ML20196C254
| ML20196C254 | |
| Person / Time | |
|---|---|
| Issue date: | 11/18/1988 |
| From: | Zech L NRC COMMISSION (OCM) |
| To: | Rousso S ENERGY, DEPT. OF |
| References | |
| NUDOCS 8812070236 | |
| Download: ML20196C254 (6) | |
Text
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h, UNITED STATES NUCLEAR REGULATORY COMMISSION e
3 E
W ASHINGTON, D, (?, 20666
%,*****s/
November 18, 1988 CHAIRMAN United States Department of Energy ATTN:
Mr. Sam Rousso, Acting Director l
Office of Civilian Radioactive Waste Management RW-122 Forrestal Building 1000 Independence Avenue, S.W.
Washington, D.C.
20585 I
Gentlement I am responding to your September 1, 1988 request for the comments of the Nuclear Regulatory Commission (NRC) on the Department of Energy's (DOE) Initial Version Dry Cask Storage l
Study (DOE /RW-0196).
The Commission's detailed comments are enclosed.
In general, we find it a well-balanced presentation of spent fuel storage requirements, of the in-pool consolidated fuel storage and dry storage technologies available to address those requirements in at-reactor storage, and of the impacts and costs of such storage.
i The Commission is concerned, however, that inadequate attention is being given to ensure the crapatibility of the various steps e
in the storage, transport, and disposal of spent fuel and thereby i
to enhance the safety and efficiency of fuel handling.
With a t
proliferation of storage options, it appears likely that fuel to i
be removed from reactor sites in some instancea may have to be i
returned to reactor pools to be unloaded and then loaded into L
transportation casks for shipsent off site.
In addition, subsequent operations at the repository, or a monitored L
retrievable storage (MRS) site, may be needed to repackags the I
fuel for ultimate disposal.
The Commission believes that radiation exposures and other handling riska should be minimized in the entire process from removing the fuel frs1 the reactor pool the first time to its ultimate disposal.
System analysis and action at this early stage could result in minimizing these handling risks, and we suggest that DOE proceed on this course of analysis and action to achieve cask design compatibility to the graatest extent possible, b
f0 8812070236 891118 g \\
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PDR COMMS NRCC CORRESPONDENCE PDC
I hope that our comments on this draft report have been helpful.
If you have any questions, please contact Hugh L. Thompson, Jr.
(telephone number 492-3352).
The Commission looks forward to I
commenting on your final report.
Sincerely,
[ M W. Lo([b.
Lando W.
Ze Jr.
Enclosure Detailed comments l
cc Charles Head, DOE l
1
NRC COMMENTS ON DOE DR'.' CASK STORAGE STUDY (DOE /RW-0196)
Page viii See the partial paragraph at the top of the page.
While as a practical matter topical reports have been referenced in dry storage licensing, there is no requirement to do so.
A license apolicant could simply submit a new design detailed in tho Safety Analysis h
Report submitted as part of the site-specific license l
application.
f l
viii see the first full paragraph and the sixth full l
and paragraph, respectively.
A utility does not apply i
11 for a general license.
Rather, the utility I
would register with the NRC to use a certified cask, l
thus committing to the specified conditions of the l
general license, i
1 l
viii Insert the following under lined wording at the end of l
first sentence, fourth full paragraph:
...for dry storage in that dry cask storace involves a new license under 10 CFR Part 72. While consolidation yhere it increases the number of assemblies oermitted to be stored in the cool involves an amendment to the i
10 CFR Part 50 license.
To the extent that utilities have consolidated scent fuel rods as a demonstration.
'l they have cerforjed these limited consolidations under 10 CFR 50.5%2 First of all,..."
x See the first full paragraph, In the third sentence l
the words, "for at least 30 years beyond the expiration of the operating license," refer to reactor pool storage also.
9 Delete the last sentence from the partial paragraph at the top of the page.
Revise the second sentence in the first full paragraph by incorporating the underlined words as follows:
"...all spent fuel storage pools where an evaluation shows that the cool efD support the additional weight...
11 See the fourth paragraph.
Please note that 10 CFR Part 72 has been recently amended (53 FR 31651, August 19, 1988).
It is now entitled "Licensing Requirements for the Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste."
. 11 Delete the last paragraph (including the continuation (cont'd) at the top of page 12) and replace it with the following paragraph:
"Consolidation where it increases the number of i
assemblies permitted to bc stored in the spent fuel pool involvos an amendment to the 10 CFR Part 50 license.
To the extent that utilities have i
consolidated limited numbers of spent fuel rods as a demonstration, they have performed these consolidation programs under 10 CFR 50.59."
12 See the second full paragraph. Again there is some lack of clarity in explaining the use of a reviewed topical report as a reference in a site-specific application.
It may be advantageous to a license applicant to do so, l
since it is an action that can reduce uncertainty (the l
proposed design having been reviewed by NRC staff) and l
effort, but it is not required by regulation.
13 Revise the first sentence in the third full paragraph to read:
"Consistent with this objective, the NRC staff i_g currgntiv develonina a crocosed rule for consideration by the Commission which would amend 10 CFR Part 72 12 provide a process for..."
13 Revise the first sentence of the fourth full paragraph to read:
"The crocosal under develooment envisions an amendment i
to 10 CFR Part 72 to specify the following process...
29 See the first full paragraph.
The first sentence concerning cask loading in the storage pool and boron is incorrect.
Nuclear criticality analyses to date have not taken credit for the presence of boron in the water.
30 Section 4.1.1.2, paragraph 3.
Gesellschaft fur Nuklear Service abH is improperly identified.
This should be General Nuclear Systems, Inc., the United States partnership.
34 Section 4.1.243, paragraph 1 (same comment as above for p 30).
. 35 Section 4.1.2.3, paragraph 1.
This section should note that the technical review panel set up by the NRC to
, investigate the acceptability of nodular cast iron for tiransportation easks has been completed.
It was cencluded that nodular cast iron should not be used as the primary structural material in spent fuel shipping casks based on the material proporties and available information at this time.
42 Section 4.1.4.2, paragraph 2, line 3.
The words, "safety analysis," should be topical report.
47 Revise the first nentence in the second paragraph in incorporating the underlined words as follows:
...with red consolida. tion are critnarily economic in nature.
Tney include the difficulties..."
49 Delete the first two eentences in the second full paragraph and replaca them with the following sentences:
"As explained in Chapter 2, consolidation where it increases the number of assemblies permitted to be stored in the spent fuel pool involves an amendment to 10 CFR Part 50 license.
To the extent that utilities have consolidated reds as a demonstration, they have performed these limited consolidations under 10 CFR 50.59."
Delete the words "local or" in the third full paragraph, third sentence.
50 Revise the wording in the second full paragraph, fourth sentence with the underlined words as follows:
...and will have to start by 1997 when a full-core..."
RTtarence:
"Spent Fuel Storage Rcquirements (1987)"
DOE /RL-87-ll, page 3.13, Table 3.4 shows full core reserve at Millstone 2 not lost until 1997.
72 See the first paragraph.
The reactor operating liconse may be amended at the end of plant operating life.
Thus, spent fuel may be stored in the reactor pool under a "possession only" license pursuant to 10 CFR Part 50.
The reactor license cannot be terminated until the reactor is decommissioned.
To fully decommission the reactor, all spent fuel must be removed from the site.
, ~.
4-81-85 In the Chapter 6, DOE discusses the use of the Nuclear Waste Fund to support additional at-reacto" storage.
The study finds that Nuclear Waste Policy Act of 1982 does not authorize DOE to use the Fund for providing such storage.
DOE also finds, as a matter of policy, that the Nuclear Waste Fund should not be used for at-reactor storage unless such storage would provide overall benefits to the waste-management system.
As these findings do not involve health and eafety issues, NRC takes no position thereon.
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