ML14049A102
| ML14049A102 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 02/04/2014 |
| From: | Marc Ferdas Division of Nuclear Materials Safety I |
| To: | Dubois P Jones River Watershed Association |
| References | |
| Download: ML14049A102 (3) | |
Text
1 Junod, Rebecca From:
Ferdas, Marc Sent:
Tuesday, February 04, 2014 3:11 PM To:
pine@jonesriver.org
Subject:
NRC Response to Questions By Pine duBois ThankyouforyourparticipationinthewebinarthatoccurredonDecember12,2013associatedwithdrycaskstorageof nuclearfuelatthePilgrimNuclearPowerPlant.IamwritingyoutoaddressseveralquestionsyouprovidedtotheNRC afterthewebinar.Answerstomanyofyourquestionscanbefoundintheslidesthatwereusedduringthe presentationandinthemeetingsummarythatwasissuedbytheNRCafterthewebinar.Thesedocumentscanalsobe foundinourelectronicdocumentsystem,AgencyDocumentsAccessManagementSystem(ADAMS),byreferencingthe followingAccessionNumbers:ML14015A170andML14008A027.
Inaddition,inyouremailtotheNRCyoucitedNUREG1536,StandardReviewPlanforDryCaskStorageSystems.This NUREGisutilizedbyourtechnicalreviewersduringthecertificationandapprovalprocessofadrycasksystem.As discussedduringthewebinar,PilgrimwillbeconstructingandoperatinganIndependentSpentFuelStorageInstallation (ISFSI)undertheprovisionofagenerallicense.Agenerallicenseauthorizesanuclearpowerplantlicenseetostore spentfuelinNRCapprovedcaskspertheiroperatinglicenseunder10CFRPart50.Licenseesarerequiredtoperform evaluationsoftheirsitetodemonstratethatthesiteisadequateforstoringspentfuelinadrycasksystem.These evaluationsmustshowthatthecaskCertificateofCompliance(CoC)conditionsandtechnicalspecificationscanbemet, includinganalysisofenvironmentalconditions,suchasearthquakeeventsandtornadomissiles.Pilgrimwillbe performingasitespecificevaluationinaccordancewith10CFR§72.212toensureitcomplieswiththeconditionsofthe casksCoC.TheNRCsubjectsPilgrims10CFR§72.212evaluationtoaninspectionpriortoloadingofthespentnuclear fuel,aswellasinspectionsoftheconstructionandoperationsoftheISFSI.TheresultsoftheseinspectionsbytheNRC willbedocumentedinpublicallyavailableinspectionreports.Thelicenseemustalsoreviewitssecurityprogram, emergencyplan,qualityassuranceprogram,trainingprogramandradiationprotectionprogram,andmakeany necessarychangestoincorporatetheISFSIatitsreactorsite.
AnNRCapprovedcaskisonethathasundergoneatechnicalreviewofitssafetyaspectsandbeenfoundtobeadequate tostorespentfuelatasitethathasbeenevaluatedbythelicenseetomeetalloftheNRC'srequirementsin10CFRPart 72.TheNRCissuesaCertificateofComplianceforacaskdesigntoacaskvendorifthereviewofthedesignfindsit technicallyadequateandusestherulemakingprocesstocodifythecaskCoCconditionsandtechnicalspecificationsin 10CFR§72.214.
AdditionalinformationondrycaskstoragecanbefoundontheNRCwebpageat:http://www.nrc.gov/waste/spent fuelstorage.html;andinformationconcerningactivitiesassociatedwithNRCactivitiesinresponsetotheMarch2011 FukushimaeventcanbefoundontheNRCwebpageat:http://www.nrc.gov/reactors/operating/opsexperience/japan dashboard.html.
Marc S Ferdas Chief,Decommissioning&TechnicalSupportBranch(NRC/RegionI/DNMS) 6103375022(work) 4844018160(cell) marc.ferdas@nrc.gov
From: Sheehan, Neil Sent: Monday, December 16, 2013 4:11 PM
2 To: Ferdas, Marc; Benner, Eric
Subject:
And some post-webinar questions
At the risk of appearing hysterical--here are my immediate followup questions:
- 1. Who will own the ISFSI and what are the triggers for changes in ownership.
- 2. Who will be responsible when Pilgrim ceases operation, and when will the Fed (DOE?) take possession and responsibility for monitoring etc.
- 3. Relative to the LOCATION of the storage Pad between 125 and 350 feet of the coastline of Cape Cod Bay, and the HEIGHT of the pad putting the vents within the likely range of storm surge flooding, ice, marine debris, and ultimately pose and unnecessary and high risk challenge to workers on site to maintain clear surrounds and monitor the casks: Why would NRC permit an installation of this nature at this location? Pligrim in its Feb28, 2013 vulnerability response claims it is a dry site--how can Cape Cod Bay be missed by an inspector's gaze on site?
- 4. Putting infrastructure at that elevation and proximity to the coast is reckless lunacy and a violation of common sense and the public trust--so the question is what is the REASON? Are you ultimately relying on a fail-safe disposal at sea? If a vent is flooded with water and the other vent is bringing in air--do you really think that the cask will be cooler? Maybe for the first 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s--but what if you can't get the flood water out in 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s--after all the Atlantic Ocean is pretty big--will the cask get warm? will you be able to monitor it? Are you even paying attention to where this facility is located??
You cited your rules, and your rules refer to reports on Sea-level rise noted here: http://pbadupws.nrc.gov/docs/ML1006/ML100601201.pdf, page 57 Sea-level rise A significant fraction of Americas energy infrastructure is located near the coasts, from power plants, to oil refineries, to facilities that receive oil and gas deliveries.
Rising sea levels are likely to lead to direct losses, such as equipment damage from flooding or erosion, and indirect effects, such as the costs of raising vulnerable assets to higher levels or building new facilities farther inland, increasing transportation costs.
The U.S. East Coast and Gulf Coast have been identified as particularly vulnerable to sea-level rise because the land is relatively flat and also sinking in many places.
NUREG 1536 8.4.3 Environment (Priority - as indicated)
(MEDIUM Priority) Generally, the ISFSI site with associated storage canisters are subjected (long-term) to a mild atmospheric environment. Twenty or more years of ISFSI operational experience has verified that no significant corrosion issues generally exist during storage.
However, note whether or not the site or potential site is a coastal marine location. Additional corrosion prevention measures may be applied when the ISFSI is located in a coastal marine 8-7 environment. Detailed review guidance is provided in 8.4.6 Coastal Marine ISFSI Sites-Material Selections.
(LOW Priority) Underground structures require additional consideration due to soil corrosion issues. Additional guidance is provided in 8.4.14.3 Omission of Reinforcement.
8.4.6 Coastal Marine ISFSI Sites-Material Selections (MEDIUM Priority)
At coastal marine locations, the heavy salt drift can significantly accelerate the normally slight
3 atmospheric corrosion rate to unacceptable values of some canister storage module designs, such as those that employ carbon steel structural elements inside the canister storage module.
Experience has shown ordinary grades of structural steel (such as A-36) withstand the nominally dry interior environment of the canister overpack very well over a 20 year operational period.
To address the increased atmospheric corrosion rates found at coastal marine (salt water) sites, some applicants have specified the use of 0.20%, minimum, copper-bearing steels, or, weathering steels such as Cor-Ten. The Kennedy Space Flight Center has collected data which has demonstrated the benefit of copper-bearing and weathering steels for significantly reducing corrosion at coastal marine sites. Therefore, for coastal marine ISFSI sites, the use of copper-bearing steels (containing a minimum of 0.20 percent copper), or weathering steels, may be necessary. Such steels are covered by ASTM A-242 and A-588, and supplemental requirements to ASTM A-36, and/or other specifications.
Other corrosion control measures may be employed, provided adequate documentation is supplied to demonstrate efficacy.
Coatings may be specified to alleviate the coastal atmospheric corrosion issue. However, unless supporting data is available to demonstrate the predicted coating life, the coating must be periodically inspected and maintained.
- 5. Please provide the document that address these requirements at Pilgrim
- 6. Where is the site specific conditions REVIEW at Pilgrim relative to climate change--in keeping the President's order :
The Federal Government must build on recent progress and pursue new strategies to improve the Nation's preparedness and resilience. In doing so, agencies should promote: (1) engaged and strong partnerships and information sharing at all levels of government; (2) risk-informed decisionmaking and the tools to facilitate it; (3) adaptive learning, in which experiences serve as opportunities to inform and adjust future actions; and (4) preparedness planning.
- 7. I am anxious to receive the answer to the question relative to dewatering of the site and the testing for tritium within the pad footprint. There is no approval to discharge tritium anywhere on site. The on-going monitoring by MA DPH shows the presence of tritium--waiting for decommissioning to de-contaminate the site while allowing radionuclides to continue to migrate into the bay is a violation of the public trust, at least. What is the de-contamination plan?
I look forward to your responses.
Thank you.
Pine duBois Executive Director Jones River Watershed Association Jones River Landing 55 Landing Rd.
Kingston, MA 02364 781-585-2322 www.jonesriver.org pine@jonesriver.org