ML20141P202
| ML20141P202 | |
| Person / Time | |
|---|---|
| Issue date: | 03/12/1986 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1496, NUDOCS 8603190140 | |
| Download: ML20141P202 (182) | |
Text
. 0%GIhAL bblUS UN11ED STATES O
NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
DOCKET NO:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCOSLMITTEE ON SPENT FUEL STOPAGE FACILITY DESIGN LOCATION:
WASIIINGTON, D.
C.
PAGES:
1-119 DATE:
WEDNESDAY, MARCII 12, 1986 0YN0{00?f oo demoye from ACRSoffice ACE-FEDERAL REPORTERS, INC.
OfficialRepor&rs 444 North CapitolStreet
/[d Washington, b.C. 20001 (202)347-3700 jj.jl31 gig 1006031,,
NwrDE COVERAGE r-1496 run
CR26137.0 1
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UNITED STATES OF AMERICA 2
I NUCLEAR REGULATORY COMMISSION 3
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS I
4 SUBCOMMITTEE ON 5
SPENT FUEL STORAGE FACILITY DESIGN l
6' 7
Nuclear Regulatory Commission Room 1122 1717 H Street, N.W.
8 Washington, D.
C.
i 9
Wednesday, March 12, 1986 10 The meeting.of the subcommittee convened at 1:30 p.m.,
g li Dr. Chester P. Siess, chairman, presiding.
12 '
(
13 ACRS MEMBERS PRESENT:
i DR. CHESTER P.
SIESS 15 MR. HAROLD ETHERINGTON 16 DR. DADE W. MOELLER i
17,
HERMAN ALDERMAN, ACRS Staff Member 18,
I
- , CONSULTANTS PRESENT
20 [
K.
Steyer i
W. Pearson 21 T. Clarke L. Rouse
{
L. Beratan 22 J. Roberts R. Kornasiewicz l
23 B. Nulsen C. Sawyer l
24 hee Federal Repo,ters, Inc.
25 i
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- N 44%,
i
-t PbBLIO' NOTICE BY THE
(,
.
7 g Q: WEDNESDAY, MARCH 12, 1986 .} 4 ,, w - n The contents of this stenographic transcript of the . ' -~ proceedings of the United States Nuclear Regulatory b'\\ Commission'.s Advisory Committee on Reactor Safeguards .\\ - ('A C' R S ), as reported herein, is an uncorrected record of s . i the discussions recorded at the meeting held on the above date. s . s No> member of the ACRS Staff and no participant at this meeting accepts any responsibility for errors or inaccuracies of statement or data contained in this transcript. \\ g 1 , \\, k f \\ a y
- 1. 4 3
l.. s l 4 N. ~ , If I 'l' 26137.0 2 7_REE u.) 1 PROCEEDINGS 2 MR. SIESS: The meeting will come to order. 3 This is the meeting of the ACRS Subcommittee on spent fuel 4 storage facilities design. I am Chet Siess, chairman of 5 the Subcommittee. On my left is Harold Etherington, Dade 6 Moeller is across from me. Carson Mark will not be here. 7 And Herman Alderman is the staff member assigned to the 8 meeting. The rules of participation have been announced as 9 part of the notice in the Federal Register, February 21. 10 In keeping a record, I think -- each speaker 11 please identify himself or herself and I don't think we l 12 will have any questions for clarity in this huge room. I f, \\- 13 your teetri chatter, s'he can' t* record it. We have received 14 no written comments or requests for time to make oral 15 statements from members of the public. 16 The purpose of the meeting is to look at 10 CFR 17 Part 72 which is entitled " Licensing Requirements for the 18 Independent Storage of Spent Nuclear Fuel and High Level 19 Radioactive Waste." What has instigated this is the fact 20 that the Staff has indicated that it will review the 21 proposed monitor retrievable storage facility under Part 72 22 as revised and that the Commission has asked the ACRS to l 23 review all of the activities on high-level waste management 24 that have been assigned by the Congress. And since the MRS () 25 is a part of the high-level waste program, and since Part ACE. FEDERAL REPORTERS, INC. m ya,,
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,#= mm- 26137.0 3 REE 1 72 is the criteria -- contain the criteria for that review, 2 we thought it best that we started off by looking at Part 3 72 and not just at the proposed revisions, which are both 1 l 4 procedural and apparently minor. l 5 This subcommittee was formed by the ACRS a few 6 years ago when the first question of independent spent fuel 7 storage installations came up. That was an acronym called 8 ISFSI. I guess it is not dead, there are still some around. 9 Part 72 was written for those independent spent fuel 10 storage facilities. And we have looked at Part 72 at a 11 very early stage but only in a very limited way. 12 The Committee never reviewed Part 72 throughout. 13 Bob Benaro was there at the time and he brought it into the h 14 Committee because he had some unique ways of approaching 15 seismic design. He wanted to get some comments on it. 16 As might have been expected, he got some 17 gratuitous advice on other aspects of the proposed criteria, 18 and since it was at a very early stage, I am not quite sure 19 what issues were taken into account. This is what we want 20 to do then: review Part 72 like we would review any other 21 proposed rule and provide some comments on it, in the 22 course of which, we will look at the proposed revisions. 23 I have my copy of the marked-up copy of Part 72. i 24 Any questions, Dade? i () 25 MR. MOELLER: I will have obviously -- l ACE FEDERAL REPORTERS, INC. l ) EOP3 X~1 - N ---- ------ f~YEY"~1- 26137.0 4 REE O 1 MR. SIESS: I mean before we start? 2 MR. MOELLER: None before we start. 3 MR. SIESS: Harold, were you involved in this 4 thing before? 5 MR. ETHERINGTON: No, I wasn't. 6 MR. SIESS: I am trying to remember who was. 7 Hell, with that introduction, I guess we could start in. 8 Ue have an agenda somewhere. 9 MR. STEYER: Dr. Siess, I am probably going to 10 l be the main speaker here. Our intentions are to cover the 11 topics as they are listed in the agenda. In fact, we have 12 prepared a handout -- we have a number of handouts. This ,_s ( ) V-13 one is the handout that generally follows the listing"in 14 this tentative schedule. 15 MR. SIESS: Now, the items on the agenda I 16 assume were worked out by you and Mr. Alderman but based on 17 my suggestions? 18 MR. STEYER: Yes. 19 MR. SIESS: The items we have listed here is the 20 proposed changes in the general design criteria, 21 design-basis accidents, sabotage, citing seismic and floods, 22 tornados and missiles. Most of those items are some of the 23 things we wanted to particularly bring up. But I really 24 think that if it fits within what you had in mind, just to I i 25 sort of run us through Part 72 completely as to what is in l ACE. FEDERAL REPORTERS, INC. s~wann W m ._=- 1 26137.0 5 (~REE \\ V 1 it. 1 2 MR. STEYER: Well, that isn't exactly what we i l 3 had in mind. But let me explain what we had in mind. I am l 4 Keith Steyer in the Research Office and Bill Pearson is in l 5 my branch. He have here Lee Rouse, Tom Clark, John Roberts l 6 from NHSS, who do the licensing of these things and will do 7 any future of MRSs. We alco have from Research Leon 8 Beratan and Mr. Kornasiewicz and also a man here from -- 9 Carl Sawyer from safeguards. I hope they will speak up and 10 I know tomorrow has prepared something to discuss what an 11 MRS is and some of the aspects. 12 MR. SIESS: Who was involved in the original l 13 Part 72? 14 MR. STEYER: Originally Part 72 was written by a j 15 fellow by the name of Russ Stanford under me. And Bonaro. 16 He h:c retired. The man who took his place has quit so wo 17 are on the third person now on this rule. 18 MR. SIESS: One question I have, it was my 19 recollection from what we were talking about when they came l 20 into us before that there was clearly the conception that 21 the ISFSI would be a pool-type storege. Now, I assume that i i 22 when it got written up, it wasn't that specific. 23 MR. STEYER: That is right. At the very 24 beginning there was, it seemed like there was most emphasis () 25 on pool-type storage. Then as it became evident that 1 l l l ACE. FEDERAL REPORTERS, INC. rmfimiin --.----M. u-- m O 26137.0 6 REE 1 licensees were more likely to come in with requests to 2 license casks and stuff -- but before the final rule went 3 out in 1980, we had modified it, we felt, to cover all 4 kinds of ISFSIs. 5 MR. SIESS: Has anybody come in with an 6 application for an ISFSI? 7 MR. STEYER: Yes. We had one in the midwest 8 that actually has a license. Then there are others that i 9 have come in without -- 10 MR. ROUSE: Ceuld I answer that -- 11 MR. SIESS: I -- you mean up in Dresden, the old i 12 GE plant. 13 l MR. ROUSE: Dr. Siess, first of all, GE Morris 14 clearly existed before Part 72 did. 1 15 MR. SIESS: It wasn't designed for spent fuel I 16 storage? i 17 MR. ROUSE: At the renewal stage in 1980-81 time 18 frame, GE Morris facility was renewed under the provision l 19 of 10 CPR Part 72 explicitly. 20 MR. SIESS: That is a pool-type? 21 MR. ROUSE Yes. Subsequent to that, as you are 22 well aware, there has been a high interest in dry storage 23 at reactors. So under the, fundamentally the purvietr of I 24 Part 72, the Staff has been doing a couple of things. In () 25 my branch we has* been looking at a number of topical i l i ACE. FEDERAL REPORTERS, INC. m 1 ~ m 26137.0 7 REE q \\_/ 1 reports submitted under the framework of Part 72 for design 2 of these metal dry storage casks. In addition to that, wo 3 actually have two applications now which the Staff is 4 nearing -- very near completion on the licensing aspect. 5 One is for VEPCO for its Surrey plant. And they have 6 proposed the use of an explicit specific dry storage cask 7 down at its Surrey site to take care of its capacity needs. l 8 Explicitly they have referenced a West German i l 9 cask that we have reviewed under the safety provision Part 10 72. As I say, wo are very, very close to going to the 11 Commission and telling them we are ready to issue that 12 license. s/ 13 MR. ETHERINGTON: What kind of cooling system do i 14 they have on the dry storaga?, \\ 15 MR. ROUSE: Strictly passive. The dry storage 16 casks are large casks. It is the intent, in fact, of theso j 17 vendors to get the same casks certified for transportation I l l 18 so you would have a dual-purpose cask. But the design of 19 the fuel, they provide a heat dissipation. The one I am 20 talking about is explicitly about 21 kw. 21 PWR assemblies. 21 Thus you are talking about five-year-old or older fuel. 22 MR. ETHERINGTON: You still would be talking 23 about a closed air-cooling system? l l 24 MR. ROUSE: Yes, just convex, radiation. () 25 MR. ETHERINGTON: Is there an external heat i P ace. FEDERAL REPORTERS, INC. rvamn m 26137.0 8 EE \\ 1 exchanger on the -- 2 !!R. ROUSE: No. Not at all. They are limited l l 3 to -- this particular cask would be limited to 1 kw of heat 4 output per assembly, and that would limit, under those 5 passive conditions in the cask, would limit the peak clad 6 temperature of any assembly in there to about 370 degrees C. 7 And there is ample evidence to show that we shouldn't 8 expect any type of failure of the fuel under thoso 9 conditions. 10 I should add one thing. The atmosphere of the 11 cask, these dry storage cask will have an inert atmosphere 12 because there is concern over oxidation over a period of 13 time, if you have failed fuel in there, oxidation of the U02, 14 splitting of the clad. So until that oxidation phenomenon 15 and temperature is nailed down better, the Staff is l 16 requiring and the vendors are going to inert atmosphere 17 casks. 18 I MR. ETHERINGTON: What is the ambient 19 temperature surrounding the cask? 20 MR. ROUSE: It is calct' lated at a consorvative -- 21 MR. SIESS: About the same as Washington. 22 MR. ROUSE: 125 -- 23 MR. ETHERINGTONt Without any cooling? 24 MR. ROUSE: Without any cooling, that is right. () 25 MR. SIESS: It just sits there and radiates. ace. FEDERAL REPORTERS, INC. . - _ ~ - - 26137.0 9 j MR. ETHERINGTON: But it radiatos to something? 2 MR. SIESS: Yos. l t 3 MR. ETHERINGTON: The air is static? j 4 MR. SIESS: Yes, it is outside. 1 l 5 MR. ETHERINGTON: I thought it was in a i 6 containment building. l 7 MR. ROUSE: They are just sitting outside on a a pad. [ i 9 MR. ETHERINGTON: I didn't realize that. I 10 MR. ROUSE: I mentioned we had two applications. I 11 He have another application from Carolina Power & Light for l 12 the Robinson site. l () 13 MR. SIESS: On the -- at Morris, they store 14 intact bottles, they are not consolidated. I 15 MR. ROUSE: That is true. l 16 MR. SIESS: And the same is true on the VEPCO? 17 MR. ROUSE: That is right. 18 MR. SIESS: And each cask contains -- i 19 MR. ROUSE: This cask would be 21 PWR assemblies. l 20 Robinson is a little different. In a cooperative agrooment 21 with DOE under the Waste Act to demonstrate dry storage 22 technologies, CP&L entered into an agreement to demonstrato 23 what we call horizontal concrete storage modules. They are 24 basically a concrote silo and the fuel would be loaded into () 25 a canistor, 7 PWH assemblies per canistor, and the fuel l ace. FEDERAL REPORTERS, INC. . - -- --- r~vmem - -. -- - m. - m 26137.0 10 EE 1 cooled and transferred to this concreto modulo that sits 2 insido the protected area in this caso, but outsido of the 3 roactor containment, would bo movod to thoro and 4 transferred by use of a shipping cask that CP&L owns. It 5 is an IF 300 shipping cask. They have designed and 6 modified the head of that cask so they can moet up with the 7 concreto modulo and transfer this canistor then into the 8 concrote modulo. Right now CP&L is planning for eight of 9 thom in this demonstration. 10 Again, we are very close to our completion of 11 this liconso. 12 MR. SIESS: If the MRS wore built, would thoro I) 13 l bo loss interest in the ISFSI money noodod? This in thero 14 attempt to bridge that gap? 15 MR. ROUSE: What it doos, Dr. Sions, if the MR9 16 woro authorized by Congross, clearly it given the utilition 17 an aiming point down lino as to how long they havo to tako 18 caro of their own fuel. The MRS, as Mr. Rucho puts it, 1 19 gives DOE high confidenco. So that providos somo 20 confidenco for the utilition to plan. Undor that scenario, 21 you would probably not sco too many peoplo going to the dry 22 storago. I 23 A lot of ranctorn can take care of their noods 24 through rocacking, tho two-region roracking whore they tako ( 25 credit for hurn up. So most reactors will tako caro of ACE. FEDERAL REPORTERS, INC. m m m m i 1 26137.0 11 l EE I l I themselves in the existing bases. 2 MR. SIESS: Somo people aro looking to t f 3 consolidation for their own pools? 4 MR. ROUSE: Yes. That is the next step that l 5 most reactors will look at, at strictly economics. You i 6 react to the extent you can. Then you will look at rod l l 7 consolidation. That hasn't really been demonstrated on any J 1argo scale yet. l 9 MR. SIESS: It has to got pretty old before you 10 consolidate it? l 6 11 MR. ROUSE: Yes, they are talking about 12 five-year-old fuel. I O 13 MR. SIESS: What is going into Morris? l = L 14 MR. ROUSE: Morris, GE still has some residual 15 contracts from the old days when it was going to reprocess. 16 So the only thing they are accepting at Morris is, i 17 fundamentally their responsibility contractually through 18 some of those old reprocessing and contracts that they had 19 for supply of fuel. Right now, for example, they are 20 accepting fuel from Monticello and from Cooper. 21 MR. SIESS: Did either one of those expand their 22 own capacity? 23 MR. ROUSE: Yes. They both reracked. 24 MR. SIESS: At least once? j 25 MR. ROUSE: Yes. f l l l l ACE. FEDERAL REPORTERS, INC. r~vmn m u m i l l 26137.0 12 EE 1 MR. MORLLER: You say Morris is still accepting ( 2 fuel and yet aren't they the ones that are sending fuel L 3 back? I 4 MR. ROUSE: Well, Morris did send some fuel back 5 to Point Beach. That was -- did I say that right? 6 MR. KORNASIEWIC2: That's correct. It was 7 simply economics. l 8 MR. ROUSE: That was strictly an economic 9 decision on the part of Wisconsin Electric. 10 MR. MOELLER: And now Duke, it said that Duke 11 had tried consolidating some fuel. Can you tell us j 12 anything or will we hear anything about that? j O + g 13 MR. ROUSE: I don't think it was on the agenda. 14 MR. STEYER: Not today. 15 MR. ROUSE: I think about three years ago or so l 16 they -- 17 MR. MOELLER: Was it successful? 18 MR. ROUSE: They used Westinghouse equipment. 19 It was strictly a demonstration where they consolidated 5 20 four assemblies and tried to get the rods from those four 21 assemblies into two canisters that they would sit right 22 back in the same rack. They were successful. They did f t 23 spill over into a third canister, but that wasn' t -- one of i 1 24 the things they learned was handling the nonfuel-bearing l O l 25 hardware. They did run into some urprises ehere. Nemaer i ACE. FEDERAL REPORTERS, INC. r v nri n m. - o m 26137.0 13 REE ,_s ( 't v 1 one, the nonfuel-bearing hardwaro was a little hotter than 2 they thought. It cost them a littlo more to dispose of it. 3 So they rocommended than that if they wont forward with 4 this in the fLture thoro would have to bo some changes. 5 nut basically it was a success. 6 MR. ETilERINGTON: What happono to damaged fuel 7 7 NR. ROUSE: Damaged fuel in all likolihood would 8 romain in the pool. It to not likely they aro going to 9 tako known damagod fuel and put it into dry storago. That 10 doecn't mean wo are asking thom to go through heroic 11 offorts to oliminato pinholo leakors. But known damago 12 fuel will stay in tho. 13 HR. PEARSON: And would have to bo shipped to 14 MRS or their dopository. But in that senso, damaged fuel 15 would have to be canistered at the reactor to be shipped. 16 MR. GIESS: That is very helpful. 17 MR. ROUSE: Lot me turn it back to Koith. 18 MR. STEYER: Okay. What I think we had and what 19 you probably havo in great degroo in your proponod schedulo 20 in tho important parts of the rule. There is a lot of 72 21 that is administrativo stuff, how many copion you ought to, l 22 liconnes you should sond. Wo don't nood to cover that. 1 ( 23 The primary purpono of this -- first I plan to 24 talk a little bit about the changen that are pronontly -- () 25 the changed rulo and modifications that are pronontly with ACE. FEDERAL REPORTERS, INC. fmriMin M L -.. m 26137.0 14 , REE (3) xs 1 the Comminnion. Throo comminnionern havo voted yon with 2 comments, two havo not yot votod. No haven't gotton thom 3 yet. And they -- 4 MR. MOELLER: Thoso are all tho votos you nood? 5 MR. STEYER: I guana. But wo also nood Mr. -- 6 MR. PEARSON: Wo haven't hoard from two of tho l 7 comminnionoen yet, nor havo wo hoard from Mr. Chilk. l 0 MR. STEYER: Thono rulon woro changod to, Part l l 9 72 was changed becauno we felt the Staff, in reviewing l 10 thom -- that it would bo, it would be all right to adapt l 11 thom to cover MRSn. MRSn for spent fuoi alono are a littlo 12 more than an ISFSI oporated by Doc. However, the rules 13 also natisfy, would natisfy the Wauto Managomont Act 14 becauno they also have to nometimos maybo take in 15 high-luvol wanto. And wo would modify -- wo modified thono 16 rulon no that they would also be able to handlo high-level 17 wanto. 10 MR. SIESS: In that the namo as trannuranicn? 19 MR. STEYER: Not por no. Thoro in a little bit i 20 of transuranien in high-level wanto becauno high-level 21 wanto in basically the material that comon out of a i 22 reproconning plant. Tho wanto from that. And most of your \\ l 23 uranium and plutonium are comovod, but mostly what in left 24 behind in finnion products. () 25 MR. SIESS: That was not -- that han to bo in ACE. FEDERAL REPORTERS, INC. 1 ~bf % ~ T - M *- L W----------- 26137.0 15 REE G 1 addition becauno that was not within tho concopt of the 2 ISFSI? 3 MR. STEYER: Thoro in no definition what 4 high-lovol wanto wan only tho wanto f rom the roproconning 5 plant. The Comminnion broadonod that to includo npont fuel 6 if it decided it would go to the repository. But thoy 7 nover did it for trannuranica. 8 MR. SICSS: Part 72 originally thought of was 9 for fuol. 10 MR. STEYER: For spont fuel which had plutonium 11 and ovorything 01so and all tho trannuranien in it. 12 MR. PEARSON: liha t you are alluding to, I think, 13 i's the ntfocific storage of trannuranica in containorn 14 l dodicated to the TRU ntorago. 15 Tho rulo doonn't addrono that spectfically, but 16 wo will discuno it lator. 17 MR. SIESS: Okay. llo thought wo'd havo 18 Dr. Clark explain tho MRS and what it in expectod to do. 19 So I would liko to havo him do that now. 20 Thin in likoly to be the last thing wo have to 21 look at, if over, but -- 22 MR. STEYER: By law it han to do ovorythinq that 23 in in the Act. That moann -- 24 MR. SIESS: Rut thoro han to bo an MRS firnt. m 25 Right now it in nomewhat in limbo. ACE FEcunAL REponTuns, INC. rvncm m m l i l l l l 26137.0 16 i l REE 1 MR. STEYrR: Well, that is true. 2 MR. SIESS: Let's see, the law did not authorizo l 3 an MRS as such. It authorized DOE to propose one, did it f 4 not? 5 MR. STEYER: And Congress would decide. 6 MR. PEARSON: It ordered DOE to propose one. 7 MR. CLARK I am Tom Clark, advanced fuel and 8 spent fuel licensing branch. I am the project manager for i 9 the MRS. We thought that you might be interosted in i 10 hearing some of this about the MRS. If you would rather 11 wait until later, that is fine. 12 MR. SIESS: Let's hear it. O Il MR. CLARK: I guesa you can stop me at any point 14 if you want to move rapidly on or anything like that. t 15 MR. RIESS: Go ahead. i ( 16 MR. CLARK: Those are the four points I want to l 17 cover. Quickly, status of the proposal. I should say that i / I 18 we understand that the ACRS is interested in MRst at any i 19 point when you folks want to be briefed after it gets j 20 approved by Congress, we would be happy to arrange for that. 21 I want to talk about the how the Statf looked at the MRS 22 and a quick thing on the schedule and then the nature of 23 the MRS. We did send down a copy of our staff report draft 24 and we sent the proposal down. I don't know if you have O 25 naa ca ace to toox e it-l l ACE.FeoeRAL REPORTERS. INC. - J~V m ri n M o m l 24137.0 17 I - REE 1 MR. SIESS: Yes, I think everybody -- we had the 2 MRS proposal. We have had a copy of the SER. Everything l f 3 that was in the Secy went up. ( 4 MR. CLARK: So you have seen all that. The l 5 status, this will take just about a minute. Commission i l 6 sent its comments to the DOE on February 5. DOE expected 7 to send those comments to Congress on about the 7th and an \\ 8 inlunction came from the State of Tennessee, U.S. District } t 9 Court in the State of Tennessee. Just about that time, I 10 prior to February 5, the governor of the State of Tennessee t 11 had vetoed the project, sent a letter to DOE. The only 12 reason he gave was he thought it was unnecessary. He said O IJ that the facility looked safe. They had to face the fact [ 14 that they would have transportation in the state anyway, 15 but he thought it was unnecessary. t ~} 16 An injunction came out prohibiting DOE from 17 sending the proposal to Congress. That is still the 18 situation. They are appealing to the Appeals Court, which 19 I understand is in Cincinnatit and my understanding of the 20 process, if everything was reversed, if DOE had its way, f 21 they could send the proposal and it could not go until 22 about the raiddle of June, according to the schedule f rom i 23 'the Appeals Court. 24 DOE wanted to send the proposal in February or i O 25 oanuary, aeeusiiv, and have Co#aress maxo a decisioa hv i t l l l I Acs. FEDERAL Raronians, INC. l \\ m - m e e------ M 26137.0 18 7_REE LJ 1 July. It in very unitkoly now that Congrons would be ablo 2 to within that month'n period, mako any kind of a docinion. l 3 So I know wo are alroady looking at nomo nort of dolay, 4 ovon if ovarything goon right for Doc from horo on in. 5 Noxt topic was our review and approach. I quons 6 I fool this in important becauno you havo to undorntand 7 what tho staff thought it was doing w'in it reviewod the 8 MRS. It definito1y was not the wholo-ball-of-wax nafoty 9 ovaluation. That in coming along in about four yearn: 1 10 again, if ovarything goon right. l 11 If you road the Nuclear Wanto Policy Act it nays 12 that wo should consult with DOE. That in what wo thought 13 wo woro doing, trying to provide the boat advice on 14 licensing, and wo had frequent contactu with DOE over this 15 period of timo. Our arrangemont with DOC wan not tho namo 16 as Wanto Management Division's arrangomonto, much loss 17 formal, much more informal. 10 I thit" ! nald that wo did do a good safoty i 19 ovaluation. Wo tried to apply what wo know at the timo. 20 And the most important aspect of tho wholo thing in that wo 21 unod Part 72. I wan project manager for Morris cano under 22 Part 72. And wo unod it. I thought it was quito unoful 23 thora. Wo are uning it now. Un still think it in unoful. 24 It noomed to bo what wo nood. 80 I am claiming right now () 25 that Pirt 72 in good the way it standn protty much. Act!.Fl!DERAI, Rl!!'ORTl!RS. INC. .m m. ,_-____m__-_ 26137.0 19 EE 1 Tho last point that I havn horo in about 2 oxperienco and judgment. That in really what the staff 3 applied for the most part. 11o did tako tho key noctions of 4 part 72 and stackod up what wo naw from DOC against that in 5 torms of how do wo think thin would work whon a liconno 6 application camo in. Thoro in unronolved innuos. Thoro 7 are topien that wo know wo will want to purnuo. So what wo 8 did wan junt fillod tho timo, tho timo wo had, with what wo 9 could do and than camo out with that NUREG 1160. So it 10 should not be viewod an a good nafoty ovaluation. 11 Vory quickly on the nchodulo. Congronn munt 12 approvo the proposal and it hann't ovon gotton thoro yot. 13 If tho schodulo holds, wo would not an application in 1909; 14 and it in betwoon tho timo of approval in 1989 and probably 15 shortly attor approval that wo would intend to como down 16 and talk to tho ACRG, probably havo DOC do that. I havn 17 aleoady talkod to thom about it. Thoy aro willing to do la that. It it gots approved, you can dopond on having an 19 oarly brioting by DOC on tho facility. 20 llo -- DOC has nuqqonted a 30-month roviow porlod, 21 which in la months for tho ntaff and another year for a 22 ponniblo hoaring. That in anybody's guono about how long 21 thono thinon might tako. lio aro confidont on the la months 24 for thin typo of facility. Ono year, 't in hard to nay. ( 25 If all that comon to pann, than wo aro talking ace FEDERAL Rlil'ORTERS. INC. m. m.- m. 26137.0 20 ,_REE N 1 about a start-up of the MRS two years prior to the 2 repository; in 1996 for start-up, repository 1998. 3 Right towards the und as DOE was getting roady 4 to cond this proposal forward, they had nogotiations with 5 tho stato of Tonnossoo and committed that the MRS would not 6 rocoivo fuel unloss thoro was a construction permit for tho l 7 repository. They tied it to the repository. So that onco 8 they got their 3600 tons, whatover it was, they couldn't go 9 any further bocauno tho ropository wasn't rondy. 10 Congress, of courso, has to approvo that. Wo l 11 don't know that Congross will. That is tho way it is not 12 up right now. O(/ i 13 I wantod to tako a little timo -- if you want mo 14 to skip over things, that is fino. When it was first 15 conceived in the Nuctoar Wanto Policy Act, it was called a 16 backup facility: If tho repository didn't como on tino, l 17 lot's put an MRS on to store the fuol until the repository l 10 is roady. 19 ! don't know for nuro that that was non Rucho's 20 idon, but it was about the integrated rolo. That in whoro i 21 you nood somoplace where you can do a lot of activition i l 22 rotated to the reponitory. Porhaps do thom, if you havo l l 23 two or throo ropositorios, just down thom at one facility l 14 and providu some annuranco to tho utilition that their fuol () 25 will be recoivod oven if tho repository la do11 yod. And l Acu.FnonRAL REPORTERS, INC. 1 PTKim W m 26137.0 21 ,~REE k_) I the word they liked to uno in either "intogral" or i 2 INTEGRATED rolo. Thoy call it the intogral HRS. It cort 3 the sits in tho middio of things. 4 I have a little viewgraph to show you that. It l l 5 sits horo. The roactorn cond mostly unpackaged annomblion 6 to the MRS. It is received there, packagod, roady for tho l 7 repository, eithor consolidated or unconsolidated, stored a untti the repository is ready for it and then shippod to 9 the ropository whora thoy could place an overpack on it or 10 nomothing like that. They do have como capability for 11 ovorpacking at tho MRS. So it sort of nits in tho middio 12 of things. 13 i MR. HIE 8S: That in an intorosting thought.
- ot 14 mo ask you nomot;hing, nuppone the reactor in that nkotch 1
15 was one of tho WPP98 and tho repository was at llanford. It 16 isn't in the middio. That doonn't mean they would ship 17 through all the way to Oak Ridoo and then back to lanford. 10 HR. CLARK: No. Right now the proposal nays it 19 would go to the repository and then you would nood nomo 20 nort of packaging capability on the ropository. So the 21 unofulnenn of the HRG for wontorn fuel is iffy. 22 MR. UIEGS: Tliat in an awful lot of shipping. i j 23 An awful lot of peoplo don't liko rtuff shippod. l 24 MR. CLARK: Woll, it in loss shipping in a way () 25 than sending tho westorn fuol to tho HR0 and back. 1 l l Acu.FunenAL REPonTERs. INC. m r w. - m - - --- - 26137.0 22 ,A B C U 1 MR. SIESS: That is what I said. Tho first 2 repository in in the west -- 1 3 ftR. CLARK: If shipping in your problom, then 4 'you would profor it that way. 5 f1R. SICSS: ftont of the fuel is in the cant, but 6 thorn is somo in the west. l 7 ftR. Ct. ARK: flaybo 10 porcont. l 0 MR. HICSS: And the cantorn repository in number t 9 2 on the lint. Doos DOE 11 ave anywhoro in their concopt, l I 10 more than ono flRu? 11 MR. CLARK: tiot that I havo soon. It in 12 conceivablo, but I couldn't -- 13 ftR. SIESSI Thoro was somothing montionod about 14 West Coant tuol. 15 ftR. ROUHE: Vory explicitly, tho Wont Coant fuel 16 hag boon a back-and-forth thing. Right now, what DOC would 17 plan would be to ship the wontorn fuol directly to the 10 repository. tiow, that means, as Tom indicatod, that you 19 have to have capability of the repo altory to handle that 20 fuel. Clearly tho MRH will never take the place of all j 21 surface facilition and reponitarion. So loan than 10 i 22 porcont of the fuol, tho wontorn fuel, may go diroctly to 23 the repository rathar than through MRS. l l 24 MR. U! EGO: If you dolayed things long enough, 25 you could havo each reponitory equipped with all tho fuol l l l ACl!.Fi!nt!nAL Rl!i'ontiins, INC. N - - - - - Mu o--------m---------- l 26137.0 23 7 REE U 1 handling, ropackaging equipmont. 2 MR. ROUSE: That is true. If Congroan doon not 3 approve MRS, then clearly the functions that are plannod 4 for MRS would havo to be dono at the nito of the repository 5 and the cocond repository. Right now DOC in planning ano 6 MRS. They havon't ron11y focunod the MRS on the second l 7 repository, but it vory clearly -- and they acknowlodgo l 8 thin -- could norvo the name function for the second 9 repository, ovon though it is in the cant. I 10 MR. MOELLER: The law also staton, though, that 11 the MRS cannot bo in the same stato whoro the ropository. 12 MR. ROUnt: In correct. 1 13 MR. MOCLLER: lihon doon ropackaging tho fuol at 1 14 the repository bocomo an MRS at the repository? 15 MR. SIESS: That is a good point. 16 MR. ROUSC You havo surface facilition and they 17 will be called just t,9 integral part of the repository. 10 They won't call it MR$ ovon though it doon the ramo thing. I l 19 MR. HTRYER: That is a good point, though. 20 Back to thin chart. What type of facility in it? 21 It in dry of courno. And it in a largo, shielded hot coll. 22 So I have got a few facts and ficuron hore on that anpoct. 13 Another thing that Dot ducidad over the lant 24 year was to limit -- they had boon talking earlier -- you () 25 may or may not havo hoard -- about a 70,000-motric-ton Act!. FEDERAL Rt!PonTEns. INC.
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1 limit that nort of matched up to a repository.
But thoy 2
decided -- again, bocauno they wanted -- didn't want tho 3
idoa that thin in a long-torm storage facility, they stuck 4
with 15,000 motric tonn, a political docinion.
The yonely 5
rocoipts of 3600r that given them about fivo years of 6
oporation if they woron't to e id anything off-nito onco 7
they rocoivo it.
O Now, horo in whoro I show that thoy actually 9
havo coloctod, actually throu niton.
The proforrod nito in 10 Clinch Rivor.
And that in nort of a standard sizo, 1300 11 neron.
Tho "300 nocuro" monna that in whore tho fonco 12 surroundn the ntorago aron.
Tho nizo, protty big plant,
(
)
13 {
100 foot high, 600 foot long by 600 foot wido.
Vory largo 14 hot colls.
15 '
capacity, actually, thin figuro could bo the 16 namo an thin figuro.
A difforonco of 1000 tonn to bo 17 storago innido the plant.
Storago cank sizo, they aro la I talking primarily, concopt for ntorago would bo a cank.
19 200-ton cank of about 20 tonn of fuol in it and capacity of 20 liko 800 cank, with full storago, tho way they are looking 21 at it now.
no that in about la to 20 tonn of fuol innido 22 the cank.
23 docondary wanto volumo, kind of hard to non 24 that -- thorn in no intontion to rocoivo any wanto from 25,
off=nito, from tho roactors.
All' thin wanto that in i
Act!.FI:nttitAL R1:i'onTt:Rs. INC.
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generated, this secondary waste is generated by the 2
oporation within the MRS.
No truo wasto, no low-lovel 3
wasto.
Just high-lovel wasto.
So this is what they are 4
going to gonorato por year just by doing the operation.
5 They will store that on site on a specially-constructed 6
facilities for that storago.
7 MR. MOELLER:
It is low-lovel wasto really?
l l
8 MR. STEYER:
Woll, some of the wasto is in this 9
ill-dofinod category betwoon low lovel and high lovol.
And l
10 not nocossarily truo r it could bo just high gamma that is 11 not low lovol and right now they are calling that high 12 lovol.
It will be packagod the same as high-level wanto.
13 MR. SIESS:
Would this be all the parts of the 14 fuol assembly that -- except the rods?
15 MR. STEYER:
Yos.
16 MR. SIESS:
What about control rods?
17 MR. STEYER:
Control rods, they would be part of 10 that, tho secondary wasto.
19 MR. SIESS And they would bo part of the 20 secondary wanto.
21 MR. STEYER:
I don' t think they will try to 22 noparato control rods if it is a hard job to do.
If it in 23 oasy to soparato any piccos like that, they would.
24 MR. SIESS:
Dut all tho hardwaro thon?
/%
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25 MR. STEYER:
Yos.
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MR. MOELLER:
Why are they ignoring the
(
3 existence of this waste or -- by saying it must be stored 4
on site?
5 MR. STEYER:
Well, they would eventually send it 6
to a repository.
It would go with the high-lovel waste.
7 It would be called high-level waste.
I 8
MR. MOELLER:
All right.
9 MR. SIESS:
Would it be stored in shioided casks, 10 too?
11 MR. STEYER:
Yes, if it is hot enough.
12 MR. SIESS:
The same kind of caskn?
O 13 MR. STEYER:
Some will be stored in a drum if it j
14 is low enough.
Depends on the gamma energy y:au are looking 15 at.
The drums would be in a building.
If' it is classified i
16 as high level and is sealed the same way as high level, it 17 would be in the same kind of casks outside as the rods.
l 18 MR. SIESS:
And Part 72 is aufficient to --
19 MR. STEYER:
Yes.
I think I have a note on one 20 of these about what part covers it.
21 We have -- I will go back here again on 22 mechanical handling.
I have a viewgraph to show you the 23 Clinch River site.
This is Clinch River down here.
It is i
24 like a peninsula.
I think you may have seen that site.
It O
2s is rea11v 3use aheut the a e tocation as the reaceee.
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I think the reactor is going to be someplace right in here.
2 It is hard to tell.
So it is really pretty much the same 3
location.
4 The two other locations were Hartsville.
That 5
still could be a lo^ cation; and a site maybe about five 6
miles from the Clinch River site on the Oak Ridge i
l 7
reservation, virtually next door to the old Exxon site that j
8 we had been looking at. 'In fact, we had taken enough of a 9
look that we had some. conclusions about that site.
I am 10 sure they would extrapolate directly to the, nite that is 11 next to them.
So we think we also know something about 12 that third site.
13 MR. N0ELLER:
In the upper right, is that the 14 stored --
15 MR. CLARK:
Back here, yes.
16 MR. SIESS
That is the cask f ann.
17 MR. CLARK:
I think this thing should be i
18 reversed.
I think it really, I think it looks more like 19 that.
I don't know that it makes any difference.
That is 20 the tray it really looks.
So if you go down there you will 21 know where the --
1 22 MR. SIESSs Right now that is a hypothetical i
23
. site no --
24 MR. CLARK:
Okay.
One other thing, I think it
()
25
' would be worthwhile just to take a quick look at this,
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1 which is a cutaway of the main building, what they call the 2
receiving and handling building.
They were talking at one 3
time about 1800 tons per year and made a decision that they 4
wanted to go, as an integrated facility, to go to 3600.
So 5
they just sort of folded it over.
6 A lot of cask receiving here.
There are two 7
cells, apparently two large hot cells for doing the dirty 8
cells, rather shorthand, where a lot of the operation 9
involving consolidation would go on, two more cells just 10 like them on the other side.
This long cell here is a 11 clean cell where they, the assemblies are first packaged --
12 well, they are packaged inside here and welded over here, s/
13 then moved down to a lag storage area.
14 When they went to this larger design, they 15 decided to put 500 tons of lag storage on each side, a
16 total of 1000 tons total.
That is a lot of spent fuel 17 storage, in canisters with a helium-argon atmosphere.
?
18 Completely stored up but awaiting direct shipment to the 19 repository or to go out into storage.
20 On this end they have two more cells that are 21 somewhat similar to that where they could receive 22 high-level waste, could do some overpacking.
Other 23 operations and also ship out into transport casks or 24
' storage casks.
But you see here, this is essentially a
()'
25 storage cask.
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, '1 I think I have one more viewgraph that might be a
2
' helpful.
Essentially what we have been talking about, but 7-3 a little better idea of how it is going to work.
Using 4
thesi' cells, the weld station, moving down this way, 5
shipping out, everything a mirror image of the other thing.
6 I think this storage here is back on the other side, the 7
way I understand the layout.
'8 I have one viewgraph on the consolidation.
This 9
is the one thing, aspect that is a little bit different is, 10 f rom the other Part 72 applications.
But it is just
-m 11 preparing the assembly for storage and for ultimate 12 disposal by consolidation.
The maximum consolidation you
(~)%
(_
13 get is about a two for one.
That is, when you compress the 14 rods so they are all touching, you can save about 50 15 percent of the space you want to use..
16,
AR. SIESS:
You mean cut it in half?
17 MR. CLARK:
Cutit in half.
18 s
MR. SIESS:
Let me ask you something, if you 19s didn't consolidate it, all it would take would be a few 20 more acres of a slab out there?
As far as the MRS is e
21 concerned.- ConsoI-idation --
22 MR. CLARK:
It would take more acres.
23 MR. SIESS:
Is consolidation aimed at the 1
24 repository --
fs( )
25 MR. CLARK :
Consolidation is an economic measure i
ACE-FEDERAL REPORTERS, INC.
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2 MR. SIESS:
It couldn't be very economic just 3
for the MRS.
4 MR. CLARK:
I calculated about S800,000 saved on 5
containers alone.
800 million.
800 million.
6 MR. ROUSE:
Excuse me.
I think you are missing 7
the point.
Absolutely.
The only reason they are 8
consolidating fuel at MRS is because of the repository.
9 Each repository site and its specifications, if I can call 10 them that, today calls for consolidated spent fuel because 11 of this point that Tom makes:
Placement in the repository 12 itself, you save a lot of money if you have the number of
()
13 holes you have to put in them.
14 MR. SIESS:
You would need twice as many casks.
15 MR. CLARK:
Yes.
That is true.
16 MR. SIESS:
These concrete casks can't be that 17 big a Z:al.
18 MR. CLARK:
Did I say casks or containers?
19 MR. SIESS:
We haven't gotten to that.
20 MR. CLARK:
At $10,000 a container for the fuel,
~
21 I calculate it is something like $800 million saved.
22 MR. SIESS:
That is what goes in the concrete?
23 MR. CLARK:
Yes.
I am about to get to that 24 really.
7 BWR would be handled in a device such as this.
()
25 DOS has some development work to do before something like ACE-FEDERAL REPORTERS, INC.
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this really comes along.
But that is their present idea.
2 You have a strong back here to bring the fuel in an upright 3
position and make some cuts as necessary on top.
Some 4
assemblies can be unscrewed and some have to be cut to free 5
the rods.
Keep everything together until you lay it in a 6
horizontal position.
You come in with some collets and 7
affix every rod at the same time and three assemblies at 8
tne same time.
Pull.the rods, the three assemblies all at 9
one time.
10 There is a configuration that is hard to see 11 here, but when they get free of the framework, they are in 12 a trough with bands underneath them.
They are put into the 13 shape that would go right into the cylinder, which is the 14 disposal container.
15 This a butt next to the wall on the dirty side, 16 the wall on the clean side with the container on the other 17 side.
So then they push through, push through the rods 18 into the container on the other side, close the door, seal 19 it off, then they break the seal on the other side and move 20 it over to seal it up and move it into storage.
21 MR. SIESS:
This has to be done all remotely, 22 hands off?
23 MR. CLAEK:
Yes.
24 MR. SIESS:
And work for how many different f u'e l --
()
25 MR. CLARK:
I figure about 22.
ACE-FEDERAL REPORTERS, INC.
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1 MR. SIESS:
God.
2 MR. CLARK:
And they claim that they will be 3
able to handle every -- well, I think HTGR would be 4
separate, but all LWRs?
All LWR fuel.
5 MR. SIESS:
By any manufacturer of any vintage?
6 MR. CLARK:
Yes.
7 MR. SIESS:
And not something go wrong, huh?
8 MR. CLARK:
Well, I don't know about nothing 9
going wrong.
If they find damaged assemblies, they 10 wouldn't do this.
This is for essentially good essemblies.
11 If they are having trouble with an assembly, they will just 12 put it in a can by itself.
13 MR. SIESS:
Could you get in there to maintain 14 this equipment when there is no fuel in there?
15 MR. C LARK :
No, probably not.
16 MR. SIESS:
You mean once they close this thing 17 up they can't get back in it forever?
18 MR. CLARK:
Probably not.
19 MR. SIESS:
It has to work right the first time?
l 20 It sounds like GE Morris all over again.
21 MR. CLARK:
It does need to work.
They have 22 quite a bit of margin in their capacity figures.
If it 23 doesn't work at all, they would be in some trouble.
24 MR. SIESS:
How many of these lines?
)
()
25 MR. CLARK:
It would be four lines.
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1 MR. ROUSE:
I would like to add again on this 2
point, it is not apparent from that mass of lines there, 3
DOE's intent is to design a lot of modular construction in 4
there and actually, then, when you are receiving a PWR 8 by 5
8, you pull off the wall that module that fits that fuel.
6 So that is the concept.
As Tom indicates, they have got a 7
lot of development and demonstration to do yet.
8 MR. SIESS:
They don't just change the computer 9
program.
10 MR. MOELLER:
On that, you show the laser and 11 you or the DOE had analyzed various accidents that might 12 occur.
I read that maybe the laser could be misprogrammed.
(
13 Can you toll me a little bit what might happen.
14 MR. CLARK:
The laser makes cuts above the rods.
15 The laser is sort of the preferred choice right now.
I 16 don't think it has ever been used for this application.
We 17 were to see a laser demonstration down at Oak Ridge, but it 18 didn't work that day so they showed us a videotape.
The 19 laser sprays quite a bit of metal around.
So it has to be 20 confined somehow.
And what they are talking about doing, 21 if they use the laser, is they would like to get it down 22 inside the rod so that the spray doesn't go anyplace.
This 23 is really an open topic for us.
24 MR. SIESS:
There are mechanical means?
()
25 MR. C LARK :
About possible use of shrouds.
I 1
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don't know how it will turn out.
2 MR. MOELLER:
So you will be doing a lot more 3
review of that.
4 MR. CLARK:
At Oconee they used a mechanical 5
double-knife cutter to do the same operation.
That seemed 6
to work okay.
They did have a lot of crud come off.
That 7
was an underwater operation.
So there is work to be done.
8 MR. SIESS:
Salt would give you even more crud.
9 That would be a mess, wouldn't it?
10 MR. CLARK:
The next thing is passive storage.
1 11 This is the cask.
One reason I show this is because we use 12 the tent " monitored retrievable storage."
This is what
)
13 they are talking about from the standpoint of monitoring.
14 Air-sampling tube, the canisters are sitting in here with 15 inert gas.
In the gas comes out of the canister and gets 16 in the cavity, the sampler picks up -- that is why the 17 nelium is with the argon -- the helium is picked up as a 18 protection to understand you have a leaky canister.
They 19
.have temperature probes.
They could set it up so that all 20 of the casks are monitored in the control room at all times 21 or a fraction, and the same thing with sampling.
There has 22 not been a determination of --
23 MR. SIESS:
What is the path for the heat?
i 24 MR. CLARK:
For the heat?
()
25 MR. SIESS:
Radiation and convex to the cask?
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MR. CLARK:
Through the concrete.
I 2
MR. SIESS:
From the rods it is just radiation 3
convex to -- I assume it is a steel cask?
4 MR. CLARK:
Yes.
5 MR. SIESS:
Then there is an annulus between 6
that and the concrete?
7 MR. CLARK:
Yes.
8 MR. SIESS:
And then through the concrete.
9 MR. CLARK:
Right.
DOE has a program on this to --
{
10 was it the RREA casks?
l 11 MR. ROUSE:
Yes.
Right now the design would 12 hold 12 canisters, essentially 3 PWR per canister, so you i
13 would be holding 36 BWR in one ca r.k.
The calculations j
14 right now with those would show that you wouldn't exceed 15 the 370 or 380 C as a peak clad temperature.
j 16 MR. SIESS:
What would the concrete temperature 17 get to?
i 18 MR. CLARK:
It would be less than that.
In fact, 19 that is another open topic.
20 MR. SIESS:
It would have to be a lot less.
l 21 MR. ETHERINGTON:
Yes.
i i
22 MR. SIESS:
You don't really have to have any 23 significant strengths.
i 24 MR. ROUSE:
As Tom indicates, that temperature 1 ()
25 of the concrete and its behavior is an open question again.
4 i
i ACE-FEDERAL REPORTERS, INC.
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1 DOE is well aware of our interest.
2 MR. CLARK :
It is time and temperature.
3 MR. SIESS:
Roinforcement in the concrete?
4 MR. CLARK:
Yes.
There have been questions come 5
up, if you had long-term storage.
In fact, we had been 6
discussing with DOE 100 years, possibly, storage, how the 7
concrete would hold up at that temperature for such a long 8
period of time.
That is still an open topic.
9 MR. RIESS:
If the cask hald up we could always 10 take it out of one concrete container and put it in another.
11 They don't have to last for 100 years.
In fact, I don' t 12 see that anything has to last for 100 years, does it?
We O
13 could repackage it.
14 MR. ROUSE: 'As a matter of fact, the Waste 15 Policy Act very explicitly, when it talks about the MRS, 16 says, maintain safe storage, including replacement of 17 facilities.
You are absolutely right.
18 MR. SIESS:
You could have another hot cell that 19
.would take them out of one -- you call the inside thing the 20 container and the concrete the cask?
21 MR. C LARK :
Yes.
22 MR. SIESS:
Take them out of one and put them in 23 another.
24 MR. ROUSE:
That is right.
(3 f,,)
25 MR. MOELLER:
Well, the hundred years is an odd I
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number to be quoting when they assure us that the MRS is 2
represents an interim stage between the plant.
3 MR. CLARK:
Yes, we haven't been hearing 100 4
years --
5 MR. MOELLER:
It is in your material.
6 MR. SIESS:
I think that is what bothered some 7
people.
They thought it might end up ao a permanent 8
repository.
9 MR. ROUSE:
Clearly the concept that DOE has 10 been fighting all the way along is the fact that the MRS 11 would become de facto disposal.
That is the political 12 intent of those two provisions they have put in.
Limit I
i_/
13 tonnage and say, we won't receive fuel unless the 14 repository is on.
15 MR. SIESS:
If it is easier to site one of those 16 than it is a permanent repository, it will be.
17 MR. MOELLER:
Is the helium under pressure?
Or 18 what is the pressure in the canister?
19 MR. C LARK :
I think it is close to atmospheric 20 pressure.
21 MR. ROUSE:
It is actually a negative.
22 MR. SIESS:
You said if it leaked it went out 23 into the annulus, so it can't be negative.
It won't be 24 negative after it heats
.p.
25 MR. ROUSE:
That is true, it will be slightly ACE-FEDERAL REPORTERS, INC.
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1 positive.
That is correct.
2 MR. CLARK:
Okay.
The last item I had was 3
limited accident potential.
And that is related to other 4
parts of the fuel cycle that we looked at.
You could 5
compare it to something like a reprocessing plant.
It is a 6
lot of passive operations; about the worst thing that we 7
can see happening would be dropping three assemblies where 8
they all, all rods open up, release all that gas.
And we 9
have used a reactor-type analysis which we consider to be 10 quite conservative to arrive at estimates.
11 MR. SIESS:
How did you arrive at 3?
12 MR. C LARK :
That is canister -- not container, 13 rods.
So it would be 7 BWRs and 3 PWRs in, 14 such an accident.
15 MR. SIESS:
When this stuff comes in from a 16 plant, a truck cask carries what, 1 PWR?
17 MR. ROUSE:
There is one approved shipping cask 18 that will carry 3 PWR, But it is in that neighborhood, yes.
19
.1 to 3.
20 l MR. SIESS:
I know that the truck and the rail 21 carry quite a bit difference.
22 MR. ROUS E:
Yes.
23 MR. SIESS:
Is this all expected to come in by 24 re.il?
()
25 MR. CLARK:
50 percent rail, 50 percent truck.
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MR. SIESS:
Your chances for accident is in 2
handling to begin with.
Every time you use a crane.
There 3
is a chance in the hot cell which, of course, is a 4
containment.
And then there is the possibility in passive 5
storage.
Those are the three areas; am I right?
Is that 6
all?
7 MR. CLARK:
Well, let's see now.
I think that 8
takes me up to where Keith comes back again.
9 MR. SIESS:
I would like to comment on something, 10 I read the safety evaluation report on DOE's MRS proposal.
11 I don't know who wrote it, but that is probably the best 12 safety evaluation report I have ever read out of anywhere 13 in the NRC.
14 MR. ROUSE:
Dr. Siess, I thank you for that, but 15 you are looking at the guy; the primary author is Dr. Clark.
16 MR. SIESS:
It was an excellent job.
17 MR. CLARK:
Thank you.
/
18 MR. SIESS:
It told me everything I needed to 19 know and --
20 MR. STEYER:
We will cover primarily the 21 alterations of 72 to handle MRS briefly.
Viewgraph 1 is 22 based on the National Waste Policy Act which requires the 23 NRC to license these facilities.
And it is based on the 24 staff's conclusion in reviewing of these that the MRS --
([ )
25 the Part 72 provisions are adequate to handle the MRS, ACE-FEDERAL REPORTERS, INC.
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)
~ /
1 including high-level waste.
I have another slide that goes 2
into that justification, it is the next slide.
3 The changes also that we are adding in this 4
package that is presently with the Commission clarifies 5
certain issues that have arisen since Part 72 was made 6
effective back in 1980.
And we will discuss those later.
7 Finally there is some conforming amendments 8
which you can recognize if we put MRS in there.
There are 9
various performing amendments.
In fact, there is Parts 2, 10 19, 20, 21,.51, 70, 73, 75 and 150 would have to be changed, 11 mostly by adding appropriate language, ISFSI or MRS.
But 12 there are other ones which I will go into on another ps, (J
13 viewgraph.
14 So viewgraph 2 are the '-- viewgraph 2 primarily 15 relates to the changes in Part 72.
As I said earlier, it, 16 because it is really, as far as spent fuel, it is an ISFSI 17 under DOE control, we saw no reason why we couldn't use 18 Part 72.
However, because it can't be used to license l
19 high-level waste because it doesn't mention it, then our 20 additions are necessary to specifically cover that.
From 21 the technical viewpoint, solid high-level waste is not 22 significantly different from the storage of opent fuel.
We 23 will go into the reasons for that in the next viewgraph.
24 Finally, the next item is the Waste Policy Act
,~()
25 specifies that monitored retrievable storage facility ACE FEDERAL REPORTERS, INC.
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1 provide for long-torm storago of spent fuel or high-level 2
radioactive waste so it must be designed to accommodate l
3 both.
From civilian nuclear activities it must be designed 4
to permit continuous monitoring, management and maintenance 5
of such fuel and waste; provide for the ready retrieval of l
6 spent fuel and waste for further reprocessing or disposal; 7
and to safely store such material as long as necessary 8
through appropriate maintenance or replacement of the
(
9 installation.
10 The Staff has concluded that the license for an 11 MRS would be given for 40 years, recognizing that the 12 license for an ISFSI is presently, in the rule, for 20 l
)
13 years, but they can renew the license.
These are just 14 basically rather arbitrary.
15 There is no real technical reason for that, I
16 except that they should be satisfactory for 40 years.
17 Of course, none of these changes would become
)
18 ef fective until Congress agrees that they are going to 19 approve one of these things.
20 Why do we feel that solid high-level waste can 21 be put, covered the same way as spent fuel?
Well, we made 22 an environmental assessment in NUREG 0192 and that 23 environmental assessment concluded that it is comparable to 24 spent fuel in its heat generation and its radioactive
()
25 content on a per-metric-ton basis.
The storage of this ACE-FEDERAL REPORTERS, INC.
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solid high-level waste would not significantly affect the 2
anvironment.
3 In comparing high-level waste with spent fuel, 4
it was not really much different, primarily because, one, 5
it would be solidified in containers that can be handled 6
and stored similar to spent fuel containers.
The HLW form 7
would be equivalent to spent fuel as a leaching barrior; l
8 the heat and radioactivity associated with the HLW package 9
will be equivalent or less than the heat associated with I
10 packaged fuel.
There is no criticality problem because 11 there is no special nuclear material, if any.
And finally, 12 there is no radioactive gases in the spent fuel and little J
13 radiciodinc.
14 MR. MOELLER:
Excuse me, I notice here and I 15 noticed in the rewrite of part 72 '. hat you use this word 16
" radioactivity."
I realize it is a petty ax that I grind, 17 but like you say, the heat and radioactivity associated
?
18 with the high-level waste package will be equivalent or
~
19 less than the heat and radioactivity associated with the 20 packaged spent fuel.
I really don't know what that means.
21 I think what you are trying to say is that the heat and 22 quantity of radioactive material in a high-level waste 23 package might be roughly the same, or the heat and the 24 radiation, the number of photons per unit time coming off 25 is about the same.
But radioactivity is a property ACE-FEDERAL REPORTERS, INC.
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L) 1 possessed by radioactive materials.
And it is like culture l
2 or, you know, goodness or something.
It isn't what --
3 MR. STEYER:
Radiation is what we are really 4
saying.
5 MR. MOELLER:
Then I would say " radiation," the 6
heat and the gamma radiatien.
You really ought to say what 7
you mean.
t 8
MR. SIESS:
That is taken care of.
The 9
radioactivity produces heat; right?
10 MR. MOELLER: ' tR), radioactivity is a property of 11 the radioactive materials.
l 12 MR. SIESS:
Radioactive materials can produce
)
43 heat and radiation.
14 MR. MOELLER:
Correct.
15 MR. SIESS:
I see what your point is.
16 MR. STEYER:
We can certainly take care of that.
17 MR. MOELLER:
Radiation would satisfy me.
18 MR. STEYER:
The proposed rule restricts 19 high-level waste to a solid form.
And since Part 60 20 requires that the high-level waste be in solid form before 21 it is acceptable to the repository, we felt that it was a 22 logical thing to add to this.
23 MR. SIESS:
I can see where I should get some 24 feeling of comfort from the fact that there is no gas and
()
25 that there is no criticality problem, because those are ACE FEDERAL REPORTERS, INC.
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really two things you had to worry about on the others.
Am l
2 I supposed to get comfort from the fact that there is very 3
little iodine?
l 4
MR. STEYEd:
That is one of the main problems, 5
if it is released to the environment, because of the long l
6
- life, f
7 MR. SIESS:
The more I look at the source term 8
research, the more I am finding out that iodine, it is-a 9
surrogate for other things like cesium.
So --
10 MR. STEYER:
You don't get much comfort there.
11 MR. SIESS:
Is what you are trying to say is l
l 12 that things that are in there are less harmful to public l
13 health than --
l 14 MR. STEYER:
No, they are very harmful.
I think 15 we are saying, iodine being one of the more volatile 16 compounds, maybe not as volatile as the gases are, could be 17 released easier if the canisters were broken or somehow it
?
18 is released from the matrix of the --
19 MR. SIESS:
The source term would be less 20 dangerous than --
21 MR. STEYER:
From the standpoint of ease of l
22 movement from one place to another, yes.
23 MR. ROUSE:
I just have got to say something 24 again.
There is a little bit of overkill here going on
()
25 with respect to high-level waste and Part 72.
I want to ACE-FEDERAL REPORTERS, INC.
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make it very clear that there has been a lot of questions 2
and confusion on this point.
The only high-level waste in 3
the conventional sense of high-level waste that would be 4
expected to be received at MRS and perhaps stored is that 5
in West valley.
That is the only place we have any.
The 6
second point is that the Act is very explicit.
It does say, 7
commercial high-level waste.
Therefore, you cannot ship 8
Savannah River high-level waste to store at MRS.
It would 9
be a dumb thing to do anyway, I think.
]
10 MR. SIESS:
What is left over after what 11 reprocessing was done at West Valley?
12 MR. ROUSE:
They expect to end up with 300
\\
13 canisters of high-level waste at West Valley.
Surprisingly, J
14 to us, DOE, in its final proposal that it has prepared to 15 send to Congress, says they do not plan to receive any of i
16 that high-level waste.
J 17 MR. SIESS:
How much did you say?
18 MR. ROUSE:
300 canisters.
19 MR. SIESS:
I remember seeing somewhere that it 20 was a few percent of the total.
21 MR. ROUSE:
That is correct.
So -- while the 22 MRS could easily receive and store this very aged -- and I 23 think that is the point about the iodine -- this very old 24 high-level waste -- it doesn' t have a lot of heat output --
()
25 they could very easily receive and store that at MRS.
They ACE-FEDERAL REPORTERS, INC.
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surprised us in NRC by saying they don' t plan to receive 2
that.
3 MR. SIESS:
I assume that whatever review is 4
made of this will be documented in such a way that if l
5 somebody changes their mind in the year 2000, that they I
6 will know the basis for licensing this thing?
7 MR. ROUSE:
That is correct.
8 MR. SIESS:
I don't expect to be around then.
i 9
Mr. Etherington may be.
10 MR. ETHERINGTON:
It seems to me you have used 11 up the word " radiation."
Radiation has always meant 12 dissipation of heat.
That is what we are talking about in l
i 13 '
part.
Can't we find another word for radiation in the old t
l 14 sense?
15 MR. MOELLER:
You have got a point.
16 MR. ETHERINGTON:
Is there -- do we have to use 17 that word " radiation" in that sense?
18 MR. MOELLER:
I don't know of any other word.
19 MR. ETHERINGTON:
I don' t understand " radiation"?
i 20 MR. STEYER:
We will attach the word " gamma" i
l 21 with it.
22 MR. MOELLER:
That would help.
23 MR. ETHERINGTON:
Yes, that would help.
24 MR. MOELLER:
Gamma radiation.
l ()
25 MR. ETHERINGTON:
Yes.
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l MR. STEYER:
The next viewgraph relates to 2
clarifying certain issues that have aricen since Part 72 3
was made effective.
The general design criteria speaks in l
4 the old rule that the fuel cladding shall be protected 5
against degradation and gross rupture.
6 MR. SIESS:
By general design criteria, are you 7
talking about the Part 50 general design criteria or are 8
there general design criteria in here?
i 9
MR. STEYER:
All these things are in part 72, 10 and this is one in particular.
11 MR. CLARK:
Dr. Siess, that NUREG document we i
12 put out, 1168, I guess it is, most of the information in 13 there is based on the general design criteria in Part 72.
14 MR. STEYER:
This is one specific one that we 15 felt we had to change because we are talking about MRS.
16 Not only the MRS, but also ISFSIs.
Namely, that these 17 things are now casks above -- paragraph (b) -- the fuel 18 cladding shall be protected against degradation and gross 19 rupture.
This allows the the plants to be modified to 20 allow consideration of other types of confinement like 21 canisters.
The fuel cladding itself had to be protected.
22 MR. SIESS:
That change would affect both the 23 fuel and the high-level waste?
24 MR. STEYER:
Yes.
()
25 MR. SIESS:
The high-level waste doesn't have ACE. FEDERAL REPORTERS, INC.
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_O_REE 1
any cladding.
2 MR. STEYER:
The high-levol waste has no l
3 cladding but it has a canister.
l 4
The next item was related to emergency plans.
5 The next item -- the next item is tornado missiles.
That l
6 is where I was getting at.
It seems like -- well, you know l
7 the MRS is described as having these casks out on some pad i
j 8
and the present applications relate mostly to casks that we 9
felt that we couldn't leave in there that you -- that they 10 didn't need to be protected against tornado missles.
We 11 had to take that out, that they do need to be protected 12 against tornado'missles.
That sort of gave the flavor that 13 we were thinking about underwater storage when we put that 1
14
.i n.
That has to be taken out.
Maybe that is where you got 15 the idea about its bias toward underwater storage.
16 MR. SIESS:
Right.
l 17 MR. STEYER:
Okay.
The next thing is on the i
18 emergency plans.
And we don't refer to Appendix C.
We 19 have taken the appropriate parts of Appendix E and put it l
l 20 directly in here.
The Federal Register notice people don' t 21 like referencing between parts very much, and so that is 22 what we did on that one.
l 23 MR. ROUSE:
Could I interrupt?
24 MR. STEYER:
Yes.
( ()
25 MR. ROUSE:
Part 72 is, as you have it in front l
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1 of you, concludes that we can't find any reason, any need 2
for off-site planning.
When you go through the accident 3
analysis that Tom has for MRS or even for our ISFSIs, we 4
just can't get there.
Nevertheless, the Commission in 5
their comments, Chairman Paladino and Commissioner 6
Asselstino have both asked us to revise that to provide, to 7
some limited degree, some requirement or precaution for 8
off-site warning.
We haven' t decided quite how we are 9
going to handle that.
l 10 MR. STEYER:
Okay.
l l
11 f tR. MOELLER:
Now, you used in the 10 CFR 72 the 12 5 rem limit por accident.
In reading that, I could not 13 determine where you got it.- I see here that you --
14 MR. STEYER:
EPA.
I
?
15 MR. MOELLER:
Well, it is not the protective 16 action guide that EPA has proposed.
EPA, PAG of 1 to 5 rom 17 whole body simply says that if you projected a doso, that 18 the whole body dose will reach 5 rem, you should think 19 about evacuation.
20 You have taken that and now applied it in 21 somewhat a different way by saying, I guess sinco you 22 project that no single person would get as much as 5 rom 23 off-site, therefore, there is no need for off-sito 24 emergency planning; is that --
25 MR. ROUSE:
Actually, the 5 rem came out a l
ACE FEDERAL REPORTERS, INC.
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little different.
It was arbitrary.
At the time of the 2
development of Part 72 back in the late '78-79, we woro 3
also doing the generic environmental impact statement on 4
spent fuel storage.
At that time we went through accident 5
analysis.
You just couldn't soom to generato any 6
credible-type accident that would give you doses.
There 7
was also great reluctance, however, to use 25 rem of Part 8
100.
So somebody grabbed and said, 5 rem, that is the 9
highest occupation at dose we will generally permit in a 10 year.
That seems a reasonable design basis for selecting a 11 site and design of a facility.
It did not come about 12 because EPA was saying that.
7_
t
'd 13 MR. MOELLER:
It would help if you add an 1
14 asterisk and a footnote or something.
It would have helped 15 me.
16 MR. ROUSE:
You are probably right.
I think 17 overybody has boon a little reluctant to put down, we chose 18 5 rom because we didn't want 25 rom.
19 MR. MOELLER:
You gave me tho impression here 20 that 5 rom was what you considered ALARA for this type of 21 facility.
There was no reason to go to this type of 22 facility.
And then when you actually calculated it, of l
23 courso it is 25 millirem, or something, I still -- some 24 sort of a footnote would have helped me.
(,
25 MR. ROUSE:
We haven't touched that number.
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1 That was in the part 72 from the beginning.
We kind of 2
hate to raise the flag.
You just don't think the 3
rationale --
4 MR. MOELLER:
I thought in reading or hearing 5
Keith that it was tied into the EPA stuff.
It is not at 6
all.
I wouldn't hesitate to just say, we selected this as 7
a conservative number.
Then no one could argue with it.
8 Who can say it should be less?
It is a very conservative 9
number.
10 MR. STEYER:
The next item relates to the 11 quality assurance.
What we have done is basically lifted 12 Appendix B and changed what was appropriate and put it; in 13 this rule, in the body of the rule.
Again,,because they 14 don't like cross-referencing between parts.
15 MR. SIESS:
How much did you take out of 16 Appendix B?
17 MR. STEYER:
You mean remove from it?
Or put 18 from --
19 MR. SIESS:
How much did you leave out?
20 MR. STEYER:
Primarily only -- we didn't really 21 leave out -- well, a few lines that I can't quote to you, 22 but when I look at them they were not very important.
23 Everything that was the least bit significant is in there.
24 It is just that we dropped the terms " reactors" and --
7 25 MR. ROUSE:
There was two things that we did j
ACE FEDERAL REPORTERS, INC.
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I there.
There are a few lines dropped out.
Nothing was o
2 significant.
However, it was also made purposely to be 3
very consistent with the OA criteria of 10 CPR Part 71 for l
l 4
shipping casks.
5 MR. STEYER:
The other thing that is really in 6
there, it is the next item, that is --
7 MR. SIESS:
I think that is important.
Because 8
the people you are dealing with are more likely to be the 9
ones that are familiar with shipping casks.
10 MR. ROUSE:
The clause is written in Part 72 to 11 have the OA criteria.
However, if you have an approved 12 Appendix B OA plan, that is acceptable.
13 HR. STEYER:
That is right.
l 14 The last item here has to do with the terms 15 safety-related and important to safety.
That was the 16 change, that was one change we made in Appendix -- when we 17 switched over the stuff in Appendix B.
l i
l 18 MR. SIESS:
You removed " safety-related"?
19 MR. STEYER:
We had both terms in there and we 20 decided to use only the word "important to safety" because 21 we felt safety-related had a special reactor --
i 22 MR. SIESS:
As I recall, the reactor GECs use l
l 23 both.
That has been part of the problem?
24 MR. ROUSE:
That is correct.
()
25 MR. SIESS:
They have a general reference to ACE FEDERAL REPORTERS, INC.
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26137.0 53 1
"impo r tant to safety" and they hsvo " safety-related" 2
defined strictly in terms of reactor behavior.
So you left 3
that out.
But you still intend that "important to safety" 4
be a level of importance equivalent to what was called 5
" safety-related"?
6 MR. ROUSE:
It is a graded thing.
But when you 7
come to the cask, certainly, the structure, yes, that is 8
Correct.
9 MR. SIESS:
Did your GECs use either term.
It 10 uses "important to safety" and --
11 MR. ROUSE:
It uses "important to safety" only.
12 At the present time, existing Part 72 uses those changes, i
i e
13 i those terms interchangeably.
That, as you are aware, has i
14 been a big argument from the Part 50 standpoint.
15 MR. SIESS:
Okay.
That also comes up in the OA 16 part?
17 MR. ETHERINGTON:
Will you tell me again what 18 the safety-related means?
19 MR. SIESS:
Yes.
GDC's refers to important to 20 safety.
" Safety-related" is defined as those features 21 which can cause an accident or are required to mitigate an 22 accident.
And I forget what the third one is.
23 MR. PEARSON:
Dose levels -- equivalent to, potentially equivalent to dose levels in Appendix C.
i 24
\\
25 MR. SIESS:
Yes.
The safety-related were strict ACE-FEDERAL REPORTERS, INC.
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definitions of systems components or structures in terms of 2
reactor accidents.
3 MR. ETHERINGTON:
Is that definition somewhere 4
in the --
5 MR. SIESS:
Yes.
6 MR. STEYER:
That is in Part 50.
7 MR. ROUSE:
There is a proposed rule that was f
8 sent down to the Commission dealing with that aspect.
It l
9 has that definition in it.
10 MR. SIESS:
And there has been one around for 11 four years now and nobody has done anything about it yet.
12
" Safety-related" is defined in the regular guide --
r I
13 MR. ROUSE:
We were told by the EDO to make sure 14 that our rules, Part 72, 70, 71, Part 60 were consistent 15 with the new interpretation -- at least the present 16 interpretation of safety-related.
And this would do that.
17 MR. SIESS:
Safety-related was essentially 18 equivalent to seismic category 1.
It was always defined in i
19 terms of pressure boundary and an accident mitigation, 20 accident cause.
I see your point.
I think it is 21 appropriate.
22 MR. MOELLER:
Excuse me.
What are the dose 23 limits that you are going to apply here for the general 24 I public?
<^x I
25 '
MR. PEARSON:
The equivalent to the EPA 140.
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1 MR. MOELLER:
Say it is the 25 millirem.
On
~
2 page 369, you say in the last line, " Releases of 3
radioactive particulate material and gases would be limited 4
.so that exposures to operating personnel and the public 5
would be within the limits in 10 CFR 20."
6 Now, one of the reasons for revising or the 7
proposed revision of 10 CFR 20,. which is currently out for 8
public comment,.is that it has no limits for the public.
9 11R. PEARSON:
It incorporated the 40 CFR 190.
10 MR. MOELLER:
This does here?
11 MR. PEARSON:
These are equivalent.
12 MR. MOELLER:
Your revised --
(
13 MR. STEYER:
Yes.
We are going to use the 14 limits.
15 MR. MOELLER:
But you aro saying that releases 16 of radioactive material would be limited so that exposure 17 to operating personnel and the public would be within 10 i
18 CFR 20 and 10 CFR 72.
Well, it probably should have said 19 "respectively," because the worker is in" 10 CFR 20, the 20 public is not.
21 MR. STEYER:
You you are right.
22 MR. MOELLER:
Now if the public is in 10 CFR 23 Part 72 --
24 MR. STEYER:
For the public it is --
()
25 MR. MOELL'ER:
Which is 25.
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1 MR. STEYER:
~Yes.
2 MR. MOELLER:
Okay, we are all right.
D
^ ~
3 MR. sIESS:
Respectively.
.,g 4
MR. MOELLER:
The other thing that that is going 5
to get you into, into a pickle or into a problem downstream --
6 it is a minor one, but if you use 40 CFR 190, you are using 7
25 millirem whole body and 75 millirem thyroid, and that is 8
not compatible with the proposed revised 10 CFR 20 for the 9
weighting f actors.
It is no great --
10 MR. STEYER:
When, I guess, 20 gets formalized,
11 then we would have to come back and modify that.
12 7_3
,M R. PEARSON:
Would that require EPA to change
(
)
13 40 CFR 190?
14 MR. MOELLER:
I don't know.
That is a good 15 point, too.
You are going to have 10 CFR 20 not comparable 16 with 190, in terms of organ versus whole body.
17 MR. STEYER:
The last viewgraph has to do with 18 confirming amendments.
The main thing in here is that we i
19 have to get Part 51 to agree with certain limitations and l
20 things that are in the Act.
51 is environmental.
21 MR. PEARSON:
The major thing in the conforming 22 amendments in 51 are certain limitations that are specified l
23 in the NWPA regarding environmental reports, environmental i
)
24 impact statements, final.
And that basically was the
/
\\
's_J 25 thrust of that slide.
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,_REE x-1 MR. STEYER:
Congress says you do not have to 2
look a't alternatives.
They have said that they are going h
3 to.have an MRS.
So I won't go into that in any degree.
4 The nex,t item is general design criteria.
5 MR. SIESS:
Would this be -a good time for a 6
break?
You are now getting into the Part 72 and not just l
j' 7
the changes.
Am I right?
I 8
MR. STEYER:
Some changes, i
9 MR. SIESS:
Ua will have a chance to get an 10 overview as well as the changes.
Let's take 15 minutes or 11 so.
12 (Recess.)
(
)
13 l MR. SIESS:
Why don't we s. art without A
'14 Dr. Moeller.
He should be back shortly.
15 MR. STEYER:
The viewgraph 5 is primarily 16 related to changes to the general design criteria that 17 relate to -- paragraph (b),
6, relate to the licensing of 18 MRSS, and the first one in the general consideration is the 19 topic I have discussed.
That is, that the high-level waste 3
20 at an MRS must be a solid form.
And if it is stored in a 21 water pool, it must be compatible with water.
22 The next item is an overall requirement, as I i
23 also mentioned earlier, that we allow canning as well as l
24 only depending on protection of the cladding against 25 degradation and gross rupture, and we added a paragraph
'\\
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1 requiring monitoring of the storage system to determine 2
when corrective action is needed.
3 Another paragraph added is require ready 4
retrieval of high level radioactive waste, and also one to 5
require ready retrieval of spent fuel.
6 Under the new criticality safety, we broadened 7
that to eliminate the implication that we were only 8
considering water pools.
We are considering all kinds of 9
storage facilities.
10 The next item in the radiological protection and 11 some of the others; namely, on criteria for spent fuel 12 waste and other radioactive storage and handling 'and the
/
i
' -/
13 criteria for decommissioning are unchanged except that we' 14 add the language that says they must include high, level 15 waste in those criteria.
16 The last -- okay.
Now, with respect to the hot 17 general design criteria in Part 72, there are around 16, 17 18 separate topics.
I wasn't.specifically going to speak to 19 each of them, but, for example, the first one is, applicant I
l 20 must provide design criteria based on the general design l
21 criteria.
22 The second one is quality standards must be 23 commensurate with the importance to safety.
These tend to 24 be that kind of a general statement.
They must protect
<x I
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l 25 against environmental conditions and natural phenomena.
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might be interested in.
I guess I have a little story to 2
tell if you don' t mind.
That is, that we started a PRA 3
program for the fue.1 cycle three years back in the research 4
office.
I guess I felt like I was instrumental in bringing 5
that about.
After just getting the program started, it was --
6 the purpose of the program was to develop PRA methods.
7 That is, the question was:
How do you know how to go about 8
analyzing the fuel cycle?
And we needed to get 9
recommendations from the experts as to how to go about i *.
10 first.
So it was really a two-phased program:
Phase 1 11 with some recommendation as to whether you would go to 12 phase 2 and apply the methods and determine what the risks
)
13 were in the fuel cycle.
We had gotten part way through 14 phase 1 and the program was stopped.
So we really don't 15 even have methods at the moment.
16 It is my understanding from reading the 17 literature from the Commission and the ACRS that they 18 l thought that looking at risk to the fuel cycle that 19 reactors essentially were more important and there was no 20 need to put funding in this area.
The program was 21 terminated, and if you read again the memos, it says, "with 22 no intent to restart the programs."
23 So as far as --
24 MR. SIESS:
I was going to say, I could explain 25 why we raised the issue with PRA.
There are several ACE-FEDERAL REPORTERS, INC.
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26137.0 59 EE 1
And so on, protect against fires and explosions.
2 They can't share with other systems and 3
structures where there might be an interaction that would 4
affect safety.
If they are near a site that has other 5
cites with radioactive facilities dealing with radioactive 6
materials, then they must consider the cumulative effects 7
of releases of those, from all in an area, which is sort of 8
related, again, to Part 40, 190.
9 And then there is a section on instrument and 10 control systems, control rooms, control areas, that is kind 11 of aimed more at, again, at pools, but can be broadened.
12 Utilities, critical safety and so on, I don't know exactly 7~,
)
13 what you would want to di.' cuss on those.
They tend to be 14 very general.
15 MR. SIESS:
I think for now we might not spend 16 much time on it.
Maybe at some other point we will want to 17 include subpart F item by item.
18 MR. STEYER:
All right.
l 19 Now, as part of the program this afternoon 20 relating to general design criteria, there was some 21 interest on what we are doing with PRAs and transuranics.
22 Dr. Clark is going to speak on those topics.
23 MR. CLARK:
I am Tom Clark in NMSS.
Lee Rouse 24 is passing out the -- just a copy of what I am showing here
( 'N 25 on PRA.
I guess we are not quite sure what the committee ACE. FEDERAL REPORTERS, INC.
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I reasons, not all of them well coordinated.
An obvious one 2
was that we are up to our necks in PRAs in reactors.
The 3
question will come up:
We are doing it in one place, why 4
not in another?
If we think there is no risk, how do we 5
know without having done an PRA.
6 There are other aspects of things we are 7
reviewing on reactors that are going to spill over:
In 8
seismic design, the ACRA has pursued the issue at length of 9
seismic margins.
The basic question is, we design for an 10 SSE, but there is always some uncertainty.
We know we have 11 capacity beyond the SSE.
But are we on the edge of a cliff?
12 Is it possible that something greater than the SSE, which 13 is not impossible, only less probable, could cause a 14 serious accident?
15 Of course, the or.ly way to approach that issue 16 without just raising the SSE is to look at it on a 17 probabilistic basis.
So it has turned out to be a way of 18 putting things into perspective.
19 We also find, in looking at reactor plants, that 20 the PRAs are a good way of bringing out those places where 21 the greatest contributors to risk, some of which are very 22 easily fixed --
23 MR. CLARK:
I have been instructed on those 24 points.
( })
25 MR. SIESS:
So there is a whole spectrum of 4
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26137.0 62 REE tv things.
The pitfalls in this, of course, the major pitfall 1
is that we end up 'in 'eactors now having two sets of 2
r 3
' criteria for licensing.
We have 'a deterministic set, 4
standard review plan -- whatever you want to call it -- reg 5
guidest then we have a probabilistic set called a severe 6
accident policy.
7 Now, this dual level, dual set of criteria is a 8
real problem as our prescriptive requirements were not 9
established on the same basis as others, they could lead to i
Y 10 contradictions or at the worst, confusions -- at the best, 11 perhaps.
I just felt that PRA was going to come up.
It 1
12 will come up in anything that is probabilistic, like
(~h k _/
13 earthquakes, like tornadoes, missiles, like floods, because i
14 you can't get away from probabilities.
l l
15 MR. CLARK:
Okay.
I think I am addressing part l
16 of what we are talking about here.
After the termination, 17 we got some reports out.
So we did get some sort of 18 product.
One of the reports, that was a risk ranking.
It 19 doesn't do it based on having all the PRA methods worked 20 out, but it does it based on people's understanding of the 21 fuel cycle.
Not only NRC, but other groups like P&L, SAIC, 22 I forget who else was involved in that.
But we had a 23 number of meetings on this topic.
24 I think, in general, I would say that the risk
()
25 ranking, there is some agreement about that.
One could ACE. FEDERAL REPORTERS, INC.
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1 look at that and find out that reactors are well above 2
anything on our list in fuel cycle.
You could be looking i
3 at reprocessing plants, and way down toward the bottom is i
4 spent fuel storage.
So if one is going to spend money 5
based on what you think the real risk is, it might be one 6
of the last things you spend money on.
So we are not doing I
7 anything.
That would be the last of anything.
So that is 8
how that study came out.
I can make those reports i
I 9
available.
l l
10 The other thing that I thought was worth l
l 11 mentioning, we felt like we were the earliest people to l
12 look at what happens when you go beyond design basis.
I 13 have worked on West Valley for quite a number of years.
We
(
l 14 looked at four different facilities there:
The main 15 reprocessing plant, spent fuel storage, high-level waste 16 tanks.
And we had Livermore and Los Alamos do analysis 17 upon facilities that were designed to Code Zone 3 and took 18 them up to 2/10ths G, which was the performed G value for 19 the site, and discovered that plants designed -- my guess 20 at what the G value would have been for the design would j
21 have been in the range of.04,
.05.
22 They were finding that up to.2 G that we would 1
23 have cracks develop in the plant, but if the fans kept 24 running actually the plant was still serving the purpose.
l
( )s 25 That is, it didn't crumble right away when you get beyond l
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design.
2 I am sure that fragility studies on reactors 3
have seen that sort of thing.
If you look at WASH-1400, 4
there was some mention by Newmark and Hall about wnat they 5
thought happened to systems when they went beyond design 6
basis.
7 We also looked at components, looking at the 8
effects of flooding, earthquake, tornado, and came to some l
9 similar-type conclusions that when you get well beyond 10 design, you are still, you still have some kind of 11 protection.
12
,7 s We did also tornado on West Valley.
13 So I think we used that to some extent in our 14 understanding of what we are faced here with spent fuel 15 storage.
That we know something about the risk.
I don' t 16 think that you have to do a full PRA to have some 17 understanding in an engineering sense of what the risk is 18 there.
A lot of passive systems -- there are a few parts 19 of the MRS that I would want to look at some more carefully 20 as regards heat transfer for stored fuel, but we will do 21 that.
I don't know that we need PRA for that.
22 So I guess our outlook right now is that we have 23 no intention on the MRS certainly, of doing a PRA.
Not 24 that it couldn't be done, but these are the reasons why we c
25 had no intention.
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MR. SIESS:
So on natural phenomena, you have 2
looked at frequencies and you have looked at margins.
Did 3
you look at floods?
4 MR. CLARK:
For West Valley the flood was real 5
oasy.
It is up high and -- that has boon looked at, but it 6
is not really a problem there.
7 MR. SIESS:
One of the first jobs I had with the 8
railroad, I checked the bridge of the New York Central 9
across Cattaraugus Creek.
I never heard of it before until 10 I heard of West Valley.
11 At other cites, I assume the design criteria all 12 for probably maximum flood.
That is still an issue with 7_
13 the ACRS as to actually what probability to assign to a PMF.
14 And that is a case where f requently your margins are a 15 cliff.
You are protected up to some flood level and then 16 you are not.
The consequences of the flood would be 17 something olso.
18 MR. CLARK:
Let's think about this from a 19 practical standpoint.
GE Morris has boon dono, that 20 analysis is over.
They mot reactor criteria there.
And so 21 does overything also.
All of the dry storage at reactor 22 sitos moot reactor critoria.
The sitos they have chosen so 23 far also meet reactor critoria.
So in a practical senso, 24 for natural phenomena, it is over.
There is not much moro
[i 25 to do.
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MR. SIESS:
By saying you meet the reactor 2
criteria -- but the ACRS has questioned some of thoso.
3 This is the kind of thing you will run into.
We would like 4
to exploro this a little bit.
You see, you probably have a 5
similar situation if you do exceed a flood, your design 6
flood, then what are the consequences.
This is --
7 MR. CLARK:
I looked at that for Morris.
It is 8
a water storage so I never thought it was a big problem.
9 It is a problem for dry storage.
You would not want to 10 have a high flood with dry storage.
11 MR. ROUSE:
I want to interrupt.
12 MR. SIESS:
You do have canisters.
7s 13 MR. CLARK:
I was thinking of MRS.
14 MR. ROUSE:
That is what I am talking about.
He 15 used dry storage.
Uo don't soo any particular problem with 16 flood at the ISFSIs that we may have, the dry storago of 17 reactors in the individual casks.
A flood at MRS is not 18 the cask.
The flood at MRS, remember you have some lag 19 storage in that facility.
That criticality analysis is 20 based on no water.
That is a thing that Tom and I have 21 agreed deservos a lot of attention.
22 MR. SIESS:
Soo if a flood above the design 23 lovel could causa a catastrocho, then it is important.
24 This is what I mean by risk assessment.
x 25 In the reactor plants, one of our major concerns ACE. FEDERAL REPORTERS, INC.
26137.0 67 REE
/"%U 1
1 with floods is simply active components no longer working, 2
short-out of an electrical system or something at that sort.
3 Have you looked at this from that standpoint?
You have got 4
your ventilation for your hot cells and --
I 5
MR. CLARK:
Yes.
Certainly.
The main thing you 6
are looking for in a plant like this, there are some dirty 7
cells and so you want to confine that radioactivity.
And 8
so you look at the basic structure, which would be.25 G 9
for the site or where it is going to be.
And the point of 10 this thing about West Valley is you know there are 11 substantial margins beyond that.25 G.
I think in fact --
12 MR. SIESS:
You are still talking flood where
(
13 you don't have margin.
14 MR. CLARK:
I am not quite sure about the margin 15 there.
I know the way it stands at PMF, it is 16 substantially above it.
17 MR. SIESS:
I am talking about any plant now.
18 Many plants, many reactor plants are designed for the PMF.
19 Some of them have just backfitted for PMF.
If it gets a i
20 foot higher than that, inches higher than that, there is 21 water coming in.
So it is a "go/no go" type of operation.
22 Now, if you are up to 10 to the minus 80 23 exceeding the PMF, forget about it.
If you are 10 to the 24 minus 3 or 10 to the minus 4, you think about it.
()
25 One problem is that nobody really knows how to i
l
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assign a frequency to a PMF.
A PMF is not a 2
probabilistically-derived quantity.
It is a conservative, 3
in quotes, deterministically-derived --
4 MR. ROBERTS:
The NRC has a contract now with 5
the National Academy of Science to investigate this problem i
l 6
of how we can do a probabilistic equivalent to the PMF with 7
the concern with the margin.
But that study is nowhere l
8 complete.
We are aware of the problem and we are working i
9 on it.
10 MR. SIESS:
It is no different here than it is l
l 11 in the -- I say it is no different.
It may be different.
i 12 This is not a reactor plant.
It may be you can flood the
.{
l 13 plant for a week, get in there and pump it out and nobody 14 will be harmed.
I don' t know.
You have to look at it.
15 MR. BERATAN:
Keep it out of'the flood plane, 16 too.
That would eliminate --
(
r 17 MR. SIESS:
Originally when we thought we were 18 doing these as pools, there were very few of them and you 19 could use optimum sites.
Now you have to use the reactors.
l 20 MR. SIESS:
I think the PMF issue, I know about 21 the Clinch River site.
If they had the PMF at that site, 22 there are a couple of fair-size cities that are under 20 23 feet of water.
But, again, that is not our job.
The 24 people that shield it, you know, --
l (
l 25 MR. ROBERTS:
I would just like to say, I think
/
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26137.0 69 1
there may not be an appreciation -- with respect to the dry 2
storare licensing of reactors, the fuel is loaded in the 3
pool so the presence of water is subcritical.
In the 4
designs of like these casks and of the canister that we 5
talked about, that can withstand a static water height of 6
407 feet above the canister.
I don't think we have got a 7
problem here with passive storage.
8 MR. SIESS:
I don't think the --
9 MR. ROBERTS:
And these happen to be --
10 MR. SIESS:
I think you can easily establish 11 that the storage casks are not a real problem.
You can 12 think of other things -- you are not going to throw them O
13 away, you are are not going to flood them.
They are sealed.
14 You will lose instrumentation, but you can go back and 15 recover that.
There is one thing you may not have thought 16 about but if it is a sufficient flood at the proper site, 17 you could have barges coming down and banging into them.
18 If you are not sure of what I mean by that, you can look at 19 the Hope Creek licensing review by NRR and they are 20 worrying about barges coming down on the flood and getting 21 onto the site and ramming into things.
So there are 22 physical things, but those would be looked at.
23 I think the thing you need to look at more, 24 perhaps, is the active components:
fans, cooling systems,
()
25 things that can be shorted out.
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'v) 1 MR. ROUSE:
I agree.
I think with respect to 2
ALARA, we have some of those types of equipment in the 3
systems that we would have to look at.
I think I agree 4
with you on that.
5 There is some ongoing discussion with respect to 1
j 6
DOE, the MRS design, as to the need for some of these 7
utility services that, you know, under abnormal conditions, l
8 and that is --
l 9
MR. SIESS:
That would be a part of your review.
10 MR. ROUSE:
Yes.
11 MR. SIESS:
I am bringing up things that may l
12 come up in an ACRS discussion.
There are 14 people on that 13 committee and I am trying to think of the questions they t
l 14 may 'ask and see how many of them we can get rid of before 15 you -- well, that is not really right.
We never get rid of 16 them.
We just get you prepared, I guess.
l l
17 MR. CLARK:
Is that enough on that topic?
(
18 MR. SIESS:
Yes.
I think enough to understand 19 what you are doing.
The PRA as such, the argument there is 20 that the total risk is so small that it is hardly worth l
21 trying to quantify.
Doing a PRA to look for outliers or l
l 22 look for weak spots or other ways of doing that, there are 23 other things you can do.
A failure modes effects analysis, 24 that sort of thing.
25 This extreme phenomena, I had raised a question --
I ACE. FEDERAL REPORTERS, INC.
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l we had been talking seismic margins on ACRS on reactors for 2
quite awhile and we are beginning to get a certain level of P
3 comfort out of studies that have been made under the 4
so-called S00G programs components subjected to larce 5
earthquakes to see how well they come through.
The valves 6
don't do so good even when there is not an earthquake.
7 So we have developed a list of equipment that i
l 8
seemed to be pretty well qualified simply by experience.
1 l
9 One thought was, is there likely to be equipment in the MRS 10 for which there would be no good counterpart in plants of i
l 11 other types that have been subjected to large earthquakes, l
12 or if there is such equipment, but it wasn't in power O
13 plants, could somebody take a id'ok at it?
The seismic i
14 margin problem is not going to go away as long as we are on 1
15 the East Coast and as long as we are anywhere near 16 Charleston.
17 MR. CLARK:
If you are looking at a structure 18 that survives and filters are in place, even if the fans l
19 failed, you are in pretty good shape.
You still have got a 20 confinement really.
It is not too much to worry about.
I 21 don't think you need much more than that.
22 MR. SIESS:
That will be a subject that 23 eventually will come up I think at the time we review the j
24 MRS.
But I think Part 72 probably fairly well covers it.
j 25 MR. ROUSE:
Yes.
I think we have the criteria i
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there.
2 HR. SIESS:
These are issues that are outside 3
the present framework of licensing.
There is nothing in 4
the present process that says you've got to look at seismic l
5 margins.
6 MR. CLARK:
No, there is not.
7 MR. SIESS:
But that doesn't stop the ACRS from 8
putting you on the grill for an hour about it and raising i
9 it in their letters.
I am just warning you.
10 MR. CLARK:
That tskes care of that one.
11 I think the other topic was TRU waste.
I think l
12 I already mentioned that there is no intent to receive
()
13 anything.
It is all secondary waste.
14 MR. SIESS:
I think you could just replaco TRU 15 by high-level.
There is not much distinction in my mind.
16 Your SER did address two categories of TRU.
What were 17 they --
l 18 MR. CLARK:
Contact-handled and remote-handled.
19 That is all handled in the opening.
Stored on site and as 20 I said before, if it is above Part 61 specifications, it 21 would be high-level waste right now and would go to a 22 repository.
It is packaged the same way.
23 MR. SIESS:
So you would just say TRU is 24 high-level waste?
25 MR. CLARK:
That is what D00 is saying.
i l
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1 MR. SIESS:
And you alrosdy made a justification 2
for high-level, for how Part 72 would apply to high-level 3
wasto, why high-level waste would be no worso than spent 4
fuel?
5 MR. CLARK :
Well, I am getting confused now.
Wo 6
are talking about a wasto that is secondary wasto that is 7
not what I would call high-level wasto -- tho stuff that 8
Leo was talking about that came from Host Valloy.
This is 9
a waste that is higher than low-level which right now in a 10 way has no category, but because there is no categorization, 11 DOE says we will call it high-levol waste because wo don't 12 know what else to call it.
(
l 13 MR. SIESS:
Put my question in this gontext:
14 Part 72 was writton for spent fuel.
Any' thing that is not 15 spent fuel you think you are covering?
16 MR. ROUSE:
Yes.
I would like to speak to that.
17 Wo think wo are covering Part 72.
You may be well aware 18 that out of the Wasto Act comes the opportunity for the NRC 19 to rodofino its definition of high-level wasto.
The Staff, 20 now under Mr. Davis, our offico director, is indued working 21 with rosearch on a rodofinition of high-level wasto.
That 22 in offect has boon impacted by the recent amendment 23 Congrass passed for low-level wanto because they havo 24 designated DOE to take over anything above class C of Part 25 61.
So it is sort of a moss right now.
ACE FEDERAL REponTEns, INC.
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All I am saying is, whatever they como out with, 2
we think wo have the critoria in Part 72 to deal with the 3
receipt, handling and storago --
4 MR. CLARK:
Thoro is a section in the general 5
design critoria that covers those kinds of waste.
That is 6
whoro it is covered.
7 MR. SIESS:
Is spent fuel a high-level wanto?
8 MR. STEYER:
The Commission has defined it as 9
such.
10 MR. PEARSON:
It is defined as --
11 MR. ROUSE:
The Commission, a few yours ago, 12 mado a finding that spent fuel should be considered 13 f high-level wacto.
However, the Waste Act now providos two 14 different definitions.
So that is a little bit --
15 MR. SIESS:
Ono for spent fuel and one for --
16 MR. PEARSON:
The proposed Part 72 usos tho 17 definition that is in tho Act.
It says the first liquid --
18 I moan liquid for first extraction from high radioactivity 19 and solidified materials from thoso, plus whatever the 20 Commission defines to be high-level wasto.
Presumably 21 spent fuel is high-loval wasto under cortain conditions 22 since the Commission has defined that.
If they defino tho 23 cthors to bo high-lovol wasto, then it is covorod.
24 In other words, what I am anying, Part 72 both 25 technically and procedurally is acceptable.
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MR. SIESS:
Okay.
And physically you consider 2
it --
3 MR. CLARK:
DOE is certainly waiting for 4
instructions from us as to whethor or not this is a 5
different category.
That is the only way they can handle 6
it right now.
7 HR. STEYER:
If somobody --
8 MR. SIESS:
How do you propose to store tho 9
high-level wasto?
In the samo kind of canistors and casks 10 as the spent fuel?
11 MR. CLARK:
Yes.
12 MR. SIESS:
Just pack it into the same thing.
13 The same limits on kilowatts?
H'igh levdl doesn't gonorato --
14 MR. CLARK:
I am trying to think of which 15 high-level you are talking about.
16 MR. STEYER:
High-level has got fission products.
17 MR. CLARK:
The secondary wouldn't have that 1
18 much high-levol wasto from Host Valloy.
19 MR. PEARSON:
T lot of radiation.
20 MR. CLARK:
As I recall, something like 3-to 21 400 watts por canister is what wo are talking about.
22 MR. SIESS:
Instead of what, 16 kilowatts?
23 MR. ROBERTS:
Kilowatt fc fivo-year-old fuel.
24 MR. ROUSC:
The PWR assembly, fivo-year decay, 1
(
)
25 kw por assembly.
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1 MR. SIESS:
This would be a fraction of that for 2
heat.
3 MR. CLARK:
Anything for more on that?
4 MR. SIESS:
Is there a limit on tho surf aco 5
radiation on the casks?
Which kind of radiation?
7 MR. SIESS:
The kind they go out and moasure on 8
a fuel cask, whatever that is.
9 MR. ROUSE:
The design of the MRS cask comes out 10 about --
11 MR. SIESS:
I mean in Part 72.
12 MR. ROUSE:
No, thoro is no specific requiremont
(
,13 other than under general donign critoria it has to be 14 analyzod.
15 MR. SIESS:
You wore thinking of water storago?
16 MR. ROUSE:
No, I probably wouldn't put a number 17 in, in any caso.
18 MR. SIESS:
Evon for protection of the workor.
19 MR. ROUSE:
Thoro is design critoria and thoro 20 are requi. rants to the ALARA.
So that is the way wo aro 21 dealing with it.
22 MR. SIESS:
All those thermocouples and things 23 road remotely or doos somebody have to go in?
24 HR. ROUSE:
They go look at it.
And tho dono l
25 rato on the curface of thoso casks is loan than 20 man-rom ACE. FEDERAL REPORTERS, INC.
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por hour.
So the main rosson thoy havo to do that is 2
becauso you have to thinx an array.
One of the limiting 3
critoria, you are going to have an array of those and then 4
you have the off-sito doso to considor.
Thus you can't 5
have a very high doso rato from a single cask without 6
getting into trouble later on.
7 MR. STEYER:
Viowgraph 7 is design-basis 8
accidents.
Three difforont NURECs have examined this thing.
9 One is "Gonoric environmontal impact statomont on handling 10 and storage of spent fuel."
Another one is on the safety 11 report related to the Morris oporation.
Thoso woro 12 pool-typo.
And then thoro was another one, "A regulatory
~s 13 l nnalysis on omorgency preparodness for fuol cycle and other I
14 radioactivo matorial licensoos," which relatos to the dry i
1 15 storago.
16 Dasically, the conditions in all those assumod 17 that there is 10 porcent of the krypton-85 availablo in the i
18 I fuoi to be roloasod.
1 porcont of iodino-129 is availablo.
19 Fuel burn-up is 33,000 megawatt days por motric ton of 20 uranium.
The fuoi is cooled long enough to allow 21 short-lived activity which is over ono year.
And to docay.
22 And finally, conservativo motoorology.
And in all casos 23 the dosos thet como out of that aro well below the EPA 24 guidolinos.
25 MR. SICSS:
ilhat are the physical phonomons that ACE.17EDERAL REPORTERS, INC.
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lead you to thoso releasos?
2 MR. PEARSON:
It varios.
3 MR. S!ESS:
Thoso are more liko source terms 4
than they are DBAs to me.
5 MR. PEARSON:
Yos.
The cask storago scenario 6
assumos somebody takes the lid off.
The other -- the pool 7
storage assumes some kind of o mechanism for -- in tho, I 8
beliovo in Morris, John, wasn't that a tornado missile that 9
ripped out about 19 rows of --
10 MR. ROBERTS:
Yes.
The Morris did assumo a 11 tornado missilo just plowed down essentially the longth of 12 the pool and ruptured the fuel.
Also the dry cask assumos ii 13 the lid's off and somehpw or other you rupture 100 porcont 14 of the rods and you just have, as you said, a sourco term 15 releano.
16 MR. SIESS:
Evorything out of ono cask.
17 MR. ROBERTS:
Wo are talking thu krypton and la todino roloaso.
You aro just assuming you fracturo all the 19 rods and it in just ro.iasod.
That is extromely 20,
conservativo.
But that w1s -- tho figure is not that high.
I 21 I MR. PEARSON:
The most you como up with in 22 3/10ths of a millirom or something like that, or 150 motors.
l 23 1 have forgotton.
It is difficult to gnt up to any kind of 24 a significant off-sito -- it is almost impossiblu.
- ~
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25 MR. CLARK:
This in Tom Clark again.
I will ACE. FEDERAL REPORTERS, INC.
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26137.0 79 EE i
i show what we had planned to show --
i 2
MR. CLARK:
What happens if it rains --
3 MR. SIESS:
You get water in the --
4 MR. PEARSON:
I believe as far as criticality in 5
the cask is concerned, I would think --
l 6
MR. ROBERTS:
As I explained before, the casks 7
are designed for being loaded into reactor pools.
So it is i
8 below the.95.
9 MR. SIESS:
There is no way of getting i
10 criticality in the cask?
11 MR. ROBERTS:
That is correct.
12 MR. MOELLER:
Now, I guess I was going to ask 1
l 13 where you got, or you are quoting NUREG 1140 for this 10 14 percent of krypton and one percent of iodine.
Here then 15 you are going to show us, you have used higher numbers.
16 MR. CLARK:
We used the reactor reg guide for 17 spent fuel storage accident.
I guess we felt that was 18 conservative because that fuel would be a lot hotter than 19 the MRS fuel.
Therefore, it would be a reasonably 20 conservative thing to do.
That is where they une that 30 21 percent krypton-85 and 10 percent iodine.
22 MR. MOELLER:
That is 30 percent of the krypton 23 in all of the canisters or rods that are open.
24 MR. CLARK:
We take 3 PWRs or 7 BWRs that are in
()
25 one canister.
All the rods break releasing theso fractions.
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1 MR. MOELLER:
30 percent of the entire inventory 2
in that canister.
i i
3 MR. CLARK:
Following the reactor reg guide.
4 MR. SIESS:
Is that a credible accident?
l 5
MR. CLARK:
It is credible for the drop.
I 6
don't know if all the rod would break.
j 7
MR. SIESS:
For it to be opened and dropped and 8
outside.
1 9
MR. CLARK:
This is inside.
10 MR. SIESS:
Do you have filtration?
11 MR. CLARK:
Yes.
1 12 MR. SIESS:
This then is after filtration'of 3 13 man-rem.
I 14 MR. CLARK:
We didn' t use filtration for th,e 15 krypton nor the tritium.
I don't think we did for the 16 iodine either.
I think that just was released that way.
17 MR. SIESS:
It might as well have been outside.
2 18 MR. CLARK:
Yes.
l j
19 MR. MOELLER:
Yes.
You are saying the reg guide 20 then is the basis for this?
l 21 MR. CLARK:
The reactor reg guide for spent fuel l
l 22 storage accident.
l 23 MR. MOELLER:
- I guess that, Chet, has been l
24 thoroughly discussed in prior years?
()
25 MR. SIESS:
Not to my recollection.
But I l
4 ACE. FEDERAL REPORTERS, INC.
26137,.0 81 ll l
1 assume.
I know in spent fuel you always just assume tha t 2
there are so many rods were opened and all the activity 3
came out.
l 4
MR. CLARK:
The iodine-129, in a way I am 5
embarrassed to show that.
1 6
MR. MOELLER:
The activity --
t l
7 MR. CLARK:
If this was increased by a factor of l
8 10 and this by 3, Sun would be 3 times 30, about almost 100 9
millirem, even if we released.
We didn't feel like we i
10 would go beyond what the roactors did for a real more 11 severe case.
12 MR. MOELLER:
What percent of the tritium in the 13 fuel is considowed to be volatile?
l 14 MR. CLARK:
Well, that is a good question.
We 15 have been wondering how much hot rods would clad.
I have 16 seen estimates of 40 percent.
He are talking about this 17 fuel would be a few hundred degrees C.
It is not real hot.
18 So probably 10 percent is probably a reasonable estimate.
19 10 percent is a little squishy compared to the other two 20 values compared to the reg guide.
21 MR. SIESS:
Let's skip ahead to another question 22 raised about sab: Lage.
23 I have got a cask out on the storage slab.
I 24 ruptured it in some way, you know, with a shape charge for
()
25 a rocket.
This is all it can produce?
l l
l l
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1 MR. CLARK:
I am not prepared to speak to that.
2 We have someone here who might be.
That is Carl Sawyer.
3 MR. SIESS:
How much worse can you get?
4 MR. ROUSE:
I will speak up.
That situation, 5
clearly you have a driving force.
You may drive out 6
particulate material where we haven't postulated that here.
7 MR. SIESS:
Not very far though.
8 MR. ROUSE:
Well, anyway, I think Carl is i
9 prepared to tell you a little bit about what has been done 10 with respect to transportation casks.
There have been some l
11 studies of the --
12 MR. SIESS:
I am roughly familiar with those, 13 yes.
Starting off with a tremendous amount and then got l
14 down to what you could practically expect to do.
15 MR. ROUSE:
Yes.
t 16 MR. SIESS:
They didn' t have four feet of i
17 concrete around them either, did they?
l 18 MR. CLARK:
Do you want to go to Carl now?
19 MR. SIESS:
Let's hold it.
We will wait on it.
20 MR. CLARK:
Okay.
Well, I think I am about done l
l l
21 from what I was going to say.
The worst meteorology or 5 22 percent meteorology is applied.
We had to make a few 23 guesses for the MRS cycle contractor about where the 24 closest point would be where a person could come.
I think
()
25 we were quite conservative.
We said 400 meters, which I I
i l
i i
l
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26137.0 83 EE 1
personally don't believ.o.
But if you look at the big fence, i
2 actually people would already be in violation to get that 3
closo.
It was pretty close.
4 The only other aspect I was going to talk about 5
had to do with our normal approach for somothing like a 6
reprocessing plant is to look at different types.
I always 7
use the word " upper lioit."
I don't try to claim that I 8
know this is the most severo thing that could ever happen.
9 In this caso, I have never soon any need to go to anything 10 else other than a spent fuel accident that was described 11 hero.
I think anything else would be just trying to 12 conjuro something up.
I don't know what it would be.
13 l Perhaps'a drop of a wastocan or something like that.
But l
14 it would never be as sovoro as this.
15 MR. SIESS:
You said that the three bundles is 16 what you have in a hot cell at one time.
You have 17 postulated the rupture of all throo --
18 MR. CLARK:
Wo just put the three assemblies, 19 pushed those rods through into the canistor and we woro 20 going to move it over to seal it up but'on the way wo drop 21 it.
A* tor that wo soo that all the canisters are going to 22 be sealed up.
In fact, we will do analysia on those 23 canisters to find out what happens to them when they are 24 dropped.
The casks will be analyzed for that.
We will 25 make sure that none of those things can bo opened up in a ACE. FEDERAL REPORTERS, INC.
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drop.
2 MR. SIESS:
How much activity is there in the 3
hot cell, assuming the rods don't bust?
4 MR. CLARK:
That is a toughy, too.
I think that 5
would be filtered.
They have got five stages --
6 MR. SIESS:
If the filters worked.
It would be 7
contained if.the valves stayed -- I am postulating what 8
kind of -- what do you have to postulate to get. stuff 9
released out of the hot cell?
10 MR. CLARK:
You have to rupture five filters in 11 a series to open those up.
What we did -- let me tell you 12 what we did on West Valley.
O
\\_/
13 NR. SIESS:
No way to bypass them?
14 MR. CLARK:
Well, it is possible.
We had three 15 dirty hot cells there and we looked at a tornado effect.
16 We have this code that we can use that can look at 17 ventilation systems and cells and parallel series, et 18 cetera.
And we brought -- we used tornado winds and winds 19 after an earthquake when an earthquake destroys everything 20 available except for the structure itself.
And passed 21 these winds by and started pulling out whatever is in the 22 cell.
We had Oak Ridge develop a source term from one of 23 the cells which was the cell where they -- cut where they 24 cut the rods.
So we had a lot of particulate.
We took At _j 25 samples and got a feel for how much particulate was ACE. FEDERAL REPORTERS, INC.
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1 available.
We developed a model and then made an estimate 2
for how much we would get out.
What it showed us was that 3
some, in the conservative sense, could get out and we had 4
them seal up supports.
5 So we have the capability to do that sort of 6
analysis.
?s We have to make some estimate.
Most of the 7
estimates say that small fractions of a dirty cell, in a 8
range of 10 to the minus 4, would actually be levitated.
9 Unless you had a lot of loose activity.
So we would be 10 concentrating on that device for pulling rods.
That is 11 where the cutting is.
That is where you have the crud.
So 12 we have to concentrate on that area as being a real source
/
)
1/
13 term.
We haven't done that yet but that would be another 14 possibility.
15 MR. SIESS:
Is that defined as a design basis 16 l accident?
17 MR. CLARK:
I wouldn't do that because I have to 18 fail those filters somehow.
We are going to make sure that 19 the design of those filters stay in place.
20 i MR. SIESS:
So this is beyond the design --
l 21 i MR. CLARK:
It would have to be done.
And that i
22 can be analyzed.
The same techniques that I have talked 23 ataut could be used to analyze that accident.
24 MR. SIESS:
So basically, then, your design
,,(j 25 basis accident is all the activity, those percentage of ACE-FEDERAL REPORTERS, INC.
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1 activity from three rods, rods from three bundles released 2
without any filtration and the site distance and 3
meteorology?
It is a source term that has been more or 4
less mechanistically arrived at?
5 MR. CLARK:
Yes.
6 MR. SIESS:
And it is at least equivalent to 7
what we are doing for spent fuel.
8 MR. CLARK:
Okay.
9 I guess we are back to Keith.
10 MR. STEYER:
The next item is, relates to your --
11 the sabotage, physical protection against sabotage.
12 Subpart H addresses that.
Primarily the requirement is
)
13 that a plan must be submitted that demonstrates how 14 applicable requirements of Part 73 would be carried out.
15 Those are in 73.50 that would relate to the MRS or ISFSIs.
16 MR. SIESS:
Those are essentially the same kind 17 of requirements that are in Part 50 for reactors?
18 MR. SAWYER:
They apply more nearly to 19 facilities like Morris.
They are are found in 73.50 as 20 opposed to Part 50.
21 MR. SIESS:
Now, I am not sure about Part 73.
22 That deals a lot with access control, is that --
23 MR. SAWYER:
Among cther things, yes.
That is 24 one component of it.
im L.s; 25 MR. SIESS:
And then 73 deals with fences and l
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1 guard forces and external threats and so forth?
2 MR. SAWYER:
Yes.
3 MR. SIESS:
Not with truck bombs and not with 4
rockets and --
5 MR. SAWYER:
There may come a day when it will 6
deal with truck bombs.
Probably we could address rockets 7
right now.
8 Truck bombs are a Commission-wide problem at the 9
moment applying to the reactors and have been handled as a 10 separate generic issue.
We in division of safeguards are 11 about to come forward with a Commission paper on the 12 various recommendations to the Commission on the subject of
(
13 l vehicle bombs.
14 MR. SIESS:
I think the rocket is an interesting 15 one because these things are sitting out there, they make a 16 very attractive target.
17 MR. ROUSE:
Carl, would you describe the studies 18 that relate to transportation?
19 MR. SAWYER:
Certainly.
I think the rebuttal to 20 that particular concern would be that in the case of truck 21 casks, we assumed the largest shaped charge currently 22 available in the military arsenals was used against the 23 cask.
24 MR. SIESS:
Right on it?
()
25 MR. SAWYER:
Well, on the other hand -- this ACE-FEDERAL REPORTERS, INC.
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1 object, incidentally, weighs 40 pounds.
On the other hand, 2
the warhead, for a rocket to be credible, would probably at 3
the most be only a few pounds.
Say an anti-tank weapon.
4 We think that the damage is going to be correspondingly 5
small.
6 MR. SIESS:
Ot. the truck cask study, that truck 7
cask would have what?
One PWR element in it?
8 MR. SAWYER:
In the truck cask studies that we 9
carried cut, we used three single casks.
10 MR. SIESS:
Which would be the same amount you 11 have in a cask here?
12 MR. SAWYER:
In an MRS cask?
No.
There would
(.s 13 be far, far'--
14 MR. SIESS:
I am sorry.
There is 36, is it?
15 MR. C LARK :
Three per canister and 12 canisters.
16 MR. SIESS:
That is right.
17 MR. ETHERINGTON:
Is helicopter considered a 18 serious threat?
A bomb from a helicopter?
19 MR. SAWYER:
I have not heard that particular 20 scenario discussed.
I don't think that we -- we are 21 attempting to --
22 MR. SIESS:
A bomb from a helicopter, if it 23 I didn't make a direct hit, probably couldn't do anything.
A 24 direct hit could only hit one.
()
25 MR. NULSEN:
It could only hit one but the ACE-FEDERAL REPORTERS, INC.
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1 shaped charge is the greatest threat to a cask breach 2
rupture and the study went through every concoivable 3
explosive, including charges and all kinds of opposition D, 4
and the shape charge of course is directional and I don't 5
think,'unless you --
6 MR. SIESS:
What did you get out of the truck 7
cask study?
8 MR. SAWYER:
We had the optimum standoff 9
distance for the particular weapon that was used.
It is 10 10 to 20 inches.
11 MR. SIESS:
I meant your people.
?
12 MR. SAWYER:
The people we allowed to just take L>
13 up their normal positions in a heavily populated area.
14 MR. SIESS:
What kind of dose is that?
15 MR. SAWYER:
I do not know the specific dose.
16 We can express the consequences in terms of the material 17 that was released and we can express the results as to the 18 number of early fatalities and late fatalities that 19 computer codes claim would result.
l 20 MR. SIESS:
So it is not negligible?
21 MR. SAWYER:
Specifically in numbers -- there f
22 were two studies.
One study came forward with a number of 23 18 rems of material released.
The second study came up 24 with a number of 32 rems of material released.
This was (O
25 shooting, unimpaired, through the shape charge, through a
,j ACE-FEDERAL REPORTERS, INC.
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w.,
1 truck cask, we see in our view the three assembly truck 2
cask as a -- here we are talking about 32 inches of 3
reinforced concrete, plus an intercontainment of at least 4
two inches of steel.
5 A second favorable point from our point of view 6
is that the public could be exposed at a much, much further 7
distance and we would expect a correspondingly smaller 8
amount of consequences from that.
9 On the other hand, once one did penetrate a cask, 10 while there is much more concentrated material in the path 11 of the shape charge jet, if it did get through these 12 various barriers.
13 l MR. ETHERINGTON:
Would the shape charge have to 14 be placed or --
15 MR. SAWYER:
It would be placed.
16 MR. NULSEN:
To do the maximum damage.
It would 17 have to be placed at a precise distance.
In other words, 18 it is about a two-man placement plus a little bit of time 19 to place it accurately.
Otherwise, you wouldn't --
20 MR. SAWYER:
To complete our story here.
We 21 have extrapolated as best we could to apply our truck cask 22 results to dry cask storage situations.
We recognize that 23 there are weaknesses in this extrapolation.
And so we last 24 September contracted with Sandia Laboratories to do a (w
(_j 25 thorough investigation of this extrapolation, and to verify ACE-FEDERAL REPORTERS, INC.
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1 whether the truck cask results could be successfully and 2
defensively applied to the dry cask storage situation, 3
including MRS casks.
4 MR. SIESS:
Good.
5 Let me go back to something a minute.
I was 6
confused.
You call the concrete container the cask.
Inside 7
of that, you call that the canister?
8 MR. ROUSE:
Yes.
9 MR. SIESS:
And the canister has in it 36 10 bundles of fuel rods.
Had rods from 36 bundles?
11 MR. ROUSE:
Right.
12 MR. SIESS:
PWR bundles?
l
(~h s_/
13 MR. ROUSE:
Each canister -- we are talking PWRs, 14 let's stay with that.
Each canister has the rods from 15 three assemblies and then there are 12 canisters placed in 16 the cask.
17 MR. SIESS:
Is the cask lined with steel?
18 MR. ROUSE:
Yes.
It has a two-inch liner.
You 19 really have a cask within a cask.
20 MR. SIESS:
Now I am clear.
The cask is lined 21 with steel and then there are 12 canisters placed in there.
22 MR. ROUSE:
That is correct.
1 23 MR. SIESS:
The source term you were talking 24 about was a --
()
25 MR. ROUSE:
A canister in the hot cell area ACE-FEDERAL REPORTERS, INC.
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26137.0 92 REE 1
being dropped.
That is true.
2 MR. SIESS:
What is physically the canister?
3 Roughly size and --
4 MR. ROUSE:
It is about a 12-inch diameter.
5 MR. CLARK:
Schedule 40 pipe, stainless steel.
6 MR. SIESS:
What is the thickness on Schedule 40?
7 MR. C LARK :
Something like 3/8ths of an inch.
8 MR. SIESS:
Is the space between them filled 9 l with anything?
It is just a space.
That is where you i
10 detect for leakage.
Okay.
11 So your accident, where you have a canister, all 12 the release from the canister doesn't bound a complete (3
s/
13 release from a cask?
That would be pretty hard to do, 14 wouldn't it?
15 MR. ROUSE:
Except for the sabotage scenario.
16 MR. SIESS:
Now, the scenario where you took the 17 lid off the cask and then ruptured the -- you ruptured a 18 canister then, is that it?
19 MR. ROUSE:
Yes.
Let me back off.
The scenario l
20 that John Roberts described for taking that lid off the 21 cask was the type of cask that VEPCO may be using or plans 22 to use.
There you do not have the fuel assemblies in a 23 canister.
In other words, they are placed right in a 24 matrix or a basket and you have the fuel assemblies exposed I'_/')
25 if you take the lid off.
So the scenario was a little bit --
x i
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MR. ROBERTS:
There would be 21 assemblies, not 2
three.
3 MR. SIESS:
That is in the VEPCO --
4 MR. ROBERTS:
Yes, the rods would b'e 21 5
assemblies, assuming that they were all ruptured.
6 MR. SIESd:
As sort of a worst conceivable 7
release -- I will use worst qualified -- would be perhaps 8
this shape charge on a single cask.
External sabotage.
9 MR. SAWYER:
Yes.
10 MR. SIESS:
To do that, a guy has got to get 11 inside the fence and it would be not too difficult, would 12 it?
gy LJ 13 MR. SAWYER:
I don' t think that we should ever 14 be put in a position of guaranteeing against it.
We 15 protect against it.
16 MR. SIESS:
You will have intrusion alarms and 17 all that stuff just like a power plant?
18 MR. SAWYER:
That is correct.
In general, our 19 system would consist of barriers where you control access; 20 a surveillance system, supplemented by intrusion alarms; a
21 response to any indication of intrusion by a nearby force 22 of armed guards.
There would be advanced coordination with 23 release; a communications capability among the guards 24 themselves and a radio communications to all of our
()
25 assistants, the police and other reinforcements if needed; ACE-FEDERAL REPORTERS, INC.
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26137.0 94 REE V
1 finally the usual test to assure for quality assurance.
2 MR. SIESS:
Now, because of the release of 3
solids from a shaped charge, do you think that would more 4
than bound release of all the gases from the cask?
5 MR. ROUSE:
There is different transport 6
involved.
A driving mechanism and --
7 MR. SIESS:
You have an awful small number of 8
millirems from one canister.
9 MR. ROUSE:
You are dealing with a dose 10 conversion factor.
If you get out in the open, a driving 11 force for particulates, the cesiums and the strontiums and 12 the other fission products, you have more of a problem.
ex s.)
13 MB. SAWYER:
Incidentally, if I may, that is 14 exactly the conclusion that the sabotage studies wound up 15
. with.
Naturally there is the opportunity for release of 16 some gases.
But in general, the health consequences from 17 release of the gases such as krypton is negligible.
And 18 the situation we found was dominated by strontium-90, 19 cesium-137 and the six or so man-made elements.
20 MR. SIESS:
I think what we would be interested 21 in when you get it would be the results of this 22 extrapolation of transfer from shipping casks to this.
23 MR. SAWYER:
Of course, it is of interest to us, 24 too, because it will very likely serve as the primary
()
25 guidance for our decision as to what we think, that our ACE-FEDERAL REPORTERS, INC.
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current requirements are about correct or whether they 2
ought to be strengthened or perhaps adjusted in some way.
3 MR. SIESS:
Yes.
4 When do you expect to have that finished?
5 MR. SAWYER:
The program began in September of 6
1985.
It will continue through 1988.
However, my personal 7
expectation is about the middle of 1987 that these studies 8
will be giving pretty good indications of the problems that 9
will happen.
Although the information will not be put in 10 typed form.
11 MR. SIESS:
Very good.
Thank you.
12 MR. STEYER:
The next two viewgraphs relate 13 primarily to siting factors and specifically external 14 phenomena.
As they are shown here, basically none of the 15 technical requirements on these we would change because we 16 are adding in our MRSs, but the language would be added to 17 say that they also apply to MRSs.
There are siting 18 limitations that come out of the Act, namely where it 19 relates to what state the disposal is versus where these 20 things would be and how many miles apart they have to be 21 and certain limitations:
how much fuel, how many tons of 22 material can be in there if they are within a certain 23 distance.
24 Ue have concluded that the seismic, the
()
25 site-specific -- specific seismic criteria that would be ACE-FEDERAL REPORTERS, INC.
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26137.0 96 REE u-1 for an ISFSI would also be adequate for an MRS because we 2
were trying to simplify that and not go beyond what a 3
reactor was doing and make it easier to apply.
4 MR. SIESS:
The original idea on the seismic was 5
to put a value up at.25 or.3 of something.
Okay, fellows, 6
you don't have to do any site -- looking at the site and so 7
forth.
8 MR. STEYER:
Yes.
9 MR. SIESS:
That didn't fly.
But you still have 10 something in there that you --
11 MR. STEYER:
Do you remember the exact --
12 MR. SIESS:
What section is it?
k/
13 MR. PEARSON:
91.
14 MR. BERATAN:
72.66.
15 MR. SIESS:
I haven't got 72.66.
16 MR. STEYER:
72.81.
It is now 72.81.
It is on 17 page 74.
18 MR. SIESS:
This is for Rocky' Mountain front.
19 If it is not unstable you could use.2 G.
That is 20 essentially central stable without any further 21 investigation except to show that it is stable.
That 22 doesn' t really take care of that thing at Charleston, does 23 it?
i 24 MR. BERATAN:
Well, Charleston would require a
( )
25 special -- the unanchored Charleston, that came after this.
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MR. SIESS:
Yes.
You thought about changinc 2
this because what seems to be done now or what they are 3
thinking about up and down the East Coast is the 4
probabilistic approach to Charleston moving around, I guess.
5 MR. BERATAN:
Yes.
6 MR. SIESS:
And that 7
MR. CLARK:
I don' t know about theoretically but 8
practically I am not sure there is a good reason to do that.
9 For MRS, the Clinch River site, that region has been looked 10 at by Bob Rothman of the NRR staff.
He looked at Watts Bar 11 and ne had looked at Clinch River and he said he doesn' t 12 see any reason to change regardless of the Charleston 13 earthquake.
So I think for that site it is going to say.25 14 G.
15 I MR. SIESS:
Is Clinch River in a region that you 16 couldn't possibly have --
17 l MR. BROCHUM:
Clinch River is not in the region 18 that USGS defined as being the eastern seaboard.
19 l MR. SIESS:
Suppose somebody picks a site that i
20 i is in that region?
l l
21 !
MR. BERATAN:
Then you would have to investigate 22 for soil stability.
23 MR. SIESS:
It doesn't say here that you can't 24 use.2 G.
I mean, if I picked a site out near Robinson, I
[,
25 think Robinson is in the same -- is in the region.
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1 MR. BERATAN:
It says here in the regulations, 2
sites other than bedrock sites shall be evaluated for tne 3
liquefaction potential or other --
4 MR. SIESS:
That is only for soil stability.
It 5
still says you can use potential for migratory ground 6
motion can be taken as 2/10ths G.
7 MR. BERATAN:
But liquefaction is what you are 8
concerned about?
9 MR. SIESS:
No, I am concerned about shaking.
10 If there is enough of it.
11 MR. BROCHUM:
In a purely deterministic sense, 12 if you brought the Charleston earthquake next to the site
)
13 under consideration on the eastern seaboard, It probably 14 would exceed this design.
In the probabilistic sense 15 though, the chances of that happening, take an area the 16 size of the eastern seaboard, the chances of that happening 17 is remote.
And I think the seismic hazard study that is 18 being undertaken right now for reactors, the preliminary 19 results do suggest that.
In other words, from a 20 probabilistic point of view, the Charleston earthquake is 21 not a major problem for designs such as suggested in this 22 regulation.
l 23 MR. SIESS:
I agree.
And yet if this were being 24 written now rather than when it was written and those (G) 25 studies not having been completed or made a part of the ACE. FEDERAL REPORTERS, INC.
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1 regulaticas, this would not be consistent with what 2
somebody would want to do for a new reactor plant on the 3
eastern sea coast.
I don' t think it would ever get by the 4
ACRS without a very strong letter, that 2/10ths G.
5 MR. BROCHUM:
I am not sure where the 2/10ths 6
comes from.
If you look at the further paragraph, number 6 7
and then Roman number 2 talks about
.25.
My recollection, 8
when we wrote this regulation -- I am the person that wrote 9
this part of the regulation back in 1980 was it was
.25.
I 10 think that is a misprint or something.
11 MR. SIESS:
The point 2 says for those sites not 12 evaluated under the criteria of Appendix A.
(]
Ns 13 i MR. DROCHUM:
That is correct.
Those sites that 14 are not ineitherseifaicareasorinthewesternU.S.
The 15 number we always used was
.25.
16 MR. SIESS:
That is what I thought but I still 17 see a.2 here.
18 MR. BROCHUM:
I think the.2 is in error but I 19 don't know where that came from.
My recollection was.25.
20 MR. ETHERIEGTON:
What about the consequences if 21 you don't have any valves that have to operate or piping 22 that will break or instrumentation that is going to foul 23 things up.
What are the consequences of that?
24 MR. BROCHUM:
Well, at the time this regulation
()
25 was written, we were primarily thinking of pool-type ACE-FEDERAL REPORTERS, INC.
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2 MR. CLARK:
For the MRS, you keep those filters 3
in place and the structure is going to stand, you are still 4
okay.
5 MR. SIESS:
If those filters aren' t designed for 6
that earthquake, they may or may not be in place.
7 MR. CLARK:
I am going to try to make sure that 8
they are.
9 MR. SIESS:
But I think you have a requirement 10 in here which makes sens, if I kept Charleston where it was 11 and it was going to be questioned right now.
12 Now, two, three years f rom now we might come 13 back with something more reasonable.
I think you get my 14 point, don't you?
This is going to be an issue, I will 15 guarantee you, when ACRS looks at it.
You need to be 16 prepared to address it.
17 MR. BROCHUM:
The only logical way to handle a 18 Charleston-type earthquake with such large uncertainties is 19 through a probabilistic approach.
That was the intent even 20 when this regulation was written:
a probabilistic approach.
21 In fact it referred originally to probabilistic maps issued 22 by the National Bureau of Standards.
23 MR. SIESS:
What you have here is not consistent j
24 with what would be done, I think, for a reactor siting.
(( )
25 MR. BERATAN:
In the near future, it may not l
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even be consistent with Appendix C.
2 MR. BROCHUM:
It would not be consistent with 3
reactor siting if you took the literal interpretation of 4
Appendix A.
If you look at what we call the intent of 5
Appendix A, we would invoke probabilistic criteria because 6
it is just~not logical.
7 MR. SIESS:
I am not sure there is agreement on 8
the literal interpretation but I guarantee you there is not 9
agreement on the intent.
I was one that was involved in 10 Appendix A from the be~ ginning.
I am not sure we knew then 11 what we intended.
12 MR. BROCHUM:
We are suggesting that it be
(~h
~
kl 13 revised now.
14 MR. SIESS:
I don' t think we have got a serious 15 problem because I think the consequences would tend to be 16 negligible.
But it is a question I hope you will think 17 about and be prepared to defend before the ACRS.
/
18 Actually, you don't need to have it in here.
l 19 There is no reason in the world why you can't simply site 20 this thing for seismic on the same basis you do Appendix A.
21 There is not going to be that many of them built.
22 Certainly for MRS.
23 MR. ROUSE:
Could I add a point here.
I agree j
24 with what you are saying.
I would add one point.
- MRS,
(~s
()
25 let's set MRS aside here for this.
We only know one and --
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1 right now it is proposed at one site.
Certainly it can be 2
moved by Congress or DOE.
3 Let me tell you, though, how we are approaching 4
dry storage like the VEPCO and the Robinson, et cetera.
5 For these other dry storage casks, for these dry metal 6
storage casks, what we are doing to the vendors are asking 7
the vendors to demonstrate that that cask will take a tipover 8
and drop and maintain its integrity and confinement.
They 9
are doing that.
10 Now, I don' t care whether it gets tipped over by 11 an earthquake or some other means.
As long as I have my 12 integrity of the cask, I am okay.
So from that sense we C) k-13 don't have a problem there.
14 MR. SIESS:
If the cask is your only problem.
15 Then that has to be fairly sure.
16 The idea when Bob Benaro brought this thing 17 first in was if we could set a G value high enough that we 18 didn't have to do all the geology and seismology, that 19 would be a benefit.
i 20 MR. BERATAN:
That was the original intent, to 21 eliminate a lot of the field investigation.
22 MR. SIESS:
Which I don't think, geology didn't 23 even got mentioned in there.
24 MR. DERATAN:
I think the intent here was that
(~h
\\
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25 they didn't want to see a full-scale reactor-type siting ACE-FEDERAL REPORTERS, INC.
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investigation done.
2 MR. SIESS:
I think that is a little optimistic 3
because we have do'ne at least two of every reactor in 4
operation.
Maybe we need to revise Appendix A then.
5 MR. STEYER:
The next item would be viewgraph 10, 6
which has to do with other external phenomena besides 7
earthquakes, specifically relating to floods and tornadoes 8
and protection against floods.
What we have to say here we 9
have already said:
Namely, that we have changed the rules 10 so that we do consider tornado missiles and that is the 11 primary change.
12 MR. SIESS:
Let me go back to the seismic a O
\\-
13 minute.
As I recall from the SER you wrote on the MRS, 14 there was a statement in there that DOE did not plan to 15 make the casks seismic category I but they would be 16 analyzed for the SSE.
Can you explain the difference 17 between --
18 MR. CLARK:
I guess I wrote that statement.
I i
19 have since looked at the definition of nafety-related and I 20 would claim that what we --
21 MR. SIESS:
That is not in there anymore.
It is 22 important to safety.
23 MR. CLARK:
But if you look at that definition, 24 these casks would meet that criteria.
That is -- seismic
(~h
(_)
25 category 1.
Seismic category 1 says you will maintain your ACE FEDERAL REPORTERS, INC.
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l confinement essentially for your containment.
We would 2
expect analysis to show that the casks will do that.
That 3
is what we are expecting to see.
The problem is, I guess 4
with what I might call the derivative reg guides and so 5
forth for reactors as to whether the casks would meet all 6
those and we are not intending that.
7 I thought in a way I was a little severe with 8
DOE on that one because I am not looking that they meet all 9
kind of reactor criteria but I want to make sure that they 10 maintain that confinement.
11 MR. SIESS:
It was just confusirg to me.
I 12 didn't know whether there was a certain amount of paper 13 that went along with seismic category 1 that didn' t go along 14 with the other.
I know there is a lot of seismic category 15 1 stuff --
16 MR. ROUSE:
What I said, just to sort of 17 emphasize what Tom said, again, they are going to be moving 18 this large concrete cask in a tractor-type vehicle from the I
19 hot cell facility out to those pads.
They are going to 20 have to look at a drop and tipover.
The seismic in it sel.?
21 doesn't have much meaning here.
22 MR. SIESS:
All they can do is turn it over.
23 MR. C LARK:
Part of that statement was due to 24 the fact that I hadn't seen that analysis yet and I wanted 25 I to be conservative.
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MR. STEYER:
I think we have discussed what we 2
were going to say about floods in the past already.
3 This is more or less all I would have to say 4
unless there are other questions.
5 MR. SIESS:
I was just trying to make a point to 6
you that when the ACRS looks at this, we have a tendency to 7
go beyond design-basis accidents, particularly if we are 8
not too sure of the frequency.
9 MR. STEYER:
When the full committee looks at it, 10 they would want more -- they would want to go through it, 11 more or less, as I guess it is~ written with more detail in 12 certain areas than we have covered.
,\\J 13 MR. SIESS:
One of the jobs of the Subcommittee 14 is to bring this thing to a point where we can tell you to 15 come into the full committee and know what to have you 16 present.
I am not sure we will know after this meeting.
17 We may want another one to sort of run through the whole 18 thing section by section and get a better idea of the scope.
19 MR. STEYER:
All right.
20 MR. SIESS:
For some reason that may not be 21 important.
ACRS has not reviewed the ISFSI applications.
22 If we hao, this wouldn't be all that necessary.
We would 23 have been through it before and we could just then look at 24 the MRS versus West Valley and whatever.
()
25 MR. ROUSE:
I would like to say, at the ACE-FEDERAL REPORTERS, INC.
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26137.0 106
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(/
1 Subcommittee's convenience we would be pleased to come down 2
and describe to you how we are handling the ISFSIs.
3 MR. SIESS:
I don't know why we haven't reviewed 4
it.
We probably, with reduced resources, we may or may not 5
have reviewed the MRS.
But that is required by the law.
6 And the Commission has asked us to.
7 MR. ROUSE:
I have pursued all along in my 8
dealings with DOE that the ACRS would have an interest in 9
reviewing with the Staff the MRS, and have so informed them 10 all along, without even touching base with you people.
l 11 MR. SIESS:
We either didn't have the interest 12 or didn't have the request to review the ISFSIs.
We are 13 sort.of starting at the beginning.
14 MR. ROUSE:
We reviewed the ISFSIs in -- most of i
15 our reviews are concerned with the reports, the actual j
16 licensing reports that looked at the safety of the casks.
17 Most of your on-site reactor storage of course is still 18 handled by NRR.
There is reracking and then the next rod 19 consolidation.
So we haven't -- I myself have not 20 considered coming to the ACRS with ISFSIs.
21 MR. SIESS:
They will license this with a l
22 license amendment.
23 MR. ROUSE:
They will receive a Part 72 license 24 that is closely tied to that reactor license.
o
(_)
25 MR. SIESS:
But it is a separate license?
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1 MR. ROUS E:
It is a separate license.
2 MR. SIESS:
We probably didn't consider it 3
within our scope.
The MRS became part of our scope because 4
the Commission said, we want you to review it.
But my 5
point is that we are not up to speed on Part 72 and what 6
happened today has been extremely helpful in doing that and 7
tying it to MRS.
I think we are going to need another 8
meeting.
I don't know that there is any real big hurry on 9
it.
2 1
10 MR. CLARK:
Could I ask --
11 MR. SIESS:
I will leave it up to the Committee.
12 If the Committee, if you are going to apply Part 72 O
As/
13 criteria to MRS, and the Committee has problems with Part e
14 72, you need to know those fairly early.
15 MR. CLARK:
Could I ask you a question?
I am 16 really asking if you could ask a question for me maybe of 17 the full body or give guidance on this PRA application for 18 natural phenomena that you are suggesting here, because if 19 I go to DOE, I would like to know specifically what it is 20 we think should be done.
I don't think we are talking PRA 21 in general.
We are talking a couple of areas where we 22 think something might be done.
I am going to need some 23 guidance on that.
24 MR. SIESS:
We will do what we can to get it for
()
25 you.
I don't expect to get a heck of a lot.
I don't i
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really think a complete PRA is justified in view of the 2
bottom-lir.e risk that you can get from just looking at it.
3 You can almost postulate the worst possible thing and not 4
get much of anything.
5 I-f you get into something like sabotage, the PRA 6
doesn't do you any good because you have no basis for 7
deciding the frequency of the initiating event.
It is a 8
complicated thing.
9 MR. CLARK:
What I thought I heard was seismic 10 and flooding.
11 MR. SIESS:
Seismic margins has been an issue.
12 It is outside of the regulatory requirements being looked i'
13 at by NRR.
It is a separate type of thing.
Trying to 14 establish generically that there are margins of looking for 15 weak spotc, like relay chatter and things of that sort.
16 The one thing that is going to fail at half of the 17 earthquake and everything else will be damaged.
I am not 18 sure that that particular thing is too applicable here.
19 The floods become two questions.
There is 20 considerable uncertainty and frequency in flood because it 21 is not a probabilistic-based thing and the consequenses are 22 not a gradual-type thing.
The question of just looking at 23 what happens if you exceed the flood might be all you need j
24 to do or ask the applicant to look at what happens.
/
25 As far as the casks, I can't see any problem ACE FEDERAL REPORTERS, INC.
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26137.0 109 EE 1
there.
Somebody mentioned the lag storage criticality 2
there.
Those are things to look at.
So I will try to get 3
something.
It may not be immediate.
4 MR. STEYER:
Are you through now?
5 MR. SIESS:
Yes.
6 MR. MOELLER:
Could I ask --
7 MR. SIESS:
Where are we?
We are through the 8
agenda.
9 MR. MOELLER:
On the general design criteria, I 10 am looking now at the staff evaluation of the DOE proposal 11 to the Congress for the monitored retrievable storage, 12 11.68, on page 3-7, in the middle of the page, you say, if (O
\\-
13 the ISFSI is located over an aquifer which is a major water 14 resource, measures shall be taken to protect it.
Why would 15 you limit.it to one that is a major water resource?
16 Perhaps you have a way of interpreting that differently 17 than I, but I read that as meaning not necessarily that it 18 could be a resource but that someone is actually using it.
19 I would want to protect it whether anyone is using it or 20 not.
21 MR. CLARK:
I guess I should address that.
We 22 had a similar case to this essentially dry facility in the 23 Anderson plant, the Westinghouse facility for plutonium.
24 And it is nard in a dry plant to conceive of a real problem
)
25 with the water.
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that --
2 MR. MOELLER:
Sure.
3 MR. CLARK:
There was impoundment of fire water 4
in that case which still would have kept the water from 5
leaking through the plant.
6 MR. MOELLER:
I agree that it is very --
7 MR. CLARK:
This one it is even more remote.
8 MR. MOELLER:
Why don't you say "which has, if 9
it is located over an aquifer, comma, it ought to be 10 protected."
11 MR. CLARK:
Okay, sure.
I don' t know.
12 MR. STEYER:
I am not sure we can reconstruct,
(_1 13 though, why se put " major" in there.
14 MR. MOELLER:
Rig ht.
Or I would have just said, 15
" protect any aquifer."
16 Let us just go on.
I found, of course, in going 17 through this, that the --
18 MR. SIESS:
You are reading from the --
19 MR. MOELLER:
I am reading from 11.68.
20 MR. SIESS:
That is the SER?
21 MR. MOELLER:
Rig ht.
Again, in the SER you show 22 me that the HVAC system in the building and so forth is 23 very critical and very important.
And yet -- and I believe 24 personally, you know, you ought to put your best people on 7()
25 it and maybe you have, but I recall the Connittee's efforts ACE-FEDERAL REPORTERS, INC.
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on control room habitability and you seem to have a good 2
program underway now but it seemed to take some time.
But 3
I think the sama effort ought to be put here.
4 Let me read on page 3-40 under " operation during 5
a fire."
Again, we are talking about HVAC systems.
It 6
says, "when a fire alarm would sound, the supply air damper 7
to an individual affected area would close, while the 8
exhaust will continue to operate."
Now you are going to 9
have the walls falling in and everything else.
It says to 10 remove the smoke.
But you can't do that.
11 MR. CLARK:
Why not?
12 MR. SIESS:
You can't take it out unless you v/
13 have got some way to get some more in.
14 MR. MOELLER:
You are going to collapse the 15 building.
16 MR. STEYER:
It depends on the delta P involved.
17 MR. C LARK :
We are talking five-foot-thick 18 shield walls here that we are going to collapse.
19 HR. MOELLER:
Well, you won't collapse those.
20 MR. CLARK:
As a matter of fact, this is kind of 21 an interesting question that Keith and I have talked about 22 in the past about what one should do in the event of fire.
23 How much air one should supply and how you cut it off.
We 24 have codes developed for that purpose for accident analysis 25 that can do that.
You can analyze the effect of a firo and ACE-FEDERAL REPORTERS, INC.
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tnis can be analyzed.
2 MR. SIESS:
This is for the hot cells?
3 MR. CLARK:
Yes.
4 MR. MOELLER:
I still, and -- I agree that it 5
does not have a clearcut answer.
But I think the Committee 6
should bring in a top flight HVAC expert to look over this 7
and to offer comments.
8 MR. SIESS:
This isn't the SER for a license.
9 MR. CLARK:
No.
10 MR. SIESS:
Right now your questions ought to be 11 directed to the Staff as questions that they should ask the 12 licensee.
Although that reads beautifully, it is still an l}
\\'
13 SER commenting on a proposed design.
14 MR. ROUSE:
A conceptual design.
15 MR. SIESS:
And any questions now are helpful 16 but --
17 MR. MOELLER:
Okay.
When it actually comes down 18 to an acted design.
19 R.
SIESS:
That may be so far from now.
When 20 do yta expo rt to get an --
21 MR. CLARK:
8/89.
22 MR. MOELLER:
You talk about emergency backup 23 HVAC systems.
You know in terms of control room 24 habitability, we have said, how frequently do you test them,
)
25 what are the testing protocol.
I hope you keep that in I
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mind.
2 MR. CLARK:, Control room habitability is not 3
nearly as necessary as it is for a reactor.
We looked at 4
Morris, the question of ualking away from Morris and 5
leaving out sabotage and things like that, but as far as 6
safety, you could walk at ay from that site and nothing 7
would happen for days and days and days.
.All the cooling 8
systems, everything that could happen, ventilation system 9<
'and everything, you don't get in trouble.
10 Ue haven't really done a full analysis of this 11 plant but I would imagine it is going to be similar.
They 12 have provided two control rooms actually in this plant, one r^x E-13 in that materials and handling building and another in 14 another building.
That is in the present plans.
But as to 15 whether it had to be. habitable, I am still not sure.
16 MR. MOELLER:
Okay.
On page 3-67, this is just 17 a nit.
I only have a few more, if I could go through them.
\\
18 MR. SIESS:
Sure.
19 MR. MOELLER:
In the middle of the page 3-67, 20 you say in determining annual direct radiation dose 21 equivalents, DOE used 10 CFR 20 and so forth.
Are the 22 direct radiation dose equivalents, do you mean the dose 23 limits for external radiation, is that what you mean?
24 MR. STEYER:
It is his document?
"8
( )
3 25 MR. MOELLER:
Right in the middle of the page.
t f
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What are direct radiation dose equivalents?
2 MR. CLARK:
I think what we are talking about is 3
something you might read on a TLD or something like that.
4 MR. MOELLER:
Then it probably means external.
5 MR. ROUSE:
I think it does.
6 MR. MOELLER:
Then your last sentences, "a cost 7
benefit evaluation of potential dose rate reduction has 8
been recommended in the final design phase," what are your 9
rules for doing a cost benefit evaluation?
This is 10 occupational exposuro and what are the criteria?
11 MR. CLARK:
That is going to be a tough one to 12 answer.
What we are saying is you have to look really, 13 essentially ALARA.
There are areas, hands-on operation 14 with some waste treatment systems and handling of filters, 15 all that sort of thing where you want them to apply ALARA.
16 That is what that is getting at.
When you have the final 17 design and you know what your operation is going to be, do 18 some sort of an ALARA treatment.
19 MR. MOELLER:
I was saying to myself, if I were 20 to do it, I didn't know how.
21 Now, on page 3-70, there was, again, an 22 interesting thing.
The middle of the page, in the 23 paragraph that begins in the middle of the page, it talks 24 about, the last sentence, the radioactive airborne monitors 25 would be operated continuously to sample the air where the ACE FEDERAL REPORTERS, INC.
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airborne radionuclide concentration might exceed MPCs.
2 It is an interesting thing that we would just 3
monitor where they might exceed the MPCs because on the 4
very -- on page 372, you say, under item 6, you should 5
monitor where there would be a potential for exposure rates 6
above a preset threshold.
That is what you want?
7 MR. CLARK:
That is exactly right.
8 MR. MOELLER:
Then shifting to the --
9 MR. SIESS:
Don't measure it unless it is large, 10 right?
11 MR. MOELLER:
In the 10 CFR 72 itself, I found a 12 very interesting, to me, item on page 61.
That is
- ~
13 enclosure A where you are talking about backfitting, 14 paragraph 72.42.
You say, page 61, paragraph 72.42, you 15 say the Commission may require the backfitting of an ISFSI 16 or MRS if it finds that such action will provide 17 substantial additional protection to the environment or 18 substantial additional protection to occupational or public 19 health and safety.
So you are telling me that you, as the 20 NRC, can require backfitting if too many people are falling 21 off the scaffolds, you know.
I don' t know whether there 22 are any even near, but I am looking at nuclear power plants.
23 I read LERs and we are not killing anyone with radiation in 24 the plants but we are sure killing them with falls and nI,,
25 accidents.
So in -- and this is the first time. have ever ACE-FEDERAL REPORTERS, INC.
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7.+.._.--.
26137.0 116 1
read it.
The NRC can force or can require backfitting to 2
protect occupational health and safety.
And then it goes 3
on -- so I said, what are the cost benefit analyses that I 4
am going to use.
And if this applied to nuclear power 5
plants, I would be off and running because I could really 6
go out and prevent some deaths.
7 MR. STEYER:
In the non-nuclear --
8 MR. MOELLER:
Yes.
And did you mean this to be 9
non-nuclear?
10 MR. STEYER:
I don' t think we were talking about 11 falling off the scaffolds.
We were talking about radiation 12 related.
, - ~
?
13 ;
MR. MOELLER:
I think so.
fiell, then, I --
14 MR. STEYER:
We need.to fix that there.
I 15 MR. MOELLER:
I think maybe you need a fix there.
16 Another one, on page 75, I think it is -- I just 17 found it a curiosity -- at the top of page 75, it is 18 paragraph 72.83, you quote in part A the 25 millirem and 19 the 75 to the thyroid and then at the top of page 75 you 20 say, you know, they shall not have more than 25 millirem 21 whole body, 75 thyroid, as a result of exposure to, one, 22 plan discharges of radioactive material, radon and its 23 daughters excepted.
I know what you mean, you are pointing 24 out that it doesn't apply to natural background.
But if 25 that radon were coming from an uranium mill tailing, you ACE. FEDERAL REPORTERS, INC.
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26137.0 117 REE
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1 would sure zap me.
So I think --
2 MR. ROUSE:
No.
3 MR. MOELLER:
Somebody would.
4 MR. ROUSE:
40 CFR 190 excludes radon.
5 MR. MOELLER:
Correct.
But you want to be 6
careful.
I am nitpicking, but -- well, it ought to be 7
carefully stated that radon, of course it should say its 8
decay products, not its daughters.
9 MR. SIESS:
Why?
10 MR. MOELLER:
Because it is the decay products.
11 MR. SIESS:
What is a daughter?
l 12 MR. MOELLER:
In a chauvinistic world --
p>
i 13 MR. SIESS:
You don't want to be sexist.
~
14 MR. MOELLER:
You should say decay products.
l 15 And then it ought to say, " arising from the natural l
16 background."
And in fact, you have to be careful because 17 why you regulate the uranium mill tailings is that is the 18 technologically-altered natural environment or 19 technologically-enhanced natural background.
20 The last one, on page 100, I just needed some 21 education because there, under paragraph 72.301, you are
(
22 training and certifying that personnel who are going to 23 operate the MRS -- well, the applicant trains them, I l
24 presume.
Who certifies them?
What is the certification
()
25 program?
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1 MR. CLARK:
It would be, they would do the 2
certification.
3 MR. MOELLER:
They will, DOE will grant them a 4
certificate?
5 MR. CLARK:
Yes, and we would inspect that 6
program.
i 7
MR. SIESS:
No license.
l 8
MR. MOELLER:
They are not licensed.
And are l
I 9
there other comparable people that are certified today?
I l
10 MR. CLARK:
Morris is doing that today.
11 MR. MOELLER:
Is there any other -- you don't 12
(~h certify -- does anybody certify electricians or any --
1 13 MR. CLARK:
No.
l 14 MR. MOELLER:
This is the only place that people l
15 are certified.
Okay.
Then that is good because that is i
16 the first time it had rung a bell with me.
I just wanted 1
17 to learn.
t l
18 MR. CLARK:
Just as an aside, we had planned to
(
19 do something like that for plutonium plant operators.
i 20 MR. MOELLER:
Well, that is very helpful.
I
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21 think those were my main things.
22 MR. SIESS:
Okay.
Harold, do you have any --
23 MR. ETHERINGTON:
I have nothing, no.
l l
24 MR. SIESS:
Gentlemen, I think that takes us to
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25 the end.
I will let you know what the next stop is.
I am I
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ACE FEDERAL REPORTERS, INC.
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26137.0 119 REE
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going to report to the full committee in a very brief 2
report and try to find out what they like to do and as I 3
said, I think we will have to have another meeting.
4 MR. STEYER:
Of this one here?
5 MR. SIESS:
Yes.
Again, I have got to get their j
6 feeling about Part 72 versus MRS and whether they want to 7
look at it and how much they want to look at it.
We will 8
let you know as soon as we know anything.
Thank you very 9
much.
You have been very helpful.
Good presentations.
10 (Whereupon, at 4:55 p.m.,
the meeting was 11 adjourned.)
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1-l STATUS OF PROPOSAL 4
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flATURE OF MRS i
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CERTIFICATE OF OFFICIAL REPORTER
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This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of:
l NAME OF PROCEEDING:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCOMMITTEE ON SPENT FUEL STORAGE FACILITY DESIGN I
I DOCKET NO.:
PLACE:
WASHINGTON, D.
C.
~
e DATE:
WEDNESDAY,' MARCH 12, 1986 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear l
Regulatory Commission.
1 1
(sigt)
W C9 s
I (TYPED) l REBECCA E. EYSTER Official Reporter ACE-FEDERAL REPORTERS Reporter's Affiliation, INC.
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l STATUS i
l NRC COMMENTS TO DOE FEBRUARY 5 TENNESSEE OBJECTIONS i
GOVERNOR'S VET 0 t
U.S. CIRCUIT COURT SUIT INJUNCTION APPEAL NUREG S00M TO BE ISSUED l
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NWPA - CONSULTATION 1
i FREQUENT CONTACTS i
4 NOT A COMPLETE SAFETY EVALUATION USED PART 72 AS BASIS i
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SCHEDULE CONGRESS MUST APPPOVE 1989 APPLICATION THIRTY MONTH REVIEW 1996 START UP REPOSITOPY 1998 O
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O MONITORED RETRIEVABLE STORAGE NATURE OF MRS i
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INTEGRATED ROLE i
e LARGE, SHIELDED HOT CELL FACILITY t
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MECHANICAL HANDLING l
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e PASSIVE STORAGE e
LIMITED ACCIDENT POTENTI AL l
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WE APE HERE TO DISCUSS PROPOSED RULE OIANGES TO OUR EXISTING RULE 10 CFR PART 72 THAT COVERS LICENSING THE STOPAGE OF SPBE FUEL AT AN It0EPEB0BE SPBE FUEL STORAGE INSTALLATION (ISFSI). THESE CHANGES WOULD VAINLY ADD LANGUAGE TO PART 72 FOR LICalSING THE STORAGE OF SPENT FUEL AND HIGH-LEVEL RADI0 ACTIVE WASTE (HLW) AT A M0filTORED RETRIEVABLE STORAGE FACILITY (MRS). AN MRS, IF AUTHORIZED BY CON 3RESS, WOULD BE DESIGNED, C0f1STRUCTED AfD OPERATED BY THE DEPARTMENT OF ENERGY (DOE). SUCH A FACILITY WOULD BE SUBJECT TO LICENSING BY THE C0FNISSION, PROPOSED CHANGES WOULD ALSO CLARIFY CERTAIN ISSUES THAT HAVE ARISEN SIflCE PART 72 WAS PADE EFFECTIVE ON NOVBEER 28, 1980 At0 ADD CONFORMING AE NDMENTS TO PARTS 2,19, 20, 21, 51, 70, 73, 75, AfD 150.
ESSRS. LELAND C. ROUSE, NMSS, JOHfl R. ROBERTS, NMSS, TOM CLARK, NMSS, L'
LEON L. BERATAN, ES, ROBERT KORNASIEWICZ, RES, BOB NULSEN, tESS SWEGUARDS, AfD CARL SAWYER, NMSS SAFEGUAPDS ARE HEPE TODAY TO ASSIST fE.
DR CLARK WILL PRESBE A DISCUSSION ON MRS AT THIS TIfE.
AS fMIONED BEFORE THE PRIMARY PURPOSE OF THE PROPOSED 01ANGES IS TO ADD SPECIFICS, NECESSARY FOR LICENSING MRS, TO JO CFR PART 72. MUOi 0F TlilS ACTION WAS MAINLY ADMINISTRATIVE IN NATUPE WIT 11 SOfE TECHNICAL CONSIDERATI0f1S AS REGARDS HIGH-LEVEL WASTE AND CERTAIN SPECIFIC REQUIREENTS IN Tite NUCLEAR WASTE POLICY ACT OF 1982 (fMPA). PART 72 C0 TRAINS PROCEDUFES, SITING CRITERIA, GENERAL DESIGN CRITERIA, O'JALITY ASSURANCE PEQUIREENTS, OPERATIONAL REQUIREMS AflD SAFEGUARDS REQUIRBMS FOR SAFE STORAGE OF SPBE FUEL., TiiE O
- NRC STAFF HAS EVALUATED TE REQUIRENES IN TE NWPA FOR CONSTRUCTION AND OPERATION OF AN MRS Ato FINDS THAT TESE REQUIREENTS IN PART 72 ARE f
APPLICABLE. TE TECHNICAL CRITERIA 0F PART 72 ARE CURRENTLY BEING USED BY DOE FOR TE CONCEPTUAL DESIGN WORK FOR MRS. SINCE TERE WILL APPARENTLY BE ONLY ONE MRS, ADDING A SEPARATE PART TO TE COPNISSION'S REGULATIONS WAS DEEKD INAPPROPRIATE.
f IN TE DISCUSSION COVERIllG VUGRAPHS 1 THROUGH 5 WE WILL COVER THE PROPOSED l
RULE.
IN THE REMAINDER OF THE DISCUSSION WE WILL RELATE THE TOPICS ON YOUR AGENDA TO SHOW HOW T EY ARE APPLICABLE TO LICENSING MRS. PART 72 WAS REVIEWED BY THIS SUBC0mITTEE ON JANUARY 3,1979.
O THE eR0e0 SED RULE GiANGES WERE SENT TO THE C0m!SS10N ON NOVEfBER 25,1985 I
AS SECY-85-374. S0 FAR WE HAVE RECEIVED 3 APPROVAL VOTES FOR PUBLICATION OF THE PROPOSED RULE.
j
! NOW DIRECT YOUR ATTENTION TO THE FIRST VUGRAPH AND WILL PROCEED WITH l
DISCUSSION OF THE PROPOSED RULE.
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VUGRAPH 1 1
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NUCLEAR WASTE POLICY ACT OF 1982 l
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o CLARIFY ISSUES CONCERNING PART 72 i
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O VUGRARi 1 - DISCUSSION 1.
THE NUCLEAR WASTE POLICY ACT OF 1982 (fMPA) IN SECTION 141(D) 0F SUBTITLE C (" MONITORED RETRIEVABLE STORAGE") 0F TITLE I REQUIRES TilAT A MONITORED RETRIEVABLE STORAGE FACILITY (MRS) BE SUBJECT TO LICENSil1G BY TliE C0t11SS10N, IF CONGPESS AlmiORIZES CONSTRUCTION OF SUCH AN lllSTALLATION. AN MPS WOULD BE CONSTRUCTED AfD OPERATED BY DOE FOR STORAGE OF SPBR NUCLEAR FUEL AfD HIGH-LEVEL RADI0 ACTIVE WASTE (HLW). LANGUAGE WOULD BE ADDED TO 10 CFR PART 72 FOR LIC91SIf1G MRS.
I WILL DISCUSS TliE JUSTIFICATION TilAT COVERS THIS FURiliER IN VUGRARI 2.
2.
CHANGES WOULD ALSO BE ADDED TO CLARIFY CERTAllt ISSUES TIMT HAVE O
ARISEN SINCE PART 72 WAS MADE EFFECTIVE Oft NOVEFBER 28,1980. TliESE ISSUES WILL BE DISCUSSED LATER Uf0ER WGRARi 4.
3.
CONFORMING AMBOME!HS WOULD BE f%DE TO 10 CFR PARTS 2,19, 20, 21, 51, 70, 73, 75, AfD 150. PARTS 19 AfD 20 WOULD BE SIMPLIFIED BY DELETING liiE PHRASE "AfD PEPS 0fG LICENSED TO POSSESS POWER REACTOR SPBU FUEL IN AN If0EPB086 SPOR FUEL STORAGE INSTALLATION (ISFSI) PUPSUAfR TO PART 72 0F T111S CHAPTER" IN SECTIONS 19.2 AND 20.2. Tills RiRASE IS REDUf0AfE. C0fGIDERATION OF HLW STORAGE IN AN MRS IS ADDED TO APPROPRIATE SECTIONS Ill FARTS 2, 20, 21, 51, 70, 73, 75, AfD 150. WGRAPH 5 PROVIDES MORE DETAILED INF0ff%T10N CONCERNING CONFORMING IIENDMBUS TO PART 51.
O
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WGRAPH 2 i
l 1
OWm IN PART 72 REGARDS MRS f
l i
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o STORAGE OF SPENT FUEL i
o STORAGE OF SOLIDIFIED HIGH-LEVEL. RADI0 ACTIVE WASTE i
(HLW) i 1
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0 PRSLICENSE o
PRS PRNISIONS NOT EFFECTIVE TRESS CONGRESS fQ AUTHORIZESCONSTRUCTION i
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'aV VUGRAPH 2 - DISCUSSION 1.
STORAGE OF ONLY SPENT FUEL AT AN MRS COULD BE LICENSED UNDER EXISTING PART 72, BECAUSE AN PRS WOULD BE AN ISFSI UNDER 00E CONTROL.
2.
HOWEVER, EXISTING PART 72 COULD NOT BE USED TO LICENSE THE STORAGE OF HLW. ADDITIONS ARE NECESSARY TO EXPLICITLY COVER LICENSING THE STORAGE OF HLW AT AN MRS. FROM A TECHNICAL VIEWPOINT STORAGE OF SOLID HLW IS NOT SIGNIFICANTLY DIFFERENT FROM THE STORAGE OF SPENT FUEL. THE O
REASONS FOR THIS CONCLUSION WILL.BE DISCUSSED UNDER VUGRAPH 3.
3.
THE NWPA SPECIFIES THAT TE P0NITORED RETRIEVABLE STORAGE FACILITY PROVIDE FOR THE LONG-TERM STORAGE OF SPENT NUCLEAR FUEL OR HIGH-LEVEL RADI0 ACTIVE WASTE. AN MRS PUST BE DESIGN:D TO ACC&MODATE SPENT NUCLEAR FUEL AND HIGH-LEVEL RADI0 ACTIVE WASTE FROM CIVILIAN NUCLEAR ACTIVITIES: TO PERMIT CONTINUQUS PONITORING, MANAGEENT AND MAINTENANCE OF SUCH SPENT FUEL AND WASTE: TO PROVIDE FOR THE READY RETRIEVAL OF SPENT FUEL AND WASTE FOR FURTHER PROCESSING OR DISPOSAL; 1
AND TO SAFELY STORE SUCH FATERIAL AS LONG AS l'AY BE Q
NECESSARY THROUGH APPROPRIATE MAINTENANCE OR REPLAC&ENT OF TliE INSTALLATION, IF REQUIRED.
IT IS CLEARLY INTENDED THAT THE MRS BE CAPABLE OF PROVIDillG THE REQUISITE SAFE STORAGE FOR A RELATIVELY LONG PERIOD OF TIE. FOR THESE REASONS A 40-YEAR LICENSE WOULD BE ISSUED TO DOE FOR TH STORAGE OF SPENT FUEL AND HLW AT AN MS IN THE PROPOSED RULE. THE 20 YEAR LICENSE PERIOD FOR AN ISFSI REMAINS i
l UNCHANGG.
l 4.
THE CHANGES CONCERNING LICENSING FOR MRS WOULD NOT BECOE EFFECTIVE UNTIL AFTER C0lERESS AllTHORIZES CONSTRUCTION OF l
SUCH AN INSTALLATION.
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0 0
1 WGRAPH 3 EQUIVALENCY OF SOLID HIGH-LEVEL RADI0 ACTIVE WASTE At0 SPENT FUEL STORAGE o
ENVIR0tMMAL ASSESSENT - NUPEG-1092 o
C0WARIS0N OF HLW WITH SPOR FUEL i
o PROPOSED RULE RESTRICTS HLW TO i
I SOLID FORi l
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_ _ _. _. _ _ _. _. _. _. _... -.. _. ~. _ -. _
""""^'" ' - "' 8 '88 ' "
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i AS DISCUSSED UNDER VUGRAPH 2 ADDITIONS TO PART 72 AE NECE l
COVER STORAGE OF HLW AT AN PRS. THE FOLLOWING DISCUSSION I
TE BASIS FOR SHOWING TE EQU1 VALENCY OF SPENT FEL AE HLW F STORAGEPURPOSES 1.
AN ENVIR0 RENTAL ASSESSPENT, PUBLISHED AS NUEG-1092 f
ENTITLED, "ENVIROWENTAL ASSESSENT FOR 10 CFR PART 72-LICENSE REQUIRENNTS FOR THE INDEPENDENT STO 4
SPENT FEL AND HIGH-LEVEL RADIDACTIVE WASTE" (AUGUST 1984),
CONCLLIES THAT SOLID HLW IS COPPARABLE TO SPENT FEj GEERATION AM) RADI0 ACTIVITY CONTENT ON A PER PETRIC j
j AlO THAT TE STORAGE OF SOLID EW IN AN PRS WOULD NOT f
i
'O SiGNIFiCAnttY AFFECT w ENviRmNT.
2.
Fipt A TECWi! CAL VIEWPOINT STORAGE OF SOLID EW IS t0T i
SIGNIFICANTLY DIFFERENT FROM STORAGE OF SPENT FEL B i
l HLW WOULD BE SOLIDIFIED IN CONTAlfERS THAT CAN BE HAM j
}
STORED SIMILAR 10 SPENT FEL STORAGE CONTAlfERS, (2) TE HLW F051WILL BE EQUIVALENT TO SPENT FEL AS A LEACHING BARRIER, (3)
TE EAT E RADI0 ACTIVITY ASSOCIATED WITH TE KW PACKAG t
j BE EQUIVALENT OR LESS THAN THE EAT 2 RADIOACTIVITY WITH PACKAGED SPENT REL, (4) 1)EE IS NO CRITICALITY PROBLEM I
WITH EW BECAUSE TE SPECIAL NUCLEAR MATERIAL CONTENT IS SO LOW t
Ale (5) NO RADIDACTIVE GASES AK) LITTLE RADI0 ACTIVE 10 l
I ASSOCIATED WITH E W.
!O 1
O i
3.
AN ANNOUNCED PURPOSE FOR AN MRS IS STORAGE OF SPENT FLEL Ato HIGH-LEVEL RADIDACTIVE WASTE PRIOR TO SHIRENT TO A HLW REPOSITORY FOR DISPOSAL.10 CFR PART 60 REQUIRES THAT HLW BE IN A SOLID FORM AND PLACED IN i
A SEALED CONTAINER, AT SECTION 60,135(c). SINCETHE SCOPE OF PRS DOES NOT INCLUDE CHEN! CAL REPROCESSING 0F SPENT FUEL, NO LIQUID HLW WOULD BE GENERATD AT TIE FRS. NOR IS 1}ERE ANY ANTICIPATED NEED FOR STORAGE OF i
L10VID HLW AT AN MRS. THUS, THE PROPOSED RULE RESTRICTS STORAGE TO SOLID HLW.
O I
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WGRAPH 4 CLARIFY ISSUES CONCERNING PART 72 o GBERAL DESIGN CRITERIA 2
SPENT FUEL CLADDING TORNADO MISSILES 1
i i
o D O GENCY PLANS UALITY ASSURANCE
! O i
i o TEINS " SAFE 1Y-RELATED" A2 l
"lMPORTANT TO SAFETY" i
O i
~ O VUGRAPH 4 - DISCUSSION AS STATED IN THE DISCUSSION UNDER VUGRAPH 1, SEVERAL CHANGES ARE PROPOSED IN EXISTING PART 72 FOR CLARIFYING PURPOSES. TliEY CONCERN:
1.
GEERAL DESIGN CRITERIA 1.1. SECTION 72.72(H)(1) ISECTION 72.92(H)(1) 0F TiiE PROPOSED RULEl 0F EXISTING PART 72 STATES, "TiiE FUEL CLADDING SHALL BE PROTECTED AGAINST DEGRADATION AND 600SS RUPTURES." THIS PARAGRAPli HAS BEEN PDDIFIED TO ALLOW FOR CONSIDERATION OF OTiiER TYPES OF CONFINEE NT AS WELL AS, SUCH AS CANNING, FOR PREVENTING RELEASE OF RADICACTIVE MATERIAL.
1.2. CURRENTLY PART 72 REQUIRES AT SECTION 72.72(B) TilAT STRUCTURES, SYSTENS, AND COWONENTS IWORTANT TO SAFETY BE DESIGNED TO WITHSTAND THE EFFECTS OF l
TORNAD0ES.
IT ALSO STATES THAT AN ISFSI NEED NOT BE PROTECTED FROM TORNADO MISSILES.
IT WAS ASSLM D ISFSis WOULD BE OF THE WATER BASIN TYPE AND WOULD BE BELOW GRADE AND THAT 111E WATER WOULD MITIGATE THE IWACT OF P01BITIAL TORNADO DRIVEN MISSILES CURRENTLY FAVORED DESIGE, SUCH AS ETAL CASKS, CONCRETE l
SILOS, A2 MRS HANDLING AND LAG-STORAGE (FACILITIES TBf0RARY STORAGE TO FACILITATE OPERATIONS) HAVE COWONENTS IWORTANT TO SAFETY ABOE GROUND AND l
EXPOSED TO TORNADO MISSILES. THE STATB9ft THAT AN ISFS1 NEED NOT EE PROTECTED AGAINST TORNADO MISSILES IS DELETED IN TliE PROPOSED RULE.
IT IS CONSIDERED PPl; DENT TliAT DESIGN BASES INCLUDE CONS!DERATION OF TORNADO DRIVEN MISSILES, 1
l UNLESS IT CAN BE SHOWN TliAT SU0i MISSILES WILL NOT ADVERSELY AFFECT STRUCTURES, l
l SYSTEMS, AND CONONENTS ITORTANT TO SAFETY.
2.
CURRENTLY SECTION 72.19, "EERGENCY PLAN," REFERS 4CES APPENDIX E TO PART 50. THE REFERENCE TO APPE21X E IS DELETED AND SPECIFIC REQUIRENNTS O
APPROPRIATE TO AN ISFSI OR MRS AFE SET FORTH. THE PROPOSED CHANGES SPECIFY l
THAT ISFSI OR MS APPLICATIONS INCLUDE PLANS FOR COPING WITH ONLY ONSITE
~
p EMERGENCIES. THE EVALUATIONS CITED IN THE SUPPLEMENTARY INF0FFATION, SECTION 10 SUPPORT THE CONCLUSION THAT OFFSITE ERRGENCY PREPAREDNESS IS NOT NECESSARY.
ESTIMATED POTENTIAL DOSES ARE FAR BELOW TliE PROTECTIVE ACTION GUIDES SET FORTH BY EPA FOR IMPL9ENTING PROTECTIVE ACTIONS FOR NUCLEAR INCIDENTS (1-5 REM WHOLE B0DYs 5-25 REN THYR 0ID). COWENTS ON TliE C0ffilSSIONERS NOTATION VOTE SHEETS INDICATE TilAT THE PROPOSED RULE SHOULD INCLUDE LIMITED DERGENCY PUiNNING PROVISIONS FOR OFFSITE DERGENCY RESPONSE.
3.
EXISTING PART 72 REFERS TO APPENDIX B TO PART 50 FOR THE CRITERIA FOR A QUALITY ASSURANE PROGRAM. SUBPART G ("OUALITY ASSURANE") IS MODIFIED TO SPECIFY QUALITY ASSURANCE REQUIREENTS APPROPRIATE FOR AN ISFSI OR MRS IN TiiE BODY OF THE RULE. Tills PROCEDURE IS PREFERABLE TO Rtrt2<ENCING AN APPENDIX.
HOWEVER, IF AN APPLICANT HAS AN APPROVED QUALITY ASSURANE PROGRAM TliAT MEETS THE CRITERIA 0F APPENDIX B, THE PROPOSED OIANGES PERilT THIS. PROGRAM TO BE Cl APPLIED TO AN ISFSI. A QUALITY ASSUPANE PROGRAM TliAT MEETS THE CRITERIA IN APPENDIX B 0F PART 50 WOULD ALSO PEET THE REQUIR9ENTS OF PROPOSED SUBPART G THIS WOULD AVOID DUPLICATION OF EFFORT.
~
4.
CURRENTLY PART 72 USES TliE PHRASES " SAFETY-RELATED" AND "lMPORTANT TO SAFETY" IfGERCHANGEABLY WHEN REFERRING TO STRUCTURES, SYSTEMS, AND COMPONDITS.
THE TERM " SAFETY-RELATED" IS ELIMINATED. THE TERi "lMPORTAfE TO SAFEIY," WHICH IS DEFINED IN SECTION 7.3, IS USED EXCLUSIVELY. TlilS USAGE IS IN CONF 0PFAN E WITH TliE PROPOSED RULE ON TliE IMPORTAfR-TO-SAFETY ISSUE (SECY-85-119, 4/5/85).
I SECY-85-119 HAS BEEN RETUPliED TO TliE IE STAFF FOR FURTliER WORK. HOWEVER, TliE WE BELIEVE THAT THE USE OF "lWORTANT TO SAFEIY" WILL APPLY, BECAUSE THE ESTIMATED OFFSITE DOSES ARE S0 LOW.
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VUGRAPH 5 J
PART 51 CONF 0@llNG AENDENTS l
o ADD LANGUAGE FOR STORAGE OF HIGH-LENE. RADI0 ACTIVE WASTE IN A MONITORED RETRIEVABLE STORAGE FACILITY (MRS) o SCOPE OF ENVIRONTNTAL IWACT STATEMENT AND/0R ENVliOPENTAL ASSESSEffi FOR MRS o
CLARIFY 00NDIT10NS FOR SUEllTTAL OF ENVIR0ffENTAL REPORT O
BY DOE 4
O
O VUGRAPH 5 - DISCUSSION 1.
SECTIONS 51.20(B)(9), 51.20(B)(10), 51.60(B)(1)(111),
51.60(B)(11), AND 51.61 ARE REVISED TO ADD LANGUAGE TO ODVER LICENSING FOR MRS.
2.
SECTIONS 51.30(c), 51.80(B)(2), AND 51.97(B) ARE ADDED TO SET FORTH LIMITS ON THE SCOPE OF AN ENVIRONWAL ASSESSENT, DRAFT ENVIRCNWAL IMPACT STATEENT, AND FINAL ENVIRONENTAL IMPACT STATEENT FOR AN ISS. THESE RESTRICTIONS ARE SECIFIED IN O
THE NWPA.
3.
SECTIONS 51.60(A) AND 51.61 ARE REVISED TO CLARIFY CONDITIONS FOR SLR11TTAL OF AN ENVIR0ffENTAL REPORT BY DOE.
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VUGRAPH 6
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GENERAL DESIGN CRITERIA o
GEERAL CONSIDEPATIONS o
OVERALL EQUIRUENTS o
CRITERIA FOR NUCLEAR CRITICALIT( SAFET(
o CRITERIA FOR RADIOLOGICAL PROTECTION o
CRITERIA FOR SPENT FUEL, HIGH-LEVEL RADI0 ACTIVE WASTE AND OTHER RADI0 ACTIVE WASTE STORAGE AND HANDLING O
o CRITERIA FOR DEC&MISSIONING 1
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O VUGRAPH 6 - DISCUSSION FOR REASONS STATED IN PREVIOUS VUGRAPHS THE STAFF BELIEVES THAT THE TECHNICAL CRITERIA IN 10 CFR PART 72 AE ADEQUATE FOR LICENSING MRS. THE POSSIBILITY OF A LARGE SPENT FUEL STORAGE FACILITY, REFERRED TO AS AWAY-FROM-REACTOR STORAGE AT THE TIE, WAS CONSIDERED IN 10 CFR PART 72 At0 NUEG-0575, "FGEIS ON HANDLING AND STORAGE OF SPENT LIGHT WATER PGER REACTOR FUEL." THE FOLLCHING DISCUSSION CONSIDERS THE TECHNICAL CRITERIA ON THE MEETING AGEf0A AND RELATES THEIR USE FOR MRS LICEtSING.
I NOW DIECT YOUR ATTENTION TO Tlf VUGRAPH 6, WHICH LISTS THE TITLE OF SECTIONS UNDER SUBPART F - GENERAL DESIGN CRITERIA.
IN iDST CASES TE GB4ERAL DESIGN CRITERIA AE GENERAL EN0 UGH TO BE USED FOR LICENSING AN ISFSI OR AN MRS.
IN M)ST OF THE GENERAL DESIGN CRITERIA ONLY LANGUAGE APPROPRIATE FOR LICENSING MRS IS ADDED.
I WILL DISCUSS HEE THOSE CRITERIA THAT NEEDED TO BE MDDIFIED FOR LICENSING MRS.
1.
A NEW PARAGRAPH (B) IS ADDED TO SECTION 72.91 [WAS 72.71,1, GENERAL CONSIDERATIONS, TO PESTRICT THE STORAGE OF HIGH-LEVEL RADI0 ACTIVE WASTE AT AN MRS TO A SOLID, WHICH IF STORED IN A WATER POOL MUST BE COPATIBLE TO WATER, 2.
PARAGRAPH (H)(1), UNDER SECTION 72.92 [WAS 72.721, OVERALL EQUIREMENTS, IS CHANGED TO ALLOW CANNING AS AN ADDITIONAL CONFINEENT TO PREVENT RELEASE OF RADI0 ACTIVE MATERIAL. EXISTING PART 72 STATES ONLY THAT FUEL CLADDING filST BE PROTECTED AGAINST DEGREDATION AND GROSS RUPTURES.
A PARAGRAPH (H)(li) IS ADDED TO E0VIRE MONITORING OF STOPAGE SYSTEMS TO O
O DETERMIE WHEN CORECTIVE ACTION IS NEEDED, A PARAGRAPH (H)(5) IS ADDED TO EQUIE EADY ETRIEVAL OF HIGH-LEVEL RADI0 ACTIVE WASTE. A NEW PARAGRAPH (t.)
IS ADDED TO EQUIRE READY RETRIEVAL OF SPENT FUEL, AS WELL.
3.
SECTION 72.93 [WAS 72.731; CRITERIA FOR NUCLEAR CRITICALITY SAFETY, IS BROADEED TO ELIMINATE THE IIPLICATION THAT ONLY WATER P0OLS ARE COVERED.
4.
SECTIONS 72.94 (WAS 72.741, CRITERIA FOR RADIOLOGICAL PROTECTION, 72.95
[WAS 72.751; CRITERIA FOR SPEhT FUEL, HIGH-LEVEL RADI0 ACTIVE WASTE, AND OTHER RADI0 ACTIVE WASTE STORAGE AND HANDLING, AND 72.% [WAS 72.76]; CRITERIA FOR DEC0mISSIONING ARE UNCHANGED EXCEPT TO ADD LANGUAGE COVERING STORAGE OF I
SPENT FUEL AND HIGH-LEVEL WASTE AT AN MRS.
AS EGARDS PROBABLISTIC RISK ANALYSIS (PRA) AND TRANSURANIlN ELEENTS, DR. CLARK WILL SPEAK ON THESE TOPICS, O
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VUGRAPH 7 DESIGN BASIS ACCIDDlTS O
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- Q VUGRAPH 7 - DISCUSSION 1.
SECTION 10 IN THE SUPPLEMENTARY INFORMATION CITES ACCIDENT EVALUATIONS FROM TE FOLLOWING PUBLISHED DOClFBffS:
1.1 NUEG-0575, " GENERIC ENVIRONENTAL IMPACT STATEENT ON HANDLING AND STORAGE OF SPENT LIGHT WATER POWER REACTOR FUELS," AUGUST 1979.
1.2 NUEG-0709, " SAFETY EVALUATION REPORT RELATED TO THE RENEWAL OF MATERIAL LICENSE Sm-1265 FOR ECEIPT, STORAGE AND TRANSFER OF SPENT FUEL PURSUANT TO 10 CFR PART 72 - MORRIS OPERATION -- GENERAL ELECTRIC COWANY --
DOCKET NOS. 70-1308 AND 72-1," JULY 1981.
THE ACCIDENTS EVALUATED IN THESE NUEGS INVOLVE STORAGE OF SPENT FUEL PRIMARILY IN WATER POOLS.
IN NUREG-1140, "A EGULATORY ANALYSIS ON EERGENCY O
PREPAREDNESS FOR FUE. CYCLE AND OEER MDI0 ACTIVE MERIAL UCENSEES - DMFT REPORT FOR C0ltENT," (JUNE 1985) THE STAFF ALSO EVALUATES POTENTIAL ACCIDENTS INVOLVING STORAGE SPENT FUEL IN CASKS. ESSENTIALLY, TE CONDITIONS ASSLPED FOR THESE ACCIDENTS ARE (1) 10% OF THE KRYPTON-85 AVAILABLE IN THE FUEL IS RELEASED, (2) 1% OF THE 10 DINE-129 IN THE FUEL IS RELEASED, (3) FUEL BURN-UP IS 33,000 EGA-WATT DAYS PER MTU, (4) THE FUEL IS COOLED LONG EN0 UGH TO ALLOW TE SHORT-LIVED RADIONUCLIDES TO ESSENTIALLY DISAPPEAR (AT LEAST ONE YEAR), AND (5)
CONSERVATIVE ETEOROLOGY, IN NO CASE DO TE ESTIMATED DOSES APPROACH THE PROTECTIVE ACTION GUIDES SET FOR BY TE ENVIR0ffENTAL PROTECTION AGENCY FOR IWLEENTING PROTECTIVE ACTIONS FOR NUCLEAR INCIDENTS, THUS, IT CAN BE CONCLlDED THAT 'INE POTENTIAL RADIOLOGICAL IWACT FR&l STORAGE OF SPENT FUEL IS LOW. DR. CLARK WILL DISCUSS EVALUATIONS MADE FOR PRS.
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PHYSICAL PROTECTION AND PREVENTION OF SABOTAGE O
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VUGRAPH 8 - DISCUSSION SUBPART H OF PART 72 ADDESSES PHYSICAL PROTECTION EQUIREENTS APPLICABLE AT AN ES. THE CRUCIAL EQUIRBENT IS THAT A PLAN MJST BE SID11TTED DEMONSTPATING HOW APPLICABLE EQUIREENTS OF PART 73 WILL BE CARRIED OUT. DETAILED EQUIE-ENTS FOR PROTECTION AGAINST RADIOLOGICAL SAB0TAGE AT AN MRS ARE SET FORTH IN 873.50.
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- WGRAPH 9 SITING EVALUATION FACTORS GENERAL CONSIDERATI0fG o
DESIGN BASIS EXTERNAL NATURAL EVENTS o
DESIGN BASIS EXTERNAL MAN-INDUCED EVENTS o
o SITING LIMITATIONS O
IDENTIFYING REGIONS AR0lf0 AN ISFSI OR MRS SITE o
DEFINING POTENTIAL tm.L,is 0F THE ISFSI OR MRS ON THE REG o
GE0 LOGICAL AND SEISPDLOGICAL CHARACTERISTICS o
CRITERIA FOR RADI0 ACTIVE MATERIALS IN EFFLUE o
l RADIATION FROM AN ISFSI OR PRS CONTROLLED AREA 0F AN ISFSI OR PRS o
SPENT FUEL OR HIGH-LEVEL RAD 10ACIVE WASTE TR O
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VUGRAPH 9 - DISCUSSION
- '.O SECTION 72.91, GENERAL CONSIDERATIONS, STATES IN PART THAT AN ISFSI OR MRS SITE MJST BE EXAMINED FOR EXTERNAL AND MAN-INDUCED EVENTS THAT COULD AFFECT ITS OPERATIONS. THE IMPORTANT NATURAL PHENOENA AND f%N-INDUCED ACTIVITIES MUST BE IDENTIFIED AND EVALUATED.
IF ADEQUATE PROTECTION CA50T BE PROVIDED THROUGH DESIGN, THE SITE MJST BE DEEED UNSUITABLE. THE NATURAL PHENONNA TO BE EVALUATED INCLUDE SEISMIC ACTIVITY.
IN ORDER TO REDUCE THE SUBSTANTIAL ESOURCES THAT WOULD BE EXPENDED IN INVESTIGATION WORK TO ESTABLISH SITE-SPECIFIC SEISMIC DESIGN VALUES,10 CFR PART 72 CONTAINS SOEWHAT l
SIPPLIFIED AND P0E SPECIFIC SEISMIC CRITERIA. THESE CRITERIA FOR AN ISFSI AE l
NOT CHANGED IN THE PROPOSED RULE. THE PROPOSED CHANGES STATE THAT A SITE-SPECIFIC INVESTIGATION TO ESTABLISH SEISMIC VALUES FOR DESIGNS INVOLVING SUCH THINGS AS CANISTERS, CASKS, DRYWELLS, AND SILOS, VAULT TYPE STRUCTUES O
RELATED TO THESE DESIGNS, SUCH AS BUT NOT LIMITED TO RECEIVING AND HANDLING AND l
LAG-STORAGE FACILITIES WOULD REQUIRE SEISMIC EVALUATIONS AS SPECIFIED IN PROPOSED SECTION 72.81(A).
i NONE OF THE TECEICAL EQUIREIENTS IN SUBPART E - SITING EVALUATION FACTORS WOULD BE CHANGED. LANGUAGE IS ADDED AS APPROPRIATE EGARDING LICENSING FOR MRS. A SECTION 72.75 SITING LIMITATIONS IS ADDED TO SET FORTH LIMITATIONS FOR SITING AN MRS, WHICH ARE REQUIRED BY THE NWPA. SECTION 72.69,
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ISFSI EERGENCY PLANNING ZONE OF EXISTING PART 72 WOULD BE ELIMINATED.
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.O VUGRAPH 10 i
i EXTERNAL PHENDENA, INCLUDING PROTECTION AGAINST FLOODS, i
o TORNAD0ES AND TORNADO MISSILES.
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l VUGRAPH 10 - DISCUSSION IN PROPOSED SECTION 72.92(B) IT IS STATED TliAT STRUCTURES, SYSTEMS, Af0 COPPONENTS IFFORTANT TO SAFETY I4JST BE DESIGNED TO WITliSTAND THE EFFECTS OF NATURAL PHENOMENA SUCH AS EARTHOUAKES, TORNADOES, LIGHTENING, HURRICANES, FLOODS, TSUNAMI, AND SIECHES WITHOUT IPPAIRING THEIR CAPACILITY TO PERF0PN SAFETY FUNCTIONS, CURRENTLY PART 72 STATES THAT AN ISFSI EED NOT BE PROTECTED AGAINST TORNADO MISSILES.
IN VIEW OF TliE RECENT DISCUSSIONS CONCERNING THE DESIGN OF MRS AND DESIGNS SID11TTED FOR STORAGE OF SPENT FUEL IN CASKS ON REACTOR SITES, THIS STATEMENT IS ELIMINATED IN PROPOSED PART 72. SINCE THERE WILL PROBABLY BE STRUCTURES, ".YSTENS, AND COPPONENTS IMPORTANT TO SAFETY EXPOSED TO POTB(TIAL TORNADO MISSILES, IT IS CONSIDERED APPROPRIATE THAT DESIGN
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BASES SHOULD INCLUDE TlilS CONSIDERATION, UNLESS.i.N ISFSI OR MRS IS LOCATED ON A SITE THAT CAN CLEARLY BE DEMONSTRATED AS A FLOOD-DRY SITE, THE EFFECTS OF FLOODINGF1JSTBEbNSIDERED. TllE DESIGNS SHOULD INCLUDE PROTECTION FLOODING, AS APPROPRIATE.
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