ML19249E118
| ML19249E118 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 01/26/1979 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17326A257 | List: |
| References | |
| FOIA-80-381 NUDOCS 7909260397 | |
| Download: ML19249E118 (33) | |
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Statement of Harold R. Denton, Director Office of Nuclear Redctor Regulation V, S. Nuclear Regulatory Comission Before the Comittee on Interior and Insular Affairs U. S. House of Representetives January 26, 1979 O,
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dr. Chairman, members of the Committee, I appreciate this opportunity to report on the actions taken by the Commission to avoid a possible shortage of spent fuel storage capacity.
My testimony will summarize the results of individual licensing reviews of proposed fuel pool expansions at power reactors, the status of proposed spent fuel t ansfers between reactors, and the status of proposed regulations governing the storage Your letter of of spent fuel in an independent storage installat n.
January 11 asked eight specific questions and answers to these questions are attached to this testimony.
Let me first give you an overview of the storage situation.
Spent fuel assemblies from light-water reactors consist of highly radioactive fuel pins held together in a geometric cluster and are typically sixteen to Fuel asssmblies from boiling-water reactors and eighteen feet long.
pressurized-water reactors differ slightly but the basic components of each are the fuel pins. A fuel pin of either type is a section of metal tubing, approximately one-half inch in diameter and hermetically sealed, filled with ceramic pellets of uranium oxide. To date, no power reactor has had to cease operation because of a lack of storage space for spent A total of approximately 20,000 scent fuel assemblies have been fuel.
About generated by the past cperation of licensed power reactors.
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2-15,000 of these* assemblies are presently stored in power reactor pools, and the remaining 5,000 assemblies art either stored in away-from-reactor pools or have been reprocessed.
Approximately Many 5,000 additional assemblies will be produced during this year.
utilities have accomplished or proposed modifications which will provide sufficient storage for up to ten additional years of plant Some existing storage racks are now full, however, and operation.
some pools are approaching the limits of their physical capacity.
Even if all pending proposals to provide additional storage are approved and implemented, at least one facility could have a spent No federal f acility fuel storage problem within the"next 3 years.
There for interim or ultimate storage of spent fuel exists today.
is, however, a development program under way within the Department of Energy which has been reviewed by an Interagency Review Group established by the President. We understand that the DOE plan under development could result in storage facilities by 1983/1984_and a geologic repository by the early to mid 1990. If it appears that 1
no Federal involvement is forthcoming in interim storage facilities, there would likely be sufficient incentives for industry to provide the necessary interim capacity.
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. Current NRC assessments regarding the environmental impacts of reactor operation consider the so-called once through, or no repro-There is no assessment of long-term storage of cessing fuel cycle.
spent fuel at reactor sites. The implicit assumption has been and continues to be disposal at a government-owned facility. Thus, it is clear that for continued licensing of nuclear power plants to proceed in the next decades it is necessary to develop and implement a waste management and disposal policy which is capable of dealing with the various forms that the waste might take.
The Commission.has, as a matter of policy, linked continued reactor licensing to ultimate implementation of a safe waste disposal program.
In 1977, the Commission in denying a petition requesting a moratorium on new reactor operating licenses, said, "The Commission would not continue to license reactors if it did not have reasonable confidence that the wastes can and will in due course be disposed of safely".
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. LICENSING REVIEW P.ROCEDURES Prior to 1975, spent fuel was stored under water in racks at reactor plants that were not built with any particular attempt to maximize the storage capacity.
About five years ago, licensees of nuclear reactors began to recognize that they could not store fuel for only a short time and subsequently have it reprocessed as they originally had planned.
As a result, they have taken, and are continuing to take, positive steps to provide additional storage capacity at individual plants which will permit continued reactor operation. The regulations do not. require any particular storage capacity but 1-1/3 cores was the standard practice.
The maximum potential increase in storage capability is limited by physical space considerations. Safety analyses for proposed increases in storage capacity have shown that, in general, these increases have a minimal impact on the original design or accident considerations.
Spent fuel from operating reactors has been safely stored in a water environment for up to twenty years and reasonable extrapolations indicate that it can be safely stored for the life of a nuclear power plant.
On September 16, 1975, the Commission announced in the Federal Recister (40 F. R. 42801) its intent to prepare a generic environ-mental impact statement on handling and storage of spent fuel from
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. This notice also announced the Commission's light water power reactors.
conclusion that it would not be in the public interest to defer all licensing actions associated with fuel storage modifications pending Because of completion of the generic environmental impact statement.
the potential high public interest and the significance of proposals to increase spent fuel storage capacity, all fiftg of the proposals received to date have been announced as Notices in the Federal Recister.
The majority of the proposals have not resulted in public comment.
However, to date there have been requests for public hearings on 12 of the proposals. Hearings have been completed on five of the pro-posals and the Atomic Safety and Licensing Board has authorized the Two of these adjudicatory decisions have been proposed expansion.
appealed to the United States courts of appeals.
Hearing dates have not been established on the remaining seven proposals.
When a proposal is made by a licensee to increase the spent fuel storage capacity and after public notice of receipt of the proposal, the staff reviews the proposal and prepares (1) a safety evaluation report, and (2) an environmental impact appraisal. The Commission has identified factors that must be weighed in the environmental impact appraisal in in addition to the normal cost-benefit balance and other issues.
In our safety review, the proposed design is reviewed against various NRC
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. Regulatory Guides,.the NRC Standard Review Plan, and industry standards.
Nuclear and thermal-hydraulic aspects of the review include the potential for inadvertant criticality, the ability of the heat removal system to maintain sufficient cooling, and the consequences of. credible accidents.
Mechanical, material, and structural aspects of the review cover the capability of the fuel assembly, storage racks, the sp'ent fuel pool, and the spent fuel cooling system to withstand the effects of natural phenomena, such as earthquakes, tornadoes, and floods, themal and corrosion effects, The environmental aspects of the review and normal operating conditions.
include the potential thermal and radiological releases from the facility
'Jnder normal and accident conditions, the potential for occupational radiation exposure, potential accident conditions, alternatives to the proposed action, and the cost-benefit balance.
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I EXISTING ONSITE STORAGE The first proposal by a licensee for increasing the onsite storage Since then, there have capacity was submitted to the NRC in late 1974.
been a total of 50 applications. These include 6 that are second-time The first-time applicacions provided increased storage modifications.
capability for 60 of the 67 light water power reactorsfoperating today.
The average proposed capacity is up about a factor of three - from a Since nominal initial 1-1/3 cores to a total capacity of about 4 cores.
reactors are operated with fuel cycles that discharge 1/4 to 1/3 of a core per year, each additional full-core storage capability provides 3 to 4 more years of spent fuel storage. The combined total available space, authorized and proposed, is equivalent to about 3 cores for each operating reactor. Thus, from an overall view point, if all this storage capacity were utilized by inter-facility transfers of fuel, continued reactor operation for 9 to 12 years would be possible before the reactor storage pools would be filled.
Almost all utilities with plants now undergoing NRC review for an operating license have proposed a storage capability substantially The greater than existed at the construction permit review stage.
increased storage ranges from 2 to 6 cores, which provide a range f rom about 6 to 18 years of storage capability.
If reactors currently c:erating, and those now under review for an cperating license, utilize
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. inter-facility tragsfer, there is sufficient storage until the late 1980's.
The full cooperation and sharing of storage capacity of these 90 units is an idealized assumption that is not likely to be realized.
In 1977, the NRC began maintaining a status summary o'f spent fuel storge capacity at each operating facility.
Information is being updated by licensees,and is reported monthly in the NiC publication,
" Operating Units Status Report," NUREG-0020. The information shows that the pools at the Lacrosse and Surry reactors are now filled, Pools and that the pool at the Kewaunee reactor will be filled in 1979.
These at Oconee, Point Beach and Big Rock reactors will be filled in 1980.
fill dates were estimated, based on a discharge rate of about 1/4 to 1/3 of the core into the pool at each refueling.
Of these reactors, proposals have been filed by all plants, except Big Rock, either to increase We understand that on-site storage or to ship fuel off-site for storage.
Big Rock intends to increase the on-site storage, but we have not received a proposal. For the situations cited above, only the proposed storage of Oconee fuel at McGuire involves shipment of spent fuel from cne reactor site to another reactor site. This proposal is the subject of a current However, we have previously approved storage of spent fuel from hearing.
the H. B. Robinson facility at the Brunswick facility and have applications under review involving the Dresden and Quad Cities facilities.
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_g-While the technology for fuel storage and associated handling systems is well developed, the safety record indicates a need for continued careful scruti ny. The most serious event during the past 10 years occurred during a facility's first refueling. This incident resulted in one worker receiving 25 rem and a companion receiving about 17 rem' during entry into an area adjacent to a fuel transfer tube containing newly discharged fuel.
About 20 events involving dropping, tipping, or mishandling of spent fuel assemblies have occurred. None of these events resulted in About 6 appreciable personnel exposures or releases of radioactivity.
other events, including pool liner leaks and instrument line failures, resulted in small amounts of pool water being inadvertently released to the environment. The maximum resulting release was less than one percent of license restrictions on liquid releases.
Severai f acilities have experienced swelling problems with the materials used to f abricate fuel storage racks. Gases were being generated within sealed portions of the racks requiring holes to be drilled to vent the The State of gases and prevent the buildup of high internal pressures.
Minnesota (the Minnesota Pollution Control Agency) has petitioned the NRC to prohibit the use of such racks at the Monticello Plant and has requested a hearing on the matter. The staff is currently reviewing the request by the Minnesota Pollution Control Agency.
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. While. fuel movemen$s within a pool to accommodate increased storage would increase somewhat the potential for occurrence of fuel mishandling events, such activities are not likely to increase the frequency or severity of the types of reported events.
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. SPENT FUEL TRANSPORTATION The transportation of nuclear fuel and waste is regulated principally by the Department of Transportation and the NRC. The regulations cover both shippers and carriers and provide protection to transport workers and tae general public from the hazards of radiation.
To develop and implem'ent consistent regulations and avoid duplication, DOT and NRC have partitioned their regulatory responsibilities under a Memorandum of Understanding.
In general, DOT is responsible for regulating safety in transportation of all hazardous materials (includ-ing radioactive materials), and NRC is responsible for regulating safety in receipt, possession, use, and transfer of byproduct, source, and special nuclear materials.
00T is primarily concerned with the conditions of carriage and NRC is primarily concerned with the evaluation and certification of certain package designs.
Primary reliance for safety in transportation of radioactive material is placed on the packaging. The standards established in the DOT and NRC regulations provide that the packaging shall prevent the loss or dispersion of the radioactive contents, provide adequate shielding and heat dissipation, and prevent nuclear criticality under both normal and accident conditions of transportation.
Both normal conditions of transcortatien and postulated accident conditions tnat must be considered are specified in the regulations.
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__ Within the limitations of the regulatory standards, radioactive materials, including spent fuel, may be safely transported in routine No special commerce using conventional transportation equipment.
restrictions on the speed of vehicles or routing are c,onsidered necessary to assure safety. In a recent reexamination of its regulations on packaging and transportation of radioactive materials, the NRC staff concluded that the environmental impacts of nomal transportation and the risks attendant to accidents involving radio-active material shipments are sufficiently small to allow continued shipments by all codes and that no changes to the regulations are needed at this time. A supplemental study is being prepared which It will focuses on transportation impacts peculiar to urban areas.
consider facets unique to the urban setting such as high population density, diurnal variation in population, shielding effects of buildings, and effects of local meteorology on accident consequences.
At present, six power reactor spent fuel cask designs are certified by These six designs include four truck casks and two rail casks.
NRC.
Two other rail cask designs are now being reviewed for certification.
The transportation safety regulations of NRC and DOT are consistent with those of the IAEA.
Imports of spent fuel to the U. S. are subject to revalidation by the DOT, as the U. S. National Competent Authority, of
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. the cask design approval certificate which the foreign shipper has obtained fr m his national competent authority. Under our present " Memorandum of Co derstanding" with DOT, the cask design would be reviewed by the NRC We are presently engineering staff before DOT provid'es that revalidation.
considering a change to that Memorandum of Understandinc which would elimincte the cask' review by NRC for most import shipoents because it is essentially a duplicate of that done by the foreign national Under this competent authority, using the same package standards.
changed procedure, 00T would, for import shipments, screen the cask If that screening design as described in the approval certificate.
raises any question about the safety of the cask design, an NRC detailed review would be provided.
In the absence of questions however, D0T would revalidate the cask design approval certificate on the basis of its screening of the foreign safety review, but limiting the. revalida-tion to import and export shipments.
Imports of spent fuel to the United States are subject to NRC import NRC has thus far licensed only relatively minor imports of licensing.
foreign research reactor spent fuel for re,;rocessing and extraction of In October highly enriched uranium by the Department of Energy (00E).
1977, the United States announced that, in conjunction with a program for the storage of domestic power reactor spent fuel, it was prepared
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One additional matter that relates to transportation involves the Price-Anderson coverage for spent fuel.
Irradiated fuel going to a storage f acility from an indemnified licensed reactor is cover $d by the insurance and indemnity protection of the reactor from which the transportation originated. Under the current regulations, however, in a situation such as the shipment of foreign spent fuel to'an independent spent fuel storage installation that is not indemnified, there would be no transportation coverage under the Price-Anderson Act.
Although nuclear dability insurance for up to 5160 million can now be purchased, government indemnity would not apply to this shipment unless the Commission were to extend Price-Anderson coverage to the storage facility, or some other method was devised to provide for public liability claims in the United States pertaining to shipments of foreign fuel. This is an area that will require further review as the policy of domestic storage of foreign spent fuel is developed.
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AWAY-FROM-REACTOR STORAGE The NRC staff has evaluated the environmental impacts of the accumula-tion of spent fuel, and recently published a draft Generic Environmental I
Impact Statement (GEIS), NUREG-0404. The draf t GEIS concludes that there will be a need in the early 1980s for independent spent fuel storage installations or, as these are sometimes called, away-from-reactor storage We installations to accommodate some of the accumulating spent fuel.
have also publ# sr2d a proposed new regulation covering the requirements for extended spent fuel storage at installations built specifically for this purpose, which are not coupled to either a nuclear power plant or a fuel reprocessing plant, but possibly on the site of such plants.
We do not perceive any significant difference in safety considerations between storage of " aged" spent fuel at reactors or at away-from-reactor Similar safety systems are provided at either site which are sites.
designed to minimize risk to the public. Personnel at either type of f acility have comparable duties and training. Differences in site-related hazards can be and are designed to preclude these hazards from contributing significantly to the risk. Use of transportation to move spent fuel to an away-from-reactor storage facility is aisc a small contributor to risk.
The increase in risk by expanding reactor storage capacity cr extending storage time is very small relative to the risk resulting from hancling and storing newly discharged fuel - - a risk that exists regardless of the nur:er of fuel assemblies stored in the spent fuel pool.
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. Transportation to a storage pool at another reactor would present about the same risk as shipment to a centralized facility.
If storage at another reactor is an interim measure with subsequent planned shipment to a centralized away-from-reactor storage facility, the interim step would increase the transportation risk.
The spent fuel pool and related access is considered to be a vital area for implementation of NRC requirements for physical protection against sabotage and theft of special nuclear material.
The design of the spent fuel pool to maintain its function under severa adverse natural Adninistra-conditions provides substantial barriers against intruders.
tive controls are applied where needed to augment physical protection.
The radiation level of the spent fuel provides an effective deterrent against thef t of this material. As long as the fuel elements are stored in the spent fuel pool, additional compaction of the fuel array does not
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The storage of spent fuel at locations other than reactors raises related Price-Anderson questions.
In this situation, where storage of irradiated fuel is not at the site of either an operating reactor or a reprocessing facility, the Commission has not exercised to date 13, s c
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. its discretionary authority to extend Price-Anderson coverage to such a storage facility. The NRC staff is conducting a study, to be completed in 1979, to determine if storage of spent fuel away from a reactor site should be indemnified under the Commission's discretionary authority.
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RESPONSES TO QUESTIONS ASKED IN LETTER FROM MORRIS X. UDALL TO JOSEPH HENDRIE JANUARY 11, 1979 QUESTION 1:
What regulatory constraints affect a reactor operator's ability to store quantities of fuel at the reactor site, increase at-reactor storage capacity, or transfer excess spent fuel to another site?
RESPONSE
There are no regulatory constraints that limit the quantity of spent fuel that can be stored or transferred. The regulaEions, primarily 10 CFR Part 50, " Licensing of Production and Utilization Facilities",
specify the safety requirements to be followed for the storage of spent fuel.
10 CFR Part 51, " Licensing and Regulatory Policy and Procedures for Environmental Protection" and thE Canmission Policy Statement of September 16, 1975, state the environmental considerations that need to be included for spent fuel storage. The regulations controlling transportation are covered in response to Question 4.
When a reactor facility is licensed to operate, the spent fuel storage capability proposed by the licensee is reviewed and approved as one part of the facility. The regulations do not require any particular storage capability. Most facility designs have provided capability for storage of at least 1-1/3 cores.
Pool design and accident considerations assume that the pool contains one core of recently The discharged fuel plus sufficient old fuel to fill the pool.
gasecus fission product inventory and decay heat associated with the
. recently discharged fuel are much greater than those associated with the old fuel. Wherl, the spent fuel storage capability is increased, more old fuel is stored. Safety analyses to date for the proposed increases in storage capacity have shown that the proposed increases have only a small impact on the design or accident considerations.
The maximum increase in storage capability is limited by. the avail-able space in the' spent fuel pool.
Spent fuel has been stored safely in a water environmen't for 20 years and reasonable extrapolations indicate that it can be stored safely for the life of the facility.
Spent fuel can a.lso be shipped by a reactor licensee to away-from-reactor facilities, provided that the recipient is' licensed to receive and possess the spent fuel. The General Electric Morris plant is the As only licensed facility that is accepting spent fuel today.
explained in the response to question number 2, a new regulation has been proposed to specify the requirements that must be followed Until such for any additional away-from-reactor storage facilities.
time as that regulation may be adopted, licensing of spent fuel storage at away-frem-reactor facilities continues pursuant to 10 CFR Part 70, " Domestic Licensing of Special Nuclear Materials."
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. QUESTION 2:
What modifications of this regulatory situation if any, are under way or under consideration?
RESPONSE
The NRC staff has evaluated the environmental impact associated with the accumulation of spent fuel and recently published a draft Generic Environmental Impact Statement (GEIS) on this subject. The purpose of the evaluation was to analyze alternatives for the handling and storage of spent light water power reactor fuel with particular emphasis on developing long-range policy. The significant findings stated in the draft GEIS are:
1.
The lack of spent fuel storage capacity at nuclear power plants has been alleviated by modification of the spent fuel storage facility in operating plants.
2.
Additional away-from-reactor storage facilities are needed.
3.
Storage of spent fuel in water pools at operating plants or at away-from-reactor facilities has an insignificant environmental impact.
4.
There is a need for a more definitive regulatory basis for licensing additional away-from-reactor storage facilities.
5.
Curtailment of the generation of spent fuel by ceasing operation of existing power plants when their spent fuel pools became filled is found to be unjustified on a cost-benefit basis, and the prohibition of construction of new plants is unrealistic.
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The NRC has published a proposed new regulation,10 CFR Part 72, " Storage of Spent Fuel in an Independent Spent Fuel Storage Installation (ISFSI),"
covering the requirements for extended spent fuel storage at installations built specifically for this purpose that are not coupled to either a nuclear power plant or a fuel reprocessing plant but may be located on the site of such plants. The proposed new regulation specifies procedures and requirements for the issuance of license; to store spent fuel in an To ensure adequate protection independent spent fuel storage installation.
c of the public health and safety, the proposed regulation would establish siting, design, operation and records requirements for away-from-reactor In addition to this proposed new rule, the staff has spent fuel storage.
issued Regulato'y Guide 3.44, " Standard Format and Content for the Safety r
Analysis Report to be Included in a License Application for the Storage of Spent Fuel in an Independent Spent Fuel Storage Installation (Water-Based Type)." However, present regulations in 10 CFR 50 and 10 CFR Part 70 can be used as a basis for review and approval of additional storage pools located at power reactor sites.
No further modifications to NRC regulations are needed to deal with the short-term handling of spent fuel.
However, the long-term solution may require additional regulatory actions.
Any necessary action will be determined following publication of the Interagency Review Group report.
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. OUESTION 3:
To what extent and in what manner is a growing shortage of spent fuel storage capacity Ubing reflected in license modifications and license applications?
RESPONSE
In 1974, licensees began to discuss several options for improving the At that capability for storing spent fuel with the regulatory staff.
time, the most viable option was increasing the capacity of the onsite storage pool.
The first formal proposal by a reactor licensee for increasing onsite spent fuel storage capability was in late 1974. The proposal added new racks of i different design to the spent fuel storage pool in " free" or Since
" unused" space. The initially installed racks were retained.
that first proposal was made, the approaches to storage design have become more sophisticated with time. They vary from more racks of the same design to new racks with a decrease in spacing between fuel assemblies; from racks without neutron absorbers to deliberate use of boron materials; and from fuel storage racks that cover the spent fuel storage pool floor to a second tier of fuel storage racks.
Including the first proposals made in 1974, there have been 50 applica-The 50 tions to modify the onsite storage capability for spent fuel.
applications include 6 applications that are for second-time modifica-The 44 first time applications provide for increased storage tions.
capaoility for 60 of the 67 light water reactors actively c;erating today.
the NRC began naintaining a status summary of spent fuel storage In 1977,
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Infonnation is received monthly from licensees. This is reported monthly in the NRC publication,
" Operating Units Status Report", NUREG-0020. The attached Table 1, entitled " Status of Spent Fuel Storage Capability," is a revision of that taken from the December 1978 NUREG-0020 report. The. table shows that the pools at !.aCrosse and Surry are now fille.d, and the pool at Kewaunee will be filled in 1979.
Pools at Oconee, Point Beach and Big Rock will be filled in 1980. These fill dates were estimated based on the discharge rate of about 1/3 to 1/4 of the core into the pool at each refueling.
The projected pool fill dates change as licensees foresee approaching problems and then select an available option to increase storage capacity.
For the above-mentioned reactors, proposals have been made for all plants, except Big Rock, to either increase on-site storage or ship fuel off-site for storage (such as Oconee to McGuire).
We understand that Big Rock intends to increase the on-site storage, but we have not received a proposal.
If all proposals to provide additional storage are carried out, only Big Rock is shown to have a spent fuel storage problem within the next 3 years. For the cases cited above, only the storage of Oconee fuel at McGuire involves pending approval of storage of spent fuel shipped from one reactor site to another reactor site. However, we have previously approved storage of spent fuel from the H. B. Robinson facility at the Brunswick facility and have applications under review involving the Dresden and Quad Cities facilities.
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4 Mos.t nuclear plants that are currently being reviewed for operating licenses are proposing to increase the storage capability of their fuel pools by redesign for the spent fuel storage racks. Of the 19 facilities currently under review,15 have submitted requests for ~ approval to expand storage capacity. The increase in storage capacity js sufficient to store fuel for about 2 to 6 cores.
This corresponds to sufficient storage capacity to accommodate about 6 to 18 years of operation without the need to transfer fuel off site.
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. OUESTION 4: Please describe regulations affecting spent fuel transportation, including those applicable to casks and rail cars.
RESPONSE
The transportation of nuclear fuel and waste is regulated primarily by the Department of Transportation (DOT) and by the Nuclear Regulatory Commission (NRC). The regulations of the NRC are contained in Title 10 of the Code of Federal Regulations, primarily in 10 QFR Part 71, " Packaging of Radioactive Material of Transport and Transportation of Radioactive material Under Certain Conditions". The regulations of the 00T are contained in 49 CFR Part 170189, " Transportation" (for shippers and road, rail, water, and air carriers). These regulations are applicable both to persons who ship radioactive materials, as they package and offer such materials for transportation, and to carriers of radioactive material, as they load and transport such materials in their vehicles. The regulations provide protection from the hazards of radiation to transport workers and the general public and protection from radiation damage to undeveloped film. The jurisdiction of the NRC and the DOT overlap with respect to safety in the transportation of radioactive materials. To develop and implement consistent, comprehensive, and effective regulations and to avoid duplica-tion of ef fort, the DOT and the NRC partition their regulatory responsi-bilities under a Memorandum of Understanding between the two agencies. ,o ss e .I
9 In general, the DOT is responsible for regulating safety in transportation of all hazardous materials, including radioactive materials, and the NRC is responsible for regulating safety in receipt, possession, use, and transfer of byproduct, source, and special nuclear materials. The 00T is primarily concerned with the conditions of carriage and the NRC is primarily concerned with evaluation of package designs for fissile materials and for la.rger quantities of other radioaciive materials. Primary reliance for safety in transportation of radioactive material is placed on the packaging. The DOT regulations prescribe general standards and requirements for all packages of radioactive material, and for handling and storage of those packages by carriers. The .4 standards that have been established in the 00T and NRC regulations provide thc the packaging shall prevent the loss or dispersion of the radioactive contents, provide adequate shielding and heat dissipation, and prevent nuclear criti. :..y under both normal and accident conditions of transportation. The normal conditions of transportation which must be considered are specified in the regulations in terms of hot and cold environments, pressure differential, vibration, water spray, impact, puncture, and compression tests. Accident conditions that must be con-sidered are specified in terms of impact, puncture, fire conditions and water emersion. \\ % b
. ~ For packages containing no significant fissile radioactive material and only small quantities of other radioactive materials, the DOT standards and requi,rements provide adequate assurance of containment and shielding of the radioactive material under nomal conditions of transportation. Although these small quantity packages, temed Type A packages, may fail in an accider.t situation, the radiological conse-quences nuld be limited because of the limited package contents. WhentheradioactivecontentofapackageexceedsthefsmallTypeA quantity limit, it may only be transported in a Type 8 package, one that is designed to survive both nomal conoitions of transportation and transportation accidents. The Type B package must be designed to withstand specified impact, puncture, fire environments, and water emersion, which provide protection against severe transportation accidents, and its design must be independently reviewed by the NRC engineering staff to verify its confomance to regulatcry requirements. Finally, a certificate must be issued by the NRC before a Type B package can be used to transport radioactive material. Spent fuel casks are classified as Type B packages. Procedures applicable to the shipment of packages of radioactive material require that a package be labeled with a unique radioactive materials In transportation, the carrier is required to exercise control l abel. over radioactive material packages, including loading and storage in areas separatec from persons, and to limit the aggregation of packagas E' t"
11 ~ to limit the exposures of persors. The procedures that the carrier must follow in case of an accident include notifying of the shipper and the DOT, isolatinf any spilled radioactive material from personnel contact, pending dispcsal instructions from qualifie1 persons, and holding vehicles, huildings, areae., or equipment from serYice or routine occup?.ncy until they are. cleaned to specified values. Within the limitations of the regulatory standards, radioactive materials may be transported in routine commerce using conventional transportztfon No special restrictions on the speed or routing of a vehicle equipment. are considered r.ecessary to assure safety.I In its recent reexamination of its regulations on packaging and transportation of radioactive materials, the NRC staff concluded tnat the environmental impacts of noncal' transport- ~ ation and the. risks attendant to accidents involvir.g radioactive materiel shipments are sufficiently small to allo (continued shipments by all mndes Two documents, and that 'no changes to the regulations are needed at this time. " Environmental Survey of Transportation of Radioactive Materials To and From Nuclear Power Plants," WASH-1238, and " Final Environmental Statement on the Transportation of Radio 3ctive Materials oy Air and Other Modes," NUREG-0170, provide addi t cnal i nformation on this topic. AccordTTg to 00T, of the more than 32,000 hazardous material i. incident reports submitted to the DOT during the five-year period Of G71-1975, only '144 were noted to involve racicictive materials. tnese 144 incidents, only 36 shcwed any release Of contents or excess radiation levels. In most cases, releases in< oiled minor contamination fecm low specific activity, exempt, or Tyoe A packages. \\)') ^ r / , 3. f e-o -m m -- ~,,.
. OUEST10N 5: Are there at this time any licensed spent fuel shipping casks, or rail cars, or any license applications for these?
RESPONSE
Six spent fuel cask designs are currertly authorized for shipment of spent fuel frcm pressurized water reactors (PWRs) or boiling water These six designs include four truck casks, each of reactors (BWRs). which can carry a small number of spent fuel assemblies, and two rail casks, each of whicN can carry a larger number of spent fuel assemblies. These designs are described in the recently issued, "Directcry of NRC Certificates of Compliance," NUREG-0383, Revision 1. Details regarding these six designs are tabulated below: Capuci ty Cask Design Certificate of Transporta (assemblies) No. Under Model No. Compliance,NO. tien M "Is) PWR /BWR No. Built Construction NFS-4 6698 Truck 1/2 6 1 NLI-1/2 9010 Truck l/2 5 0 TN-8 0015 Overwt Truck 3/0 2 2 TN-9 9016 Overwt Truck 0/7 1 3 IF-300 9001 Rail, Overwt 7/18 4 0 Truck NLI-10/24 9023 Rail 10/24 2 0 At present, two other cask designs are under review for certification, Model Nos. TN-12 and NAC-3K. Both casks are designed to be rail casks with capacities for 12 PWR assemblies each. Adoption of AFR storage would require a significant increase in the number This aculd also require an increase in the cask of casks available. ar.uf acturirg capacity which is currently limited. m 1 - - ~ - QUESTION 6: What type of domestic or international regulations would affect spent fuel being shipped to this country? How do they differ, if at all?
RESPONSE
As indicated in the response to question 4, transportation of radioactive material is regulated by the Nuclear Regulatory Commission (NRC) and the Department of Transportation (DCT), and responsibilities are partitioned under a Memorandum of Understanding. The transportation safety regulations of NRC and 00T are consistent with those of the IAEA. Imports of spent fuel to the U. 5. are subject to revalidation by the DOT, as the U. S. National Competent Authority, of the cask design approval certificate which the Under foreign shipper has obtained from his national competent authority. our present " Memorandum of Understanding" (MOU) with DOT, the cask design would be reviewed by the NRC engineering staff before DOT provides that revalidation. We are presently considering a change to that MOU which would eliminate the cask review by NRC for most import shipments because it is essentially a duplicate of that done by the foreign national Under this competent authority, using the same package standards. changed procedure, 00T would, fnr import shipments, screen the cask If that screening design as described in the approval certificate. raises any question about the safety of the cask design, an NRC detailed review would be provided. In the absence of questions however, DOT would revalidate the cask design approval certificate on the basis of its screening of the foreign safety review, but limiting the revalida-tien :: irpert and export shipments. . s l _..-.m_.._ _m.. . ~.. _.
, The statutory criterion for approving NRC import licenses involving spent fuel is that a determination be made that the f aport would not be " inimical to the common defense and security" of the United States, and would not " constitute an unreasonable risk to the health and safety of the public." The Commission has not licensed any spent fuel imports to date other than relatively minor imports of foreign spent research reactor fuel for recrocessing and extraction of highly enriched uranium by the Department of Energy (00E). In October 1977, the United States government announced that, in conjunction with a program for the storage of domestic spent power reactor fuel, it was prepared to accept limited quantities of foreign spent power reactor fuel for storage in this country. Such acceptance would be limited to instances in which U. S. nonproliferation goals would be advanced, and if a need for such services existed. Congressional approval would be required. With respect to health and safety impacts, the DOE is currently preparing generic environmental impact statements for both the domestic storage program and the storage of foreign spent fuel. The NRC will submit comments, as appropriate, to the DOE regarding the impact statements, and it is anticipated that the NRC will draw heavily upon the findings in the final statements' in connection with its review of spent fuel import license applications. I - _ ~ - _ _., - - ~
QUESTION 7: What if any difference in safety risk exists between storage of spent fuel at reactor sites and storage of the fuel at centralized facilities away from the reactors? Please answer this both in terms of the storage means themselves and in terms of the related management systems.
RESPONSE
There are no significant differe*nces in health and safety risks between storage of spent fuel at reactors and storage of the'same spent fuel at centralized away-from-reactors ( AFR) storage facilities. Fuel stored ~ at reactors would normally include fuel with less decay time, but thi s dif ference is accounted for in facility design. Fuel handling systems, components, etc., may differ in design and manufacture somewhat, but all are required to. meet comparable seismic, manufacturing, and reliability standards. Personnel attendant at the storage facility area and equipment of either type of facility would have comparable duties and training. Differences in risk related to siting f actors are accommodated in design. While preliminary results, with attendent large uncertainties, suggest that transportation may De a significant factor in contributing to risk in the post irradiation part of the fuel cycle, use of transportation to move spent fuel to an AFR storage facility is a small contributor to overall fuel cycle risk. Only aged spent fuel 1>l20 days) is shipped, and the shipping casks used to transport the spent fuel are designed to maintain integrity following impact and fire due to a postulated traffic accident. Overall, the increase in risk by expanding AFR storage capability or stcrage time is very small compared to the risk from handling and storing ne-ly discharged fuel. . o i s
1, . ~ OU.ESTION 8: Will the absence of substantial newly constructed storage capacity in 1984 be likely to result in a si~gnificant risk to the public health and safety, if present trends in reactor operators' activities continue? If so, why?
RESPONSE
The absence of substantial additional storage capacity in 1984 will not result in a significant risk to public health and safety from radiological (h)accomplishphysical hazards in that utilities will find it necessary to: modifications that increase the capacity of existing jools or construct new at-reactor storage pools; or (2) transport their spent fuel to existing pools at GE Morris, Barnwell, or at under-utilized reactors, or (3) cease Strong economic incentives would likely exist to avoid a power generation. 'As of July 31,1978, for reactor shutdown for a lack of storage capacity. example, 69 nuclear plants capable of producing approximately 50,000 This megawatts of electrical power were licensed for commercial operation. is approximately 9% of the total electrical generation capacity for the contiguous United States. In 1978, these nuclear units were expected to generate a net of nearly 25 billion kilowatt hours (kwh) per month or 13% To the extent
- of the total electricity product' ion in the United States.*
that curtailment of operations were necessary, and electrical demands were met by other fuels, society would be exposed to the public health and safety risks associated with the other fuel cycles. -8:n Annual Review of Overall Reliability and Adequacy of the North American Eulk Power Systems, National Reliability Council, August 1978. 1 m e -e=- - emme emo w-e e -e~ow,===-e.- --e-e-- --+ - ,e}}