initial 20 year license period and during subsequent removal and transportation from the site by the DOE.
CY believes that retrievability can and should be canister based and that any necessary retrieval of SNF assemblies should be performed at a future DOE facility(ies). Spent fuel assembly retrieval or repackaging at sites designed for these tasks is safer than repackaging the material at the CY site, because the CY site no longer possesses either the capability or the licensing basis to retrieve spent fuel assemblies by normal means. The level of effort to establish such a capability at a stand-alone decommissioned site such as CY would be substantial and consolidating that capability at a DOE facility(ies) would be clearly more cost effective from a national waste management perspective.
C. Cladding Integrity
- 1. Should the spent fuel cladding continue to be protected from degradation that leads to gross rupture, or otherwise confine the spent fuel, during storage such that it will not pose operational safety problems with respect to its removal from storage? In particular, provide any explanatory information discussing the additional cost, dose, and effort required to repackage potentially damaged fuel over canned spent fuel, if the prohibition against gross deformation to the cladding were removed and the spent fuel required repackaging (whether by DOE or storage licensees).
Response
CY believes that spent fuel cladding should be protected from degradation to the maximum extent practical during dry storage. However, because of the inherent design of the welded canisters stored at the site, CY does not believe that the canisters should be opened to inspect the spent fuel assemblies for damage or otherwise address concerns with the contents of the canister, except at a licensed DOE facility(ies) that is designed to do so. At stand-alone decommissioned reactor sites, such as CY, the infrastructure and licensing basis for opening and/or repackaging a welded dry storage canister no longer exists.
Page 2 of 3
ATTACHMENT TO CY-13-019 CY's Response to the NRC's Request for Comments
- 2. Should each high bum-up spent fuel assembly be canned to ensure individual fuel assembly retrievability? Additionally, should spent fuel assemblies classified as damaged prior to loading continue to be individually canned prior to placement in a storage cask? In particular, NRC is interested in gathering input on the additional cost, dose, and effort required to place individual fuel assemblies in a damaged fuel can during storage cask loading. Comparison of the upfront cost, dose, and effort to can all high bum-up fuel assemblies against the cost, dose, and effort to repackage potentially damaged fuel at a repository or prior to transport to a repository, may factor into NRC's retrievability policy decision making process.
Response
CY does not possess any high bum-up spent fuel assemblies, so this issue is not directly applicable.
See the CY response to question B above for a discussion of repackaging spent fuel assemblies.
D. Transportation Retrievability
- 1. The NRC would like external stakeholders to comment on (a) whether retrievability should be extended to transportation packages after normal conditions of transportation (similar to the storage requirements), or (b) is it acceptable for high bum-up spent fuel to degrade such that damaged fuel may have to be handled when the package is opened? Extending retrievability to transportation may be important if the U.S. were to move to consolidated interim storage, and if the NRC were to maintain its current definition of assembly-based retrievability during storage.
Response
Retrievability should be at the canister level after normal conditions of transportation. This will ensure that repackaging remains an option, not a requirement, when the DOE transports the SNF/HLW canisters to a DOE facility(ies).
- 2. If it is acceptable for the fuel to degrade, should the package application for a certificate of compliance provide a description of the design and operations of any facilities and methods necessary to handle the damaged fuel (at the facility that will open the package)?
Response
The design and operation of the receiving DOE facility(ies) receiving both spent nuclear fuel and GTCC waste, including the capability for handling and repackaging SNF/HLW, should be addressed in that facilities' license application and approval. The inclusion of these design details in the Certificate of Compliance for the transportation casks would unnecessarily restrict the design of the facility or facilities that receives the SNF/HLW.
Page 3 of 3
Text
Page 1 of 1 As of.: March 26, 2013 Received: March 18, 2013 Status: Pending-Post PUBLIC SUBMISSION Tracking No. ljx-849q-5rbw Comments Due: March 18, 2013 Submission Type: Web Docket: NRC-2013-0004 Retrievability, Cladding Integrity and Safe Handling of Spent Fuel at an Independent Spent Fuel Storage Installation and During Transportation Comment On: NRC-2013-0004-000l Retrievability, Cladding Integrity and Safe Handling of Spent Fuel at an Independent Spent Fuel Storage Installation and During Transportation Document: NRC-2013-0004-DRAFT-0004 1/! 7/~'/~5 Comment on FR Doc # 2013-00478 7~7/~ 3~j13
- zi Submitter Information
~J-,
Name: Brantley Buerger 171 k.,.
-~
Address: C)r~
362 Injun Hollow Road -] m
'0 C)
East Hampton, CT, 06424 m
Organization: Connecticut Yankee Atomic Power Company General Comment See attached file(s)
Attachments CY-13-019 Response to NRC's Request for Comments - Retrievability SUNSI Review Complete Template = ADM - 013 E-RIDS= ADM -03 Add=
https ://www.fdms.gov/fdms-web-agency/component/contentstreamer?obj ectld=09000064... 03/26/2013
- CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT 362 INJUN HOLLOW ROAD EAST HAMPTON, CT 06424-3099 March 18, 2013 CY-13-019 Cindy Bladey, Chief Rules, Announcements, and Directives Branch (RADB)
Office of Administration, Mail Stop: TWB-05-BO1M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001.
Connecticut Yankee Atomic Power Company Haddam Neck Plant Independent Spent Fuel Storage Installation NRC License No. DPR-61 (NRC Docket Nos. 50-213 and 72-39)
Subject:
Connecticut Yankee Atomic Power Company's Response to the NRC's Request for Comments Regarding Retrievability, Cladding Integrity and Safe Handling of Spent Fuel at an Independent Spent Fuel Storage Installation and During Transportation (Docket ID NRC-2013-0004)
Dear Ms. Bladey:
Connecticut Yankee Atomic Power Company (CY) appreciates the opportunity to provide comments in response to the subject request for comments regarding retrievability, cladding integrity and safe handling of spent fuel at an Independent Spent Fuel Storage Installation and during transportation. CY's responses to each of the subject section questions are-provided in the attachment.
If you have any questions regarding this information, please do not hesitate to contact me.
Sincerely, Brantley B ~erger, PE ISFSI Mankger Attachment CY's Response to the NRC's Request for Comment cc: W. M. Dean, NRC Region I Administrator M. S. Ferdas, Chief, Decommissioning Branch, NRC, Region 1 J. Goshen, NRC Project Manager, Haddam Neck Plant Document Control Desk, Washington, DC
ATTACHMENT TO CY-13-019 CY's Response to the NRC's Request for Comments A. Acceptance of Spent Fuel by a Future Disposal or Reprocessing Facility I. Should an enhanced regulatory framework assume the licensee receiving spent fuel for disposal will be able to site and design a repository for direct disposal of these high capacity canisters without repackaging?
Response
An as yet to be constructed federal nuclear waste repository or repositories will need to be designed to address the current and future inventory of commercial and defense spent nuclear fuel and Greater than Class C (GTCC) waste (SNF/HLW). Currently, there are over 1,700 dry storage systems with SNF/HLW deployed in the United States. At CY, there are 40 NRC licensed, NAC International Multi-Purpose Canister System (NAC-MPC System), dual-purpose (storage/transportation) canisters in dry casks storing spent nuclear fuel and 3 canisters in dry casks storing GTCC waste.
The enhanced regulatory framework should not assume anything beyond the fact that the U.S.
Department of Energy (DOE) has the obligation to take possession and remove all the SNF/HLW stored in the existing canister systems at the CY site under the Nuclear Waste Policy Act and the associated Standard Contract, and that the nation's nuclear waste management program and federal repository facility will need to address a broad spectrum of existing and future dry cask canister systems. CY will pursue re-licensing of the existing dual-purpose systems to ensure that the canisters storing the SNF and HLW can be safely stored and transported during the Certificate of Compliance renewal period. Accordingly, any rulemaking initiative to define specific assumptions associated with the design of a waste repository would place unnecessary limitations and preconditions on the back end of the fuel cycle.
- 2. Should an enhanced regulatory framework assume the repository licensee will be able to handle and repackage potentially degraded/damaged fuel on large production scales?
Response
See CY's responses to Questions A. 1 and A.4.
- 3. What effects, if any, would a canister-based retrievability policy have on a future reprocessing facility?
Response
CY does not believe that a canister-based retrievability policy would have any impact on a potential future reprocessing facility. Any such facilities would be licensed and designed to have the appropriate engineering and quality controls in place to safely handle canistered spent fuel.
- 4. What other factors, such as cost, dose, should be considered?
Response
Recent policy recommendations in the Blue Ribbon Commission on America's Nuclear Future Final Report (January 2012) and the DOE's report, "Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste" (January 2013) propose that the spent nuclear fuel and GTCC waste stranded at stand-alone decommissioned reactor sites such as CY be removed and transported on a priority basis to a pilot consolidated storage facility. This consolidated storage Page 1 of 3
ATTACHMENT TO CY-13-019 CY's Response to the NRC's Request for Comments facility should be designed and licensed to handle and repackage potentially degraded/damaged fuel and address any retrievability, cladding integrity, and safe handling capability for spent fuel assemblies. Accordingly, it would be more cost effective and a more efficient location to repackage spent fuel assemblies, if that was required, than the stand-alone ISFSI sites, such as CY, that no longer possess either the capability or the licensing basis to retrieve spent fuel assemblies by normal means.
B. Spent Fuel Retrievability During Storage Given the uncertainty with the material properties of high bum-up spent fuel, it is unclear whether some spent fuel may degrade during storage periods longer than 20 years and subsequent transportation. The NRC would like external stakeholders to provide an assessment of:
- 1. Whether ready-retrieval of individual spent fuel assemblies during storage should be maintained, or
- 2. Whether retrievability should be canister-based.
Response
CY does not possess any high bum-up spent fuel assemblies, so this issue is not directly applicable.
However, CY did can the damaged spent fuel assemblies to ensure assembly-based ready retrieval for storage purposes longer than the initial 20 year license period and during subsequent removal and transportation from the site by the DOE.
CY believes that retrievability can and should be canister based and that any necessary retrieval of SNF assemblies should be performed at a future DOE facility(ies). Spent fuel assembly retrieval or repackaging at sites designed for these tasks is safer than repackaging the material at the CY site, because the CY site no longer possesses either the capability or the licensing basis to retrieve spent fuel assemblies by normal means. The level of effort to establish such a capability at a stand-alone decommissioned site such as CY would be substantial and consolidating that capability at a DOE facility(ies) would be clearly more cost effective from a national waste management perspective.
C. Cladding Integrity
- 1. Should the spent fuel cladding continue to be protected from degradation that leads to gross rupture, or otherwise confine the spent fuel, during storage such that it will not pose operational safety problems with respect to its removal from storage? In particular, provide any explanatory information discussing the additional cost, dose, and effort required to repackage potentially damaged fuel over canned spent fuel, if the prohibition against gross deformation to the cladding were removed and the spent fuel required repackaging (whether by DOE or storage licensees).
Response
CY believes that spent fuel cladding should be protected from degradation to the maximum extent practical during dry storage. However, because of the inherent design of the welded canisters stored at the site, CY does not believe that the canisters should be opened to inspect the spent fuel assemblies for damage or otherwise address concerns with the contents of the canister, except at a licensed DOE facility(ies) that is designed to do so. At stand-alone decommissioned reactor sites, such as CY, the infrastructure and licensing basis for opening and/or repackaging a welded dry storage canister no longer exists.
Page 2 of 3
ATTACHMENT TO CY-13-019 CY's Response to the NRC's Request for Comments
- 2. Should each high bum-up spent fuel assembly be canned to ensure individual fuel assembly retrievability? Additionally, should spent fuel assemblies classified as damaged prior to loading continue to be individually canned prior to placement in a storage cask? In particular, NRC is interested in gathering input on the additional cost, dose, and effort required to place individual fuel assemblies in a damaged fuel can during storage cask loading. Comparison of the upfront cost, dose, and effort to can all high bum-up fuel assemblies against the cost, dose, and effort to repackage potentially damaged fuel at a repository or prior to transport to a repository, may factor into NRC's retrievability policy decision making process.
Response
CY does not possess any high bum-up spent fuel assemblies, so this issue is not directly applicable.
See the CY response to question B above for a discussion of repackaging spent fuel assemblies.
D. Transportation Retrievability
- 1. The NRC would like external stakeholders to comment on (a) whether retrievability should be extended to transportation packages after normal conditions of transportation (similar to the storage requirements), or (b) is it acceptable for high bum-up spent fuel to degrade such that damaged fuel may have to be handled when the package is opened? Extending retrievability to transportation may be important if the U.S. were to move to consolidated interim storage, and if the NRC were to maintain its current definition of assembly-based retrievability during storage.
Response
Retrievability should be at the canister level after normal conditions of transportation. This will ensure that repackaging remains an option, not a requirement, when the DOE transports the SNF/HLW canisters to a DOE facility(ies).
- 2. If it is acceptable for the fuel to degrade, should the package application for a certificate of compliance provide a description of the design and operations of any facilities and methods necessary to handle the damaged fuel (at the facility that will open the package)?
Response
The design and operation of the receiving DOE facility(ies) receiving both spent nuclear fuel and GTCC waste, including the capability for handling and repackaging SNF/HLW, should be addressed in that facilities' license application and approval. The inclusion of these design details in the Certificate of Compliance for the transportation casks would unnecessarily restrict the design of the facility or facilities that receives the SNF/HLW.
Page 3 of 3