ML18016A820
| ML18016A820 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/22/1999 |
| From: | Lochbaum D UNION OF CONCERNED SCIENTISTS |
| To: | Diaz N, Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| Shared Package | |
| ML18016A809 | List: |
| References | |
| FRN-64FR2237 NUDOCS 9902240076 | |
| Download: ML18016A820 (20) | |
Text
UN lON OF CONCERNED SCIENTISTS January 22, 1999 Chairman Shirley A. Jackson Commissioner Nils J. Diaz Commissioner Greta J. Dicus Commissioner Edward 5 fcGaffigan, Jr.
Commissioner Jeffrey S. Merrifield United States Nuclear Regulatory Commission
%'ashington, DC 20555-0001
SUBJECT:
C(JEOKiVX'3GQdPLE OF RISK-DEFORMEDREGULATION
Dear Chairman and Commissioners:
II During the January 11 Commission briefing on risk-informed regulation and during the January 20 briefing on the proposed reactor oversight process, I expressed our concern that the NRC and the nuclear industry are making risk decisions using incomplete and inaccurate data. As a current example, I call your attention to the license amendment application dated December 23, 1998, by the Carolina Power 4 Light Company involving spent fuel storage at the Harris Nuclear Power Plant and the subsequent proposed no significant hazards consideration determination (Federal Regis(er: January 13, 1999, I/ol.
64, No. 8) prepared by the NRC staff.
The licensee and the ~C staff have improperly downplayed the risk associated with the proposed activity. Their risk characterization is wrong. The licensee should be required to resubmit a corrected application and another Federal Register notice issued with a corrected proposed no significant hazards consideration determination.
The error involves the determination made by the licensee and endorsed by the staff regarding the affect ofthe proposed activity, namely placing storage racks in Spent Fuel Pools 'C'nd 'D't the Harris plant, on the probability of a fuel handling accident. From the Federal Register notice:
"The probability that any of the accidents in the above list [a spent fuel assembly drop in a spent fuel pool / loss ofspent fuel pool cooling flow/a seismic event/ misloaded fuel assemblyJ can occur is not significantly affected by the activity itself.... The probabilities ofaccidental fuel assembly drops or misloadings are primarily influenced by the methods used to liftand move these loads. The method ofhandling loads during normal plant operations is not signficantly changed, since the same equipment (i.e., Spent Fuel Handling Machine and tools) and procedures as those in current use in pools 'A'nd 'B'illbe used in pools 'C'nd 'D.'ince the methods used to move loads during normal operations remain nearly the same as those used previously, there is no significant increase in the probability ofan accident,"
9902240076 99021.i
~PDR ADQCK 05000400 PDR Washington ONce:
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January 22, 1999 Page 2 of2 It is precisely this type of "smoke and mirrors" shenanigans that we decried during the briefings. The logic seems proper at face value, but it does not take much effort to show that it is wrong. In Enclosure 1
to the license amendment submiKil, the licensee reported that the total storage capacity ofpools 'A'nd
'B's 3,669 assemblies and that the proposed activity willadd 4;715 storage locations in pools 'C'nd
'.'hus, ifthe amendment is granted, CP&L willhandle pick up and move about twice as many irradiated fuel assemblies as they willifthe amendment is not granted.
Consider for a moment the old game ofRussian roulette using a six-chamber revolver loaded with a single bullet. CPEcL and the NRC staff would apparently conclude that the probability oflosing the game are not increased whether one or two turris are taken because, after all, the same method and the same equipment are used each turn. Their logic is simply wrong. The probability ofa fuel handling accident at Hams willnearly double iftbe license amendment request is granted. This matedat fact contradicts the conclusion of the iiccnsec and the staEE that there willbe "no significant increase in the probability,"
unless doubling the risk is not significant.
Luckily, there's an opportunity to fix the mistake this time. Unfortunately, it's not the first, and probably won't be the last, time this mistake is made. The NRC staff made this same mistake in April 1998 when it allowed the Paducah facilityto continue operating with its risk doubled.
We have no intention at this time of formally intervening in this Harris licensing action. We trust that the NRC staff willtake the necessary steps to have the licensee fix the fundamental flaw in the licensing amendment request before granting it.
Sincerely, CLuia g.
David A. Loch aum Nuclear Safety Engineer
The Sacrffmeilto Bee
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Rnday, ApzB 2, ]9g5 I, OPMON.
eEDH'ORIALS Nolbody knows bow to store Bo!L'lcRrwRstc PcrBMQcntlg:
6 ceo OI earS 0
ByEd Smeloff ITHIZITMfanfare and no public oppositioa,'MUD
'as begun building a facfhty to store high-level nuclear waste next' to the ahuttared Rancho Seco nuclear
'ower plant. Nestled nfnong rolling t pastures southeast ofSacramento, con..
crete nnd steel bunkers nrnbefng erect".
ed to hold canisters fuff ofradioactive t, fuel cfasaiQad nn high-level nu-ear waste for at least the next 25 years and perhaps formuch longer..
Twenty-Gvo years.ngo, wben Rancho Heco was under construction, no one I
would hnvo imagined that BMUD.
would have to buiM n nuclear waste storage facilitythat would end up being, used for'more years than the nuclear<!
powat'lant itaaK In the late 1960s nnd early 1970s, when utilities ware enthusfas or-dering nuclear power plants, they na.
,numed that the! fodernl government would quickly sobs the problem ofnu.
clear waste, But, despite the passage of'.
many federal Iavrs and the expenditure ofnearly $2 billion, agreemcnt on what to do with material that remains lethal
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For as long as 260,000 "yonra has not boon found. The U.S. Departnumt of Energy fs focusing ffa efforts on bury-.
ing U1o wnato in thousand foot deep caverns to bo excavated befovr tho Southern Novndn desert,But that solu-tion fn vehemently opposed by tho state'f Nevada and fn questioned by same of tha government'a'own scientists.
Ed amefcff'is a dfrvator ofthe Soc-nuncnto Municipal UtN<District.
Some in the atomic industry cfnfm
. that the failure of the federal govern-ment to come up with a peru!anent so-lution haa create'd:a crisis that needs immediate legislative redress.
- Others, including the Congressional General
.Accounting Office, are cnHing for n com-
~ prehensiva nnd independent review of nuclear waste: policien and programs before federal laws are revrritten. Mbat; envfronmental orgnnbatfons believe that, given the current level of knowl-edge and technology, a permanent solu-
'ion fs fQusory and that the best wo cnn do is to safely store the waste in a rd trievnble manner.
VifhQe the pohcy debate is heating up, SMUD ie building an Independent Spout Fuel Storage InataQatfon GSFSQ aad purchasing multi purpose casks which can be used both for the trans-portation nnd atornga cf nuclear fuoL Two public hearin'gn wnro held in early 1994 aa part of the environmental re-view ofthe project under the Caliibrnia Environmental Quality Act, ApparaM-'
with tho nuclear reactor now closed, ere waa little public interest ia the specifics of waste storage. Tho multi-purpose casks SMJD has ordered atffl must bo Occnsod by the Nuclear Regu-latory Commission. SMUD estimates that tho coats of )he casks nnd.tho ISFSI wQlbe $16.B mffHon.
Beginning next year SMUD QH
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move the nuclear 'fuel at Rancho Seco from tho spent fuel pool to the ISFSI.
After being cooled in the wats'r for Gvo years, spent nucfeax iuef can be safely removed to dry storage. AtRancho Scco 24 fuel assemblies wiff bo loaded inta each of 22 stainless steel canisters.
Loading into the 1644 feet-long by 6M!-
feet-in-diambter cnnfntera wQf tnfre place under water. Once filled, tho can-ister vtfQ bc removed from the pool nnd
'ta Hd wofde<i abut. The canister will then be inserted into a 79-ton, multi-purpose cask with special ahfelding for gamma rays nnd neutrons.
The cnak vtfffbo loaded onto a specially designed trailer nnd transported several hun-dred s to the IBFSI, where n hy-dra!fifa ran1 willpush 018 cnnfsfor out ofthe cask and, insert fthgixontaffy In-to a steel-lined 'concrota"storage mod-'le.
It is anticipated that alf the fuel vriflbe movod into dry storage by April i997.
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HR multi-purpose cask can be reused to transport additional canisters. It'can also be used as a storage "overpack" to contain a leak-indcanister. The abiHty to provide star aga for a damaged canister is required by'he Nudaur Regulatory Commission so that SMUD can dose the spent f'uel pool once aH the fIoel is removed. Aban.
doning the pool willsave SMUD about 010 millionper your.
The storage module at Rancho Saco is designed to hold the canisters for at least 50 years, Eventually tha connote buzzkars.nt tho storage sita will.start to ezode, and ifthere is stQl spent fitMIat the site itwould have to be transferred to a new sat of bunkers. The greatest risk of atorizlg flzel at sites 1Uze Rancho Seco is the potential for terrorism. A powerful bomb placed at a storage site could result ln the release ot'aPiution into the environment. Much of tha an-nual $1,6*mQHon budget for tho fsdlity wQ1 be spent on high level sacuritty.
Four other nudear power plants have already moved soma oftheir spent fuel into dry storage. Most other utiH-Ues w91 need to build similar fhciHtios
'oon. That half beezi made eusiez by a recant 'court ruling that eliminates the need for aapurata Nudear Regulatozy Commission hearings for utilities that use already Hcenscd casks and canis-ters Still, the fadHties are'subject to state environmental laws.
o Dry storage is generally'acknowl-edged to be safer than storage in a spent fuel pooL Dzy storage requires no uctivo mechanical systems that need to'e maintained und that can break down. All'hat is routinety required is security and monitoring. The multi-purpose casks ara available for fuel re-moval in any abnormal circumstance.
The Nuclear Regulatory Cmnmission estlmatea that Caaka IMe bS safely used'or interim storage for 100 years. And it's zala'tively inexpensiva, At $1.6 mil-lion per year, SMUD could store spent fuel at the ISFSI for 50 yours for what it cost to operate Rancho Seco for six months.
HILZ SMUD bas been able l to craft a temporazy solution for Rancho San's wastes, ze-I cent events have demonstrated,
- again,
'ow difiicultnational nudear waste poHcy has become. Several sdentists at the Loe Alamos National Laborutozy hypothesized 'that burying nuclear waste underground might trigger nu-dear explottione contaminating ground, water or evan releasing radioactivity into the ntnoaphara.
The controversy some of their col-leagues sharply disputed the possibility comas on top of the recent discovery by the Depaztment of Energy ofradio-
'ctive water - created by above ground.
bomb tests at depths of 1;000 feet be-
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low the Nevada desert. This Qnding in-dicates, accozdmg to the state ofNeva-da, that water can travel much more rapidly at the site of the proposed na-tional nuclear repository then previ.
ously assumed. Water is the nemesis of safe, long-tenn waste storage. Federal guidelines for a perinanent repository, require that no water flowinto the site
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in loss tha'n 1,000 yeaza.
Since the federal government has been planning to buzy spent fuel deep
~ in the Nevada dosert by 2010, these new controversies threaten to further delay this already troubled project.
Many, including the General Account
'ng Office, had seriously questioned how realistic tho 2010 target was avon before these latest revelations.
Even ifthe Yucca Mountain site in Nevada were to be built'on time, utili-ties wouM still have to store nudear
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waste on-site untQ it could be shipped
'ut, Since there is already a backlog of 30,000. tons of'nudssr fuel with'more
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being created every year, utilities would huva to wait in line before their waste could be shipped to Nevada. For SttttD the oooueet that all the Stet i
could ho tuoeod out ol Saocatueuto l
would be 2024, 7or other utiHties with
'oro waste itwould be even longer."
All nudear utiHties currently keep spent nudear fuel in small.covered pools next to tha power plants. Tha wa-ter in tho pools'keeps tho fuel cool and
, absorbs neutrons that can initiate a nu-clear chain zeaction. Spent flialpools at nudear reactors around tho country are rapidlyrunning out ofapace.
There are deca.alternativea fm iitQi-ties with limited underwater storage capacity. They can dose their reactors, build dzy storage facilities. next to their t power plants or Gnd someone else to take the spent fuel and storo it. Besides I
SMUD, four other utilities have dosed large oparatlzhg audaar reactozs, but.
none because of spent fuel stozage problams.
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HE ONE utilitythat has so far bean faced with the prospect of dosing u nuclear plant due to a lack ofsuch storage ia Northern States Power. The Mnnasota utility, which operates two nuclear planta on an is-land on tho upper Mississippi River, would have run out of spuco in ons of its spent lhel pools by 1996. Plans to bufl~dan on-site storage EaciHty next to the plants were legally challenged by the Mdewakanton Tribal Council, whoso lands were next to the facQity, and. by local environmental groups, They argued that state law required the state legislature to license any
'1ong-term" nudear waste facility. A state court found that because no per-manent nudoar repo'sitory or other long-tenn storage site existed that the facility should be. considered "lang-tenn,"
That decision led to a bitter, drawn out battle last year in the MInnasotu Legislature. In the end, the Legisla-ture, by one vote, approved enough
'torage capacity to allow the plants ta run another seven years but only after the utUity agreed to spond over half a bQlion dollars constructing savoral largo<cele wind and biomass energy prolecta. Aftet'hat narrow victory..
Northern States Power snd a handful I
of'other utiities began looking for an-other place to dump their nuclear
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waste. preferably somawhere far away from their customers and pesky state'egislatms.
- Racantly, these utiTities began dis-cussions with the Mescnlero Apaches of southern New Mexico about tha poasi-biHty of buQding a storage facility an their reservation. The issue has deeply divided the hhscaieros.A. Januazy elec-tion, in'which 6h percent of the Mescsieros voted against going into the nudear waste business, embarrassed the tribal laadazsMp, which supported the proposal. A socond vote was sched-uled six weaks later. Using what New Mexico Attorney General Tom.Udall called strong-arm tactics, the tribal leadership successfully reversed tho initialvote. Since the New Mexico Leg-islature strongly opposes tho facQity, the tribe's decmion promises to crauta u txtnfzontation between tha issues ofIn-dian soveroignty and the. state's rs>>'ponsihiHty for pubHc health and safe-tyo
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Several 'members of Congress. have Introduced legislabon to authorize the construction of an interIm facility to store hiffh-level nuclear waste in Neva-da. Lending tho charge far sanding the waste to Nevada fs Louisiana sea. J.
Bcanett Johnston, former chairman of tho Senate Energy Committeo and aovr ranking minority member. Johnston has been one of the top recipients of:
campaign contributions from nuclear industry political action coauafttses for the past decade.
Johnston wna iastzumentnl in nar-rowing down thfe Hst ofpotential sites for the high-level nuclear wnste reposi-tory to Yucca Mouatsfa in Nevada, In
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1986 the Reagan administration aar rowed the search to three potential
'ites in %'ashiagton, Texas and Neva.:
da. The nextyear Johnston camel leg islatfoa that dcsfgnated Yucca Moun-
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tain as thq.only site.
BE GENI2hK Accounting Of-
'ice recently reported that dur-ing the Grat 10 years oftho pro-
- m. the estimated cost ofdisposing of'gh.level nuclear waste Increased 6am $26 bilHon to OSO MHon. Part of, the reason for the increase has been
'he high cost of maintaining an in@a-!
structuro nfcontractors nad faciHtfes to
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support the ecioatUfc and technical ac-tivities. But mainly it fe due ta the in-,
creased complexity and the expanding timetabls ofthe project. So far, the util-ftfes hive contributed nb'out $8 bfHIon to the had. SMUD'a contribuUon bne
, boon about $40 milHoa.
The GAQ caHed for an independent, revievr of the dhposal program. Among
.'he issues recoauneaded for study nre
.'the interim storage of vraste, the ade-'uacy of thc.program's AIndiag, the management and organhatfon of the program nnd repository ~i'ect and the approach to regufatiag the program."
But with only two gears left before ho retiree, Johnston an't Interested in studfes, He hna a new Ml that. would authorize the construction of an inter.
fm storage facilitor at Yucca Mountain at "tho earliest practicable date", along with the raff lines needed to tzanspozt the spent fuel to Nevada.
Spending huge sums an bufidfag aa infrastructure sad. thea shipping nude-nr waste to Yucca Moiintsia would vir-
'unUy foreclose serious consideration of '.
other methods of mnnnging nuclear, vraste. Thfs could end up being n very.:
costly mistake if Yucca Mountain proves to bs a geologicnHy unsuitable site.
tenfold.
Transmutation of radioactive vrasts,-
like. turnfag lead into gold, may offer a
'echnical sofutioa in the lang run. Re.
searchers at the Los Alamos National Laboratory in New Mexico and at the European Laboratory for Particle Phys-ics in Geneva propose shooting a proton beam into ~adioactfye atoms, thereby converhng them into'less lonpUved iso-:
topes or even aon.radioactive eletnents.
if Cnzzsatfy, no accelerator can deliver a beam ofthc required intsasity. Howev-er, funding for n prototype could come horn the Department of Energy or the
'European Union. Even ifthe technical challenges and costs of transmutation could be oveivome, thus would stiH be some remaining wastes that would need to be managed,
. For the time being high-level nuclear for the retnevablo placement of waste in the reposftoty only for the fust 100 years, The Mea fs that ifproblems de-velop at the site, the aging canisters fuH of nuclear waste can be UAed out from tho 1,000-foo&eep caverns and:
stored above ground. How much it vrould cost to build,the repository, Mlit up vrith nuclear waste and thea empty itlater an is anybody's guess.
No other country in the worldhns es-tnbUshed a site for permanent dfspoanl.
Besides the Uaftei Gtntes, only Germa-ny hss narrowed down hs options to one site.
Ia 1982 Britain approved a 50.year
'torage plan and is currently oxpforiag; several options with the earhost target t
for waste burial In 2MO, France is studyitig three sites withn finalone aot.
to be selected uatQ 2006 and opening.'aste wUI have to be managed at nu-clear power plaata. That it can be done snfofy, as 8MUD is'doing, should give the federal government time to com-mission an iadeperidsnt, comprehen-sive evaluation af long term nuclear waste poHcies and programs. Such a re-view could save U.S, taxpayers billions
'f doUsrs and prevent us 6am passing on to future generations irreversible
'nd regrettable decfsfbns, up'possibly 10 yearn later. The Nether-lands bss approved interim storage for 60 to 100 years with the year M40 be<<
'ng tho earliest date itviouId have a re-'ository.
Japan is conducting several studies aad fs building an undergroudd, rerieazdi fncflitywith ahfaa. They doa expect to bury waste until at least l 2020.
EEP 6EO~Oburfal has be,".
come, nlmost by default, the'.
favored option for disposing of.",
high-level nuclear waste. 'Qther ideas i
.for vraste disposal - such as burying it/i under Antarctic ice, foiectfag lt ia the~
ecnbcd or shooting it into outcr apace 4, have been rRlected aatoo risky,
. Bepzocesefng wntrte by separating" out pltitoniunz and uranium for zeustt>>
vras o'ce thought to be the preferred method of handling spent fueL But in".
19VV, President Car~ cancelled U.S.".
efforts to reprocess ftief from cfvlffsa';
nuclear'reactors,because of concern about the proUferatfon ofnuclear weap.
ons materials. %bile the Reagan ad>>
mhfstzatfon zesdnded the ban on re-.
proccssing, the United States nuclear sndtisfzy hns shown HNe iafsrsst. In its revival because of the "economics.. The i separated plutonfum and uranium are
'ar aioze costly than the uranium ob-"
tained loom muung, In fact, plutoai
$s pfUng up at European reproccsafag.
facilftios because of the lack of a mar-ket, crentiagpzsssuze to cfoeo them, Thy ms s of shipping waste From qp, Reyrocessing goes not eiiminnt rn differ<<tancien plants <<fsbcrossing dfoactivB wQstB Rllg thB need fol'hsf&"
43 sf N, to minappropnate ate~
'. Storag,,%hfls zepzocessing reduces 1
storage facility pales la comparison 'he mostpotentcompoaentof wants ft:!
with another Propose fm Yucca Moua-increases its overall Ruantit nearf tain. Some nuclear utilities are calling
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Csnfsters contafnlng hfgh-level nuclear waste willbe stored, for at least the '.
I)ext'25 years, In dry storage vaults that wlH look like this at Rancho Seco.
Upper r.: a canister with containers for spent fuel rods. At battotn; a trans porter that carries the canister from the cooling pond to the storage vault C
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gi Rancho Scca IIas a ghost%own amblenoe thoso aya.
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