ML20214K236
| ML20214K236 | |
| Person / Time | |
|---|---|
| Issue date: | 11/21/1986 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| FRN-51FR19106 AB70-2-02, AB70-2-2, ACRS-T-1558, NUDOCS 8612020236 | |
| Download: ML20214K236 (257) | |
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O UN11ED STATES 1 NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCOMMITTEE ON SPENT FUEL STORAGE n
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O vast c nor cm er was UNITED STATES NUCLEAR REGULATORY COMMISSIONERS' ADVISORY COMMITTEE ON REACTOR SAFEGUARDS FRIDAY, NOVEMBER 21, 1986 The contents of this stenographic transcript of the proceedings of the United States Nuclear Regulatory Commission's Advisory Committee on Reactor Safeguards (ACRS), as reported herein, is an uncorrected record of the discussions recorded at the meeting held on the above date.
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.
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1 UNITED STATES OF AMERICA
, 2 NUCLEAR REGULATORY COMMISSION 3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4 SUBCOMMITTEE ON SPENT FUEL STORAGE 5
Nuclear Regulatory Commission Room 1046 1717 H Street, N.W.
Washington, D. C.
8 Friday, November 21, 1986 9
The subcommittee meeting convened at 8:30 a.m.
10 11 ACRS MEMBERS PRESENT:
12 DR. CHESTER P. SIESS 13 DR. DADE W. MOELLER 14 DR. FORREST J. REMICK 15 DR. PAUL G. SHEWMON 16 17 18 19 20 21 22 23 24 o 25 ACE-FEDERAL REPORTERS, INC.
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J 28861.0 2 BRT V("T 1 PROCEEDINGS 2 DR. SIESS: The meeting will come to order.
3 This is a meett.ng of the ACRS Subcommittee on Spent Fuel 4 Storage. l'am.Chester Siess, chairman of the Subcommittee.
5 The other ACRS members that are in attendance this morning 6 are, starting on my left, Dr. Moeller, Dr. Remick, and 7 Dr. Shewmon just went out to check his mailbox.
8 The purpose of the meeting is to continue our 9 review of 10 CFR Part 72, " Licensing Requirements for the 10 Independent Storage of Spent Nuclear Fuel and High Level 11 Radioactive Waste and the application of that to the 12 licensing oft a monitored retrievable storage facility, the
() 13 MRS.
14 The ACRS cognizant staff member for this meeting 15 is Owen Merrill, who is seated on my right.
16 The rules for participation in today's meeting 17 have been announced as part of the notice published in the 18 Federal Register on November 6th.
19 I would like for each speaker to first identify 20 himself or herself and then speak with sufficient clarity 21 and volume so that you can be heard by the others'present 22 and by the reporter.
23 These black things on the table.are microphones 24 but as loi.g as we are sitting around here we shouldn't have 25 any trouble. Anybody at the lectern, we'll hang a O
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2 I want to review a little history. Some time 3 back we dug up minutes of the first couple of meetings of
"'- That was in 1979, which isn't that long 4 this Subcommittee.
5 ago. Apparently it was long enough ago that we had to dig 6 them out of dead storage, microfilm or something to find 7 them. This was originally an ad hoc committee on spent 8 fuel storage n:ol design and like a lot of other ad hoc 9 subcommittees it went on ad infinitum, and became a 10 standing subcommittee.
11 It was originally formed to look at the design 12 aspects of expansion of spent fuel pools at operating 13 nuclear power plants, what I'll refer to as reracking. I
( )
14 don't;know that we ever looked at any reracking. It didn't 15 seem to be a major issue. The Staff asked a lot of 16 questions about the seismic analysis and there were of 17 course some questions about criticality and things of that 18 sort, and we had never met on that.
19 But in 1979, in May and again in July, we had 20 two meetings having to do with what was then known as ISFSI;
- 2) that was one of the notable acronyms developed by the NRC, 22 which'was Independent Spent Fuel Storage Installations.
23 That was a time at which Part 72 wcs being born and the 24 presentation at the May '79 meeting was made by R. Stanford.
f 25 Is he present?
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w 1 MR. STEYER: Mr. Stanford has retired.
2 DR. SIESS: He is retired. The other ACI ,
3 members present at that meeting I believe were Borowski, 4 Etherington and Matthis. I'm the only one that's still S around, which isn't a lot of help.
6 The rest of the presentations were made -- that 7 was all. Stanford was the only one present at that meeting.
8 In the July meeting, Bob Bernero, who used to i 9 work for the NRC and hasn't quite retired but he's doing 10 other things now. I never knew why Bob was involved in 11 the --
12 MR. STEYER: Mr. Bernero'at that time was a 13 deputy of the division that was handling that.
_-( )
14 DR. SIESS: Now, that wasn't --
15 MR. STEYER: He was in Research. I guess it was 16 Research.
17 MR. SAWYER: Mr. Bernero was the branch chief.
18 MR. ROUSE: Not at that time. But he had been.
i 19 MR. SAWYER: He had been.
20 DR. SIESS: Now, the original purpose of this 21 committee was this reracking and that was not handled by 22 NMSS; or Research, either. That was strictly an NRR 23 project.
24 So at the end of the day when we are through 25 with these guys we may want to talk a little bit about the s
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d 1 reracking because the question has been raised whether we 2 should be looking at it. Most plants are on the second 3 round of it now and there's some interesting questions 4 about it, about the scope of it.
5 We were in at the birth of Part 72. But it 6 wasn't being handled by any of the people that are here 7 today; right?
8 MR. ROUSE: Let me correct that just a little 9 bit, Dr. Siess. The fellow here on my right, John Roberts, 10 was involved with Research. John is from NMSS, but 11 following that rulemaking he had been project manager of 12 the generic environmental impact statement that the NRC did
() 13 on spent fuel storage and handling.
MR. STEYER: Also, just -- Stanford worked for 14 15 me at the time.
16 DR. REMICK: Chet, I might add at that time I 17 was serving on licensing boards and happened to be a board 18 member on the first use of Part 72, which was GE Morris.
, 19 A comment I would make because I have been on
- 2) some reracking pools, I thought Part 70 was a tremendous l 71 improvement from the board standpoint, knowing what the 22 regulations are all about.
23 DR. SIESS: 70 or 72?
- t 24 DR. REMICK: 72.
25 DR. SIESS: 72 wasn't used for reracking.
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1 DR. REMICK: Meant 72 --
2 DR. SIESS: But 72 wasn't used for reracking.
3 It was used fc t- Morris.
4 DR. REMICK: That's right. But by comparison 5 and knowing what the regulatory requirements were for spent 6 fuel pools, they were better defined. At that time I 7 thought the Commission should go ahead when there's no 8 request and threw out regulations for reprocessing 9 facilities and put those in a separate part also.
10 We did write general design criteria for 11 reprocessing facilities somewhere back in history.
12 DR. SIESS: On Part 72, it was never brought to
() 13 ACRS for approval. I don't think we ever wrote a letter on 14 it even. You haven't found a letter, have you?
15 MR. MERRILL: I don't think -- I couldn't find a 16 letter. I didn't think we took any action.
17 DR. SIESS: I don't think so. And the main 18 issue when it was brought to us was some innovative 19 approaches to seismic siting. Mr. Beratan I think is well 20 acquainted with that, which I think we promptly helped to 21 shoot down, at least partly. But NRR also had some 22 problems with that, I believe.
23 In the course of our discussions, at the 24 Subcommittee meeting, our members, as is customary, had 25 comments on a number of things and expanded the discussion o)
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1 somewhat beyond the seismic approach. We discussed various 2 things like sabotage and maybe flooding, I'm not sure. Of 3 course at that time it was strictly pool storage and as I 4 understand it, from something I read, it was expanded 5 beyond pool storage before it was issued. Okay.
6 As I said, we never saw it after that. We were 7 not involved in the licensing of Morris or the ISFSI at 8 Rcbinson or the ISFSI at Surry.
.9 For the benefit of the Subcommittee members, the 10 reracking was an NRR issue. It is always handled as a 11 license amendment to what I think the regulations call the 12 production and utilization facility -- utilization facility.
() 13 Morris, Surry, and Roberts ISFSI simply got a 14 materials license through NMSS. They were not a materials 15 and facilities license, it was all through NMSS. Why we 16 were not involved I don't know. Nobody asked us. The 17 Commission didn't ask us to be involved. I don't think 18 anybody, sua sponte, brought it up.
19 We are now involved, officially, I think, in the 20 licensing of a monitored retrievable storage to be built by 21 the Department of Energy and licensed to them as a part of 22 the National Waste Policy Act -- is that the proper name?
23 Because we received a letter from the then chairman 24 Palladino, saying that the ACRS was to review and approve 25 and be involved in all actions under the National Waste
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2 That assignment, I think, is under review by the 3 Commission. We don't know exactly what will happen but we 4 are not worried about what might happen. Right now we are 5 obliged to review the MRS when it -- I guess I_should say 6 when and if it materializes. If it ever gets out of the 7 court or out of DOE or wherever it is going to be hung up.
8 And since the MRS is to be reviewed and licensed under Part 9 72, I thought it was time we looked at Part 72, at least in 10 as much detail and with as much understanding as we have of 11 other parts of the Code of Federal Regulations that apply 12 to nuclear power plants.
() 13 We had a meeting in March of this year but it 14 did not involve a complete look at Part 72.- It was aimed 15 partly at getting an overall picture because, as you can 16 tell from our questions, we didn't understand a lot of 17 things about it; and partly to look at the proposed changes 18 to Part 72 which, in themselves, were relatively minor; 19 simply present DOE as a licensee, and then it did something 20 -- high-level wastes were -- what was it?
21 MR. STEYER: High-level waste were included in 22 MRS --
23 DR. SIESS: Also, simply to expand it to cover 24 what MRS might include under the law.
- 25 So the object of this meeting is really to sort
- (1) i
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28861.0 9 BRT G of go through Part 72, step by step, with, I would say, a 1
.2 varying amount of detail. Some parts of it are fairly 3 straightforward translations of general design criteria and 4 so forth. Others are more specific and we need to 5 understand it because at some point in time we'll, 6 presumably, be reviewing the MRS.
7 The agenda has been developed to do that. I 8 suggested that we might learn something by looking at the 9 safety evaluation report, the actions that were taken in 10 connection with Surry and Robinson as good examples of how 11 Part 72 -- they ere much better examples than Morris.
! 12 Morris is a pool storage, the other two are a dry storage.
() 13 One aspect of the dry storage is the cask, and I l 14 believe that the cask has been essentially reviewed through l
15 a topical report in both instances; am I right?
16 MR. ROUSE: That is correct.
17 DR. SIESS: In other words, the cask is a 18 designed submitted by somebody that was reviewed. The 19 topical report was reviewed and the SER, more or less, just 20 references that.
21 Which branch in NMSS reviewed the cask? Was 22 that the transportation certification branch or was that 23 separate?
24 MR. ROUSE: No, sir, Dr. Siess. Lee Rouse.
25 The storage cask for the purpose of storage has O
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V 1 been reviewed by my branch, the advanced fuel and spent 2 fuel licensing branch. If those same casks, those same 3 designs are proposed for transportation they will, indeed, 4 then be reviewed by our transportation branch. We will 5 have Ross Chapell here with us a little later this morning 6 to sort of clear that.
7 DR. SIESS: I thought the modular cast iron had 8 already been proposed. You said "if."
9 MR. ROUSE: Not really. At one time a partial 10 application was submitted to our transportation branch. It 11 had to do with a proposed drop test over in Germany. They 12 failed to respond to some of the comments of the -- written p)
(_ 13 comments of our transportation branch and it was 14 subsequently withdrawn, so at the present time there is no 15 formal application for the modular cast iron cask for 16 transportation in house.
17 DR. SIESS: They had a question on the borated 18 steel internals?
19 MR. ROUSE: That's correct.
20 DR. SIESS: That's also a characteristic of the 21 cask that has been approved by your branch?
22 MR. ROUSE: Yes.
23 DR. SIESS: But those were issues only in terms 24 of the transportation and the drop test that went along 25 with it?
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N..Y l MR. ROUSE: That's correct. John Roberts, a 2- little later when he gets down to talking about the Surry 3 licensing will probably sort out, I'm sure he will, a 4 little problem that we had with the basket.
5 DR. SIESS: Now, as a procedural question, if 6 somebody now comes in with a dry storage installation, 7 wants to use either of the designs that you have already 8 approved, that doesn't need reviewing again?
9 MR. ROUSE: That's the intent of the reviewing 10 of the topical report, to expedite the specific site 11 license.
12 DR. SIESS: Someone could come in with another
() 13 design that you would not require there to be a topical 14 report? You could review it either way?
15 MR. ROUSE: That's correct.
16 DR. SIESS: In other words, the manufacturer l l
17 came in or designer came in and got the topical report 18 reviewed and then went out and sold it to the utility?
19 MR. ROUSE: That's correct. I might add we 20 actually have in house five or six other designs as topical 21 reports that we'are reviewing.
22 DR. SHEWMON: Could you tell me, is the cask the 23 same that is now being used stationary, the same licensed 24 for transportation in Germany? Or do they have the same 25 material in two different casks, one for transport and one m
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1 for stationary?
2 MR. ROUSE: John, would you answer that?
3 MR. ROBERTS: There are several nodular cast 4 iron cask designs, the so-called cast series, so far as I 5 know the caster 5/21 have not been certified for storage --
6 DR. SIESS: How about for transportation?
7 MR. ROBERTS: I don't believe the 5 has. The 8 caster 1-C, the 2s --
9 DR. SHEWMON: 5 is the one at Surry?
- 10. MR. ROBERTS: 5 is the one at Surry. That 11 really arises -- and I think I can explain this a little 12 later in the day -- it arose in the point of our licensing
() 13 review where, basically, production of the cask was being 14 allowed but they hadn't finally certified it in Germany.
15 DR. SIESS: Let me take time out on that for a 16 minute.
17 Where are you from? Let's identify everybody.
i 18 MR. STEYER: Keith Steyer, research.
19 MR. ROUSE: Lee Rouse, advanced fuel and spent 20 fuel, licensing branch, NMSS.
21 MR. ROBERTS: John Roberts, advanced fuel and 22 spent fuel, licensing branch, NMSS.
23 MR. STORZ: Frederick Sturz, advanced fuel and 24 spent fuel, licensing branch, NMSS.
25 MR. SAWYER: Carl Sawyer, division of safeguards.
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l MR. CLARK: Tom Clark, same.
2 MR. BERATAN: Leon Beratan, Office of Research.
3 MR. NILSON: Chuck Nilson, Office of Research.
4- DR. SIESS: I had a question and I can't 5 remember what it was because I interrupted myself.
6 Oh, yes. Who is it that keeps track of the 7 spent fuel storage capacity at the power plants? Every 8 monthly operating report has attached to it a form sheet.
9 Is that NMSS's job?
10 MR. ROUSE: No. That's our resources -- they 11 handle those inquiries at OL, it's an administration shop.
12 They put together what's called the gray book and that
() 13 includes that information.
14 DR. SIESS: I used to get the gray book. Does 15 that give you -- do you look at that and have any idea as 16 to what you might be getting in terms of the applications 17 from other plants?
18 MR. ROUSE: Yes, sir.
19 DR. SIESS: What's the status of that? How many 20 of those do you expect to see?
! 21 MR. ROUSE: That's an excellent point, Dr. Siess, f
l 22 because I was going to bring it up and I might as well 23 bring it up now. There is some sort of perception that i
j 24 sooner or later we are going to have dry storage or casks I 25 or some sort at every reactor. That really isn't the case.
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1 If one looks at the storage needs right now --
2 John and I have talked with Duke Power and they are 3 strongly considering dry storage at Oconee.
4 DR. SIESS: Just for Oconee?
5 MR. ROUSE: 'Ju s t for Oconee. Other than that 6 it's hard for us to point out anyone yet here in the '80s 7 that would need dry storage. As a matter of fact, there is 8 in a document --
9 DR. SIESS: You are basing that on DOE taking it 10 over by 19987 11 MR. ROUSE: Let me go on. Once you get into the 12 mid-90s, then you begin to see more of the plants, the
() 13 stations beginning to run out of what is now called maximum 14 rerack. What we find is the utilities are very innovative l
15 and had taken rerack, certainly a lot further than we would 16 have guessed a few years ago.
17 The two reracks that are now being approved by 18 NRR, where burn-up credit is taken under a certain type of 19 controls has helped. So each reactor that needs additional 20 storage of course goes to reracking first. And most 21 reactors, most reactors, by far, have taken .re of their 22 needs well into the '90s by t method.
23 There is one other method, of course, being 24 strongly considered by a few reactors right now and that is 25 rod consolidation in the pool. NRR presently has an D
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28861.0 15 BRT 1 application from Northeast Utilities for Millstone II that 2 would be the first that would permit, if they approve it --
3 reach-that decision -- storage of consolidated fuel in the 4 pool, 5 So, if you take those, the reracking, possibly 6 rod consolidation, I think until the mid-90s you don't see 7 a lot of stations needing the additional capacity provided 8 by dry storage, although there are a number of them 9 studying it.
10 DR. SIESS: I saw an application, I don't 11 remember it being Millstone, I was thinking Maine Yankee.
12 They had already reracked once and they were now proposing 13 a reracking with some consolidation.
14 MR. MERRILL: Was that LaSalle?
15 DR. SIESS: No. It wouldn't be LaSalle.
16 MR. ROUSE: Maine Yankee did, in fact, come in 17 for -- I'll use my terminology, with NRR for what I call a 18 hybrid type of consolidation. It was just taking --
19 DR. SIESS: Partial consolidation. Yes.
20 MR. ROUSE: But they had heavy -- it was heavily 21 contested up in Maine and they finally reached agreement 22 with the state to withdraw that except for a very limited, 23 I think just a few assemblies, sort of a demonstration 24 basis.
25 DR. SHEWMON: Was the state against, what, the O
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1 procedure? Or against accumulating fuel on-site?
2 MR. ROUSE: I'm not an expert, Dr. Shewmon, but 3 I have read a'little. I think it was a little of both.
4 DR. SIESS: There have been a lot of 5 interventions on reracking.
6 DR. SHEWMON: I'm surprised the state got into 7 it. I just wondered --
4 i 8 DR. SIESS: Have most of the operating plants 9 reracked at least'once?
10 MR. ROUSE: Yes. Essentially all operating 11 . reactors.
12 DR. SIESS: A few were shipping to Morris.
() 13 MR. ROUSE: Yes, Monticello and Cooper are 14- presently in fact shipping to Morris. That has to do with 15 one of the old contracts; yes.
- 16 DR. SIESS: Was tnere something I recall that 17 somebody was shipping fuel back from Morris?
18 MR. ROUSE: Yes. Point Beach took some fuel 19 back from Morris.- That was an economic decision.
20 DR. SIESS: They reracked and got enough 21 capacity. Was there fuel at West Valley?
22 MR. ROUSE: Yes. There was fuel at West Valley.
23 There's still some fuel at West Valley but --
! 24 DR. SIESS: That was shipped back?
25 MR. ROUSE: That was shipped back to che I
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I reactors, essentially.
2 DR. SIESS: You say most of the plants now 3 figure they can-go into the '90s. But, as I recall, 1998 4 is the date, the magic number for DOE to take them over.
5 Can many of them go to 1998?
6 MR. ROUSE: That's a little more uncertain, as
. 7 far as I'm concerned. It gets a little hazy out there in 8 the mid-90s.
9 There is one document that I have a copy of that 10 I would just like to refer you to or reference. It is put 11 out by DOE. Now, its data -- the document I'm talking 12 about is termed " Spent Fuel Storage Requirements." It is
() 13 DOE /RL-86-5. It was put out in October of '86.
It isn't quite as up to date They 14 annually put out this report.
15 as the most recent gray book but it does have information 16 in perhaps a little better form.
17 There are some tables in the back where you can 18 sort of look and you can see that picture out towards the 19 mid-90s. But, even they, I think, would indicate the 20 further you get out, a little more uncertain it becomes.
21' DR. SIESS: I have a faint recollection of a 22 NUREG, NUREG CR, that summarized the spent fuel storage 23 situation in the past few years. Is there anything -- or 24 am I thinking, maybe, of the gray book? If you don't 25 remember it probably doesn't exist.
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. 28861.0: 18 BRT 1 MR. ROUSE: We, in NMSS, had a contract for a 2 couple of years with Nuclear Assurance Corporation who did 3 some of that digging on data. That came out as a NUREG CR, 4 but I'm not sure we are talking about the same thing.
5 DR. SIESS: So you don't see -- wait a minute.
6 Why did Surry and Robinson go to dry storage? Had they 7 reracked?
8 MR. ROUSE: Yes. In the case of Surry, they had 9 reracked, I believe twice. Their particular situation, 10 they looked at rod consolidation-but from the structural 11 standpoint, apparently they determined that they couldn't 12 go any further with the rod consolidation or further i
'( ) 13 reracking. So they were one of the early ones who began to 14 look at dry storage.
j 15 They did reach -- enter a cooperative agreement 16 with the Department of Energy, under NWPA, where there was 17 some assistance from DOE on that.
18 In the case of Robinson, now, Robinson also 19 entered into a cooperative agreement with DOE for some 20 assistance on this dry storage project, and their dry 21 storage license is really a demonstration. It isn't --
22- DR. SIESS: That's the concrete one?
23 MR. ROUSE: Yes. It isn't a large scale. The
~
24 license only covers about eight modules and 56 assemblies.
- 25 DR. SIESS
- Those are fairly old plants but
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l there are others of the same vintage. They don't see the 2 need for dry storage' and these two did?
3 MR. ROUSE: John may help me here but Oconee is 4 one, certainly. Here you have two pools, they have 5 reracked, they reracked --
6 DR. SIESS: They only had two pools? 2 and 3?
7 MR. ROUSE: 3 has a separate pool. I think 1 8 and 2 share.
9 They've reracked twice and have determined they 10 can't go any further with rerack. They have considered rod 11 consolidation as well, but right now it appears to us that 12 they seem to be leaning toward dry storage.
13 DR. SIESS: What about some of the older plants
[ )_
14 like Dresden, Connecticut Yankee --
15 MR. ROUSE: Dresden seems to be in good shape --
16 and I refer to this book -- into the '90s.
17 Palisades is another one that, for example, 18 would show a near-term need in this document but, 19 apparently, now has a application for a reracking again 20 that will give them some extra capacity and is also very 21 strongly considering rod consolidation.
22 DR. MOELLER: When you do rod consolidation, 23 what do you do with the gap activity or the gases?
, 24 DR. SIESS: You don't change them. You don't do 25 a thing with the rods.
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El- DR. MOELLER: You don't do a thing -- ;
l
- j. 2 DR. SHEWMON: Rerod means taking the end l l
3 fittings off-and maybe the spiderwebs. So those go but the )
!~ 4 tube's cladding stays intact.
5 DR. SIESS: Just put them in a closer i- 6 configuration.
1 7 MR.-ROUSE: Fundamentally the theory ofsrod 8 consolidation it has been demonstrated,.if you take the 9 unpacked rods, and carefully -- how'you do this, you can i
10 get the rods from-two assemblies into a cannister that will 11 fit, then, the same space in the racks that an assembly did,
- i. 12 So theoretically you get a 2 for_l. You have to do i
] )' 13 something with the hardware, however.
14 DR. SIESS: From the standpoint of criticality 15 it is undermoderated when you consolidate it. From the 16 standpoint of heat generation, if it's old enough it's
- 17 really no problem. If you were trying to do it from the 18 beginning --
19 MR. ROUSE: Then you would have the problem.
f 20 DR. SHEWMON: When you say "cannister," do these
?
21 still have open ends so that water flows through them?
7-22 MR. ROUSE: Yes.
L 23 DR. MOELLER: And when you talk about rod 24 consolidation at the MRS, that also would not violate the i ~25 integrity of the individual rods?
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U, 1 MR. ROUSE: That's correct, Dr. Moeller.
2 DR. SIESS: And any leakers would be handled --
3 would be packaged somewhere?
4 MR. ROUSE: Yes. One of the things we are of 5 course looking at, at MRS, under the production scale rod 6 consolidation that they have under concept is the breakage 7 of rod. We know there will be a few rods that will.
8 DR. SIESS: MRS differs from the off-site dry 9 storage in that there's a lot of handling and fabrication 10 in air. I think the rod rerack -- the consolidation in the 11 spent fuel pools is all done underwater, isn't it?
12 MR. ROUSE: That's correct.
-(m)
~/
13 DR. SIESS: But MRS will have a hot cell to do 14 this. The storage isn't that much different but it's the 15 handling, processing that does make MRS different.
16 MR. ROUSE: The storage is very similar.
17 DR. SIESS: But as was pointed out at a previous 18 meeting.by Dave, if you don't have MRS as an interim 19 storage device some of that reprocessing will have to be 20 done at the depository and that's sort of a separate issue, i 21 I guess.
22 MR. ROUSE: There are some who would suggest 23 that perhaps that consolidation,.which seems to be 24 important for the repository, might be done at each reactor.
i
- 25 There are some who are a little skeptical of that.
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l DR. SHEWMON: Let me stay with that for a minute.
2 I don't know if we are going to get to this today but could a
3 you -- I would like to hear, physically, what's involved in 4 the consolidation. Do they have to pull on these things 5 and have some reliable tensile strength in them? To what 6 extent can they cut out and relieve that? How often do 7 they break a tube when they do it?
8 MR. ROUSE: Tom Clark, would you want to speak 9 up?
10 MR. CLARK: Well, we had a little place here for 11 a discussion of MRS after lunch. If you want we could go 12 through some of that --
13 DR. SIESS: We'll discuss it then. I think it
- (( )
14 would be better.
15 DR. MOELLER: And let me throw out a question to 16 consider. Why -- and I appreciate the clarification on 17 what re -- what rod consolidation means. But let's say in 18 repackaging the rods, let's say you broke one out of every 19 10. I know that's wrong but let's pick a number -- one out 20 of every 100. Why I was bringing it up, the point is EPA, 21 which you well know, has a limit on how much krypton you 22 can release, regardless of the dose.
23 MR. ROUSE: That's correct.
24 DR. MOELLER: I forget what their release is.
25 Is it 1 percent of the total? Or 10 percent? Or what?
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\) 1 MR. ROUSE: If one makes that calculation --
2 they of course put it'in terms of curies per 3 gigawatt-electric, but if one makes the calculation -- we 4 'did this'back in the reprocessing days -- one makes the 5 calculation and assumes all of the krypton would have been 6 released in the reprocessing plant. It meant that they had 7 to be assured of' recovering 90 percent.
8 DR. MOELLER: So you cannot then, theoretically, 9 have more than 10 percent of them broken and total 100 10- percent release?
11 MR. ROUSE: That's right.
12 DR. SIESS: No changes had to be made to Part 72
() 13 to accommodate this processing part of MRS?
No, sir, Dr. Siess. The reason that 14 MR. ROUSE:
15 I say that -- and I was going to mention it in my 16 introductory remarks when we began going through 72 -- Part 17 72 is developed in the late '70s, when it was, at least, 18 anticipated at that time that fuel storage would be, by DOE, 19 at large regionalized storage centers.
i
- 20. Even at that time they were considering 21 large-scale rod consolidation. It would have been wet.
22 That's a little different. But, really, we looked at the s.
23 rule and the criteria there for the effluent monitoring and 24 handling seemed to be there.
i 25 DR. SIESS: Those things were done after we took
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<g 1 that first look at it.
2 I guess so far we have been on the introduction 3 by the Chairman. Yes, Forrest?
4 DR. REMICK: I just want, looking ahead to the 5 day's presentation, I don't know if you have it planned but 6 if not I would appreciate some information -- if you can't 7 give it today perhaps you could send me something -- on two 8 aspects. One, what kind of criteria are you using on these 9 for criticality consideration? What K effective are you 10 using? .99 or what?
11 DR. SIESS: .95.
12 DR. REMICK: .95 you are using? And how do
()
p 13 these look compared to that under various conditions?
14 The other is, I would like to know what detailed 15 consideration you are giving for personnel. You are 16 talking about certification. I guess these are fuel 17 handlers. The question is: Do you expect these fuel 18 handlers to be also licensed? I'm not quite -- I'm not 19 that familiar with the certification of fuel handling 20 people but what kind of people do you foresee involved?
21 MR. ROUSE: Okay.
22 DR. REMICK: I read the words but it didn't have 23 complete meaning to me when I read those words.
24 DR. SIESS: There's an item on OA and training.
25 Would it come under that, appropriately?
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(\) 1 MR. ROUSE: Yes.
2 DR. SIESS: Dave?
3 DR. MOELLER: One more comment and then I'll 4 drop about losing gap activity. But if I were a lawyer, in 5 re'ading this I would then, perhaps, say to you that there 6 would have to be a paragraph in the revised 10 CFR 72 that 7 says: Whatever gap activity I lose in rod consolidation 8 must be subtracted from that which can be released if and 9 when these same fuel elements are later reprocessed.
10 That's EPA's problem, not yours.
11 MR. ROUSE: That's an excellent point.
12 DR. SIESS: They define the base.
() 13 DR. MOELLER: Right. They define the base.
We will be measuring or would 14 MR. ROUSE:
15 require the measurement at MRS. The experience would be 16 there but you are absolutely correct. It would all count 17 toward the total.
l 18 DR. MOELLER: Correct.
19 DR. SIESS: Okay. We'll go on to item II, 20 introduction to what's left of Part 72 and what's left of 21 the introduction to Part 72. Mr. Steyer?
l 22 MR. STEYER: I'm Keith Steyer, Research.
23 As you said, most of what I was going to say has 24 already been said. I do want to point out, though, that 25 during the last meeting on the rule in March, when we (1)
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1 talked to the Subcommittee -- we primarily covered the 2 proposed rule changes, the MRS facility and some NMSS 3 licensing experience.
4 Since that meeting we have put out the proposed 5 rules and have received 186 separate comment documents.
6 However, two-thirds of those are the same comment. They 7 all came frem Tennessee. They don't want the MRS in 8 Tennessee.
9 _Then we have also had some experience in NMSS in 10 licensing these things.
11 Since that time in March, Research was 12 reorganized so the project manager came to talk to you at es
() 13 that time, he was involved at that time -- Bill Pearson is 14 no longer on the project and Chuck Nelson is now the 15 project manager.
16 I believe that's all I need to add.
17 DR. SIESS: Let me raise a procedural question, 18 I guess, again. I'm not sure whether the ACRS is going to 19 review and comment on Part 72 or not. We have a memorandum 20 agreement with the EDO to review all proposed rule changes.
21 NMSS is aware of that.
22 MR. ROUSE: Yes.
23 DR. SIESS: But it has not been invoked in this 24 case.
25 The typical procedure is we see a proposed rule O
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' We then 1 at some stage, as early a stage as possible.
2 notify the office of what our schedule will be for 3 reviewing it. We might choose to review it before it goes 4 to public comment. We may prefer to wait until after it 5 goes to public comment and have the benefit of the public 6 comment. We may do it both. We are obliged to notify 7 somebody of that because that has to be factored into the 8 schedule. We don't move very fast.
9 We would get the proposed rule. We would get 10 all of the public comments. We would get a copy of the 11 Staff's response to the public comments. We'd get a copy 12 of the regulatory -- what do you call it, cost / benefit --
(} 13 MR. STEYER: Regulatory analysis.
14 DR. SIESS: All that, the same that goes to 15 CRGR --
16 MR. ROUSE: May I comment? I'm certainly aware 17 of the MOU. It was my understanding that the reason that 18 these proposed revisions to Part 72 didn't follow that 19 route, I recall the MOU that talks -- it has the terms, 20 something - "significant safety matters." I believe it 21 was determined that that these revisions to Part 72, that 22 may be arguable from your point of view but just going back 23 to when this revision started -- that they weren't 24 sufficiently significant from the safety standpoint, these 25 changes -- this being an existing rule, of course it didn't
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1 consider, perhaps, that the ACRS hadn't looked at the 2 initial rule. It also was not reviewed by CRGR for the 3 same reason.
4 DR. SIESS: That's not at all unreasonable, 5 including the fact that we hadn't reviewed the initial rule.
6 If we hadn't reviewed the initial rule it wouldn't make 7 much sense to ask us to look at the changes.
8 And as to whether even the initial rule is a 9 significant safety matter compared to something else might 10 be worthy of some discussion.
11 Until the Chairman asked us, rather formally, to 12 review everything having to do with the NWPA, we, obviously,
(,,) 13 had not reviewed either the rule or the license as issued 14 under it. .
15 I'm going, now, under the procedural assumption 16 that we will have to review the MRS and it would be 17- appropriate to review the rule.
18 I'll have to go see what the Subcommittee thinks, 19 what the full Committ;ee thinks as to whether they want to 20 write a letter approving or commenting on the proposed 21 changes since the rule is already established. But I think 22 your reasoning there is quite good.
23 Where do you stand right now? You have had your 24 public comments?
l 25 MR. STEYER: Yes. We are reviewing and C)'
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2 After the rewrite, in consultation amongst the Staff, the 3 next formal stage is to go out for division review. Then, 4 after division review the comments are resolved and it goes 5 .to office review. Once that's done it goes to the EDO. I 6 don't know -- in the past, as Lee said, it did not go to 7 CRGR. We basically made an argument that they finally 8 agreed with. So it went on up from EDO to the Commission 9 and was issued.
10 DR. SIESS: It doesn't seem to by a CRGR matter.
11 It's certainly not a backfit.
12 Will there be any substantive changes as a 13 result of the comments?
-( })
14 MR. STEYER: A lot of the comments I think are 15 going to be useful but I don't think so.
16 MR. ROUSE: Technically I don't believe so.
17 Procedurally there is a policy issue that has to do with 18 whether or not there is the possibility of a second hearing 19 on the MRS, just prior to receiving fuel after construction.
20 I will discuss that a little bit later. It is a policy 21 issue and we'll probably have to get some guidance from 22 upper management on that.
23 DR. SIESS: I happened, on some basis, to get 24 the comments that came from TVA. They didn't appear to be 25 much more than clarification-type things, which frequently O
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i 2
Can we then; proceed to essentially a 3 section-by-section look at Part 727 Okay.
4 We are in,'then, to item III, only 15 minutes 5 behind/which is good for us.
~
6 1 MR. ' ROUSE: As I introduced myself before, Lee
=}
7 Rouse. I want to lead this off. I don't plan to'take a
~F 8 lot of your time-because I'm'more anxious for you, and I'm 9 sureyouare,todetintomoreoftheharderpartof72,;/l 10 the technical details. But there are a few things I want 11 '
lto mention to begin with.
12 First, as I have already indicated, a little j ) 13 background on Part 72. It was developed in the late '70s.
14 There was a focus on pools, and the rule still reflects 15 that to some extent. However, the rule clearly, now, as it
. J 16 was-issued in 1980, the rule clearly applies to both wet 17 and dry storage modes at or away from the reactors.
18 We've also sort of indicated our actual I
19 licensing experience with Part 72 is somewhat limited. It-20 was-first applied to the GE Morris pool operation and then 21 this summer we finally issued the first two dry storage
'22 licenses under Part 72.
1 23 However., in addition to this, this actual .
24 licensing experience, we have accumulated a fair amount of i
25 experience in Part 72 in these looks at these topical O
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1 reports; a number of designs, a number of which are ongoing 2 reviews at the present time. And of course we gained some 3 experience in applying the technical criteria of Part 72 to 14 the MRS, as it was -- the conceptual design was developed 5- by DOE over the last two or three years.
6 We, very early in the game, advised DOE that we 7 felt that'the technical criteria of Part 72 would be 8 applicable to the MRS, and that is what they did then use 9 in connection with their design efforts.
10 Based on our experience today, we consider Part 11 72 a good, sound regulation. We haven't had a great deal 12 of difficulty. I suppose this comes from the fact the
- f~)
.v 13 handling and storage of spent fuel is based on established 4
14 Ltechnology and using these kind of requirements, the 15 handling and storage of spent fuel doesn't really present, k s 16 N from the technical standpoint -- relatively little risk to 17 public health or safety.
18 At the end of our last meeting, Dr. Siess, you 19 did indicate that you wanted to get a better idea of the 20 overall scope of 72 so we are going to try and walk through, 21 generally, section by section, with you today. We are 22 going to be using the current rule to do this. I think 23 each of you have a copy.
24 DR. SIESS: By " current" you mean with the 25 latest revisions? Prior --
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l l MR. ROUSE: Prior to the proposal that is out.
2 What we will do, though, as we go through the current rule, 3 we will try to indicate where the proposed revisions are 4 coming, where we think they are substantive.
5 As we have already indicated we don't think they 6 are significant from the technical standpoint but they do 7 change things in a couple of places.
8 DR. SIESS: Revisions as a result of public 9 comment. May '86?
10 MR. STEYER: No. It should be '80. May '86 is 11 the proposed --
12 DR. SIESS: Why don't we just take the most-(m) 13 recent?
14 MR. ROUSE: Well, we found it somewhat difficult.
15 Let me make one further comment along that line, for going 16 to use the current rule, because the numbering system 17 changed, and to jump back and forth it became a little 18 difficult for us.
19 I have one gentleman on the end of the table, 20 however, who has sort of an index that, if there is a 21 question: How did this section change in this proposed 22 rule that's being considered? He can lead us to that.
23 We all have copies of both, what I referred to 24 as the existing rule and the proposed rule.
25 DR. SIESS: A lot of the changes were discussed o)
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b-1 at our. meeting last February. I guess we need to have it 2 called to our attention but maybe we won't need to spend 3 too much time on it.
4 MR. ROUSE: All right. Thank you.
5 For my part, I'm going to talk a little bit 6 about the general provisions and procedural requirements in
~
7 Part 72. I don't want to take a lot of your time with that 8 because, as I say, I would rather get into the technical 9 details. But much of. subparts A, B, C, and D of Part 72 10 are common regulatory language that's in all of our NRC 11 licensing rules. However, there are technical requirements 12 spelled out here. I'll mention a few of those. But they
() 13 are really dealt with in more detail under general design 14 criteria, siting factors, et cetera, which you'll hear 15 about after I finish.
16 I have given you a handcut. I'm going to talk 17 from that and if you wish you can stop me if you want to go 18 to a particular rule, or not.
19 DR. SIESS: Go ahead.
20 MR. ROUSE: With respect to Section 72.1 and 21 72.2, purpose and scope, just a quick comment. The present 1
22 rule covers licenses for power reactor spent fuel. That's 23 a subtlety that is sometimes lost. It's only power reactor 24 fuel. That specification carries forward in the proposed 25 rule.
o)
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./m I,'^'I 1 DR. REMICK: Let me ask why is it limited to 2 power and not including nonpower, just in case?
3 MR. ROUSE: You know, I'm going to step out, and 4 John will probably correct me. When this rule was being 5 developed, the DOE, proposed DOE program for accepting fuel l
6 from the utilities, there was even some talk about foreign 7 fuel coming in and research fuel. -And we got a clear 8 signal: Don't get yourself involved in that. And there 9 wasn't any need for research reactor fuel in this country 10 for this type of rule because it was being handled by DOE 11 reprocessdrs -- that's the only explanation I have. It's 12 not a very good one.
[~)
V 13 MR. ROBERTS: The other thing is high enrichment 14 fuel came into play there, if you are not reprocessing it.
15 That sort of thing. That puts you into another area.
16 DR. REMICK: There is certainly low-enriched 17 nonpower reactor fuel that's not being processed. I just 18 wonder why it was excluded.
19 I can understand why originally in Part 7:2 the 20 independent spent fuel -- that's certainly going to apply 21 only to power reactors. But I was wondering in the rewrite 22 -- but you are saying specifically it was excluded from 23 consideration? It seems like it's just tying our hands.
24 I'm not saying there is a need but I'm not sure why it 25 should be excluded.
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G' 1 MR. ROUSE: I personally had an early 2 ccaversation with the Department of Energy staff with 3 respect to their charter, now, under NWPA and thinking 4 about MRS. They have no plans, you know, for receipt of 5 research test reactor fuel at the MRS. They haven't 6 designed for that --
7 DR. REMICK: Could that put that at WIPP? DOE?
8 MR. ROUSE: I don't know. They have signed 9 contracts now, as required by the NWPA, with those, say, 10 some test reactor -- they have signed contracts as with the 11 power reactors.
12 DR. REMICK: Has the Commission specifically n
13 considered this as a policy question, whether it's power
(\s) 14 reactors or all spent fuel?
15 MR. ROUSE: Not in this go-around.
16 DR. REMICK: I sometimes wonder, I see it on NRR 17 side. When you sit on the other side you get frustrated, 18 all reactor licensees -- and when you read 75 pages they 19 really mean all power licensees. I was wondering if it was 20 just once again people thinking about one problem and not 21 thinking beyond that? Or --
22 MR. ROUSE: Well, not I think -- perhaps to some 23 degree. Although we have considered it. There just 24 doesn't seem to be any need for the MRS, doesn't appear --
25 it is being handled in other fashions. DOE is taking test o
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r
-3 DR. SHEWMON: You know, there has been pressure 4 to get the research reactors, which now almost means 5 university reactors, I guess, but not DOE-owned, off of 6 this high-enrichment fuel. If they go to the 20 percent-7 enriched or whatever it is, will that-be less attractive 8 for reprocessing? Or is there part of the DOE contract to 9 sweeten this up that, indeed, they will take it back?
10 DR. REMICK: I don't know, Paul. I am not 11 involved. DOE is taking the fuel. They continue to do it.
12 I think some they reprocess with naval fuel. Some I think
() 13 they can't reprocess. That's the trigger fuel and it is 14 being stored somewhere. I don't know -- maybe Idaho. But 15 I don't think that necessarily changes it. Perhaps it 16 improves it so that they will not be using long-term ACU, 17 high-enriched uranium -- worrying about that. The 18 situation today is very much like what it was three or four 19 years ago. Although I think Congress did appropriate some 20 money to DOE to provide the money that the NRC said they
! 21 wanted assurance of before they would implement the LEU l
22 rule. Maybe in five or six years we'll see the impact of l 23 it.
l 24 DR. MOELLER: On that, and maybe you'll cover it
[
l 25 later, I noticed in the wording on the Surry dry storage, L.)
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I that it refers to initial enrichment of less or equal to 2 2.2 percent. What percent of the power reactor fuel is 2.2 3 percent or less?
4 MR. ROBERTS: Well, basically we are talking 5 start-up cores. It's the first year, year and a half, I 6 guess. In VEPCO's case at Surry they have over 100 7 assemblies.
8 DR. SHEWMON: Well, the regular fuel isn't lower 9 than that, is it?
10 MR. ROBERTS: No. There's a reason. I'll get 11 into it. It's involved in the analysis of this borated 12 steel basket.
e (s) 13 DR. SIESS: The limit, was that part of the 14 Surry license or part of 72?
15 DR. MOELLER: Surry.
16 MR. ROBERTS: That's part of the Surry license.
17 DR. SIESS: The other radioactive materials 18 would be fittings and so forth?
19 MR. ROBERTS: That's correct.
20 MR. ROUSE: The revision, I want to just quickly 21 say on the scope -- we all know that the proposed revision 22 now on Part 72 adds MRS and high-level waste terms.
23 There's a point that I wanted to mention that has come up.
24 It's a favorite of John Davis, my office director.
25 The scope, combined with the definition of MRS --
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. ,a 1 we tried to be rather careful in the writing, such that if 2 DOE should ever come up with a change in name for the MRS, 3 we can handle it.
4 Under " definitions," I'm not, certainly, going 5 .to take you through definitions. There are some peculiar 6 definitions in Part 72. Most of those will come up as Tom 7 talks about siting factors or John talks about general 8 design criteria. There's a couple, though, I want to 9 mention.
10 There is a definition of independent spent fuel 11 storage installation. That definition includes the 12 provision that, if it is at another nuclear site you can
() 13 share services and support facilities provided that such i 14 sharing of utilities and services that are -- doesn't 15 increase the probability of the consequences of an accident 16 or reduce the margin of safety for either facility.
17 The point of bringing that out right now is that 18 for the Surry and Robinson cases, there is clearly an 19 interaction between the Part 72 license and the OL.
20 We work very closely with the NRR people and the 21 project manager on that. There is a little bit of a gray 22 line as to when the cask that is loaded in the pool under 23 the operating license -- when it becomes Part 72. That 24 isn't as important -- that's just a procedural thing.
25 Since they are referencing a lot of their procedures, o)
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1 administrative procedures, their OL, it doesn't make that 2 much difference.
3 It is important, though, that they make this 4 evaluation to show that, let's say the movement of this 5 heavy cask somehow doesn't impinge upon reactor safety and 6 botn Surry and Robinson made that type analysis.
7 DR. SIESS: Is this cask significantly different 8 in shape or mass from the shipping casks for which spent 9 fuel pools have been analyzed for drops.
10 MR. ROUSE: It's essentially equivalent to a 11 rail shipping cask.
12 DR. SIESS: So if it was different they had the x
mj 1 13 information.
f 14 MR. ROUSE: Correct.
i 15 DR. REMICK: Incidentally people with pool type 16 research reactors were. faced with that, when you produce 17 something when is it under the facility license and when 18 does it come under the by-product material license.
19 Generally when it comes out of the pool it switches.
20 MR. ROUSE: Up through the tube.
21 One other definition I just wanted to focus on, 22 there is a definition of high-level waste. It is the 23 conventional definition of reprocessing. That's what it 24 means, old extraction cycle waste.
25 The reason I want to mention it is because right i
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G' 1 now in front of the Commission is a proposed advance notice 2 of proposed rulemaking that would redefine high-level waste.
3 That is permitted under the NWPA that gave NRC the 4 authority to change the definition of high-level waste, if 5 it saw fit.
6 There is, of course, right now as we all know, 7 there's a gap between what is termed low-level waste and.
8 high-level waste. The reason I mention it here, I'm not 9 familiar in depth with it, I know generally the concept t
10 they are going to throw out for comment as advanced notice --
11 that rule could come back and effect us to some extent in 12 Part 72. However, I think we even said the last time we
() 13 mentioned this was we were talking to you -- we are quite 14 confident that no matter -- there's some slight change in 15 the definition of high-level waste that would permit some 16 other type of high-level waste to come into the MRS, we can 17 handle it under the criteria. I 18 DR. SIESS: You have a definition of an ISFSI j 19 EPZ. If it's at a reactor site, does that have any 20 significance?
21 MR. ROUSE: Yes. Because in the proposed ruling 22 we are dropping that definition and I'll cover that a 23 little bit better detail when we get to purchase planning.
24 DR. SIESS: It seems to me if it's a separate 25 installation it has to have its EPZ. But if it's at the O
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I separate.
1 2 MR. ROUSE: That's it. That's it to an extent.
3 In actual fact let me cover right.now, 72.19, I believe, 4 covers emergency planning. That is one more substantive 5 change that is being made now in the proposed revision.
6 Previously the rule referenced section four of 7 Appendix E of Part 50. That, with our experience, our 8 accident analyses for spent fuel storage,' aged' fuel, 9 combined with the desire to get away from referencing "
,- 10 another regulation, we have now put all of the emergency
, 11 planning requirements, incorporated them directly into Part s
12 72.
(} 13 They don't refer to an EPZ. As to the reactor.
14 The reason for that is all of our analyses have shown that 15 frankly it's very, very -- we have not come up with an 16 analysis that would get enough off site to require off-site i- 17 planning. Nevertheless, the Commission came back to us and i 18 asked us to put in the proposed rule, some limited off site i
19 coordination. And we have done that. But it is very 20 limited.
21 DR. MOELLER: For the dry storage at a nuclear 4 22 power plant, I would presume the emergency plan would be i 23 integrated with it.
! 24 MR. ROUSE: Yes. And there's an explicit 7
25 statement now in the proposed rule that says at a reactor ,
!CE) .
I i
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I site emergency plan for the reactor shall be deemed to meet 2 these requirements.
3 DR. MOELLER: On your definition, just a nit, 4 but were you doing high-level waste, the one above that is 5 a definition of a flood plan?
6 MR. STEYER: Plane.
7 DR. MOELLER: My copy says the " flood plan." I 8 just wondered.
9 DR. SIESS: Which copy are you looking at?
10 DR. MOELLER: I'm looking at the proposed rule.
11 DR. SIESS: He's going through the existing rule.
12 DR. MOELLER: I know, but he's doing'a little of L/ )
13 both.
14 MR. STEYER: Must have missed that.
15 DR. SHEWMON: What would the trip point be for 16 activating the emergency plan for the dry storage? What 17 sort of things do you envision? You state it in terms of 18 when there's a certain release rate or what?
19 DR. SIESS: Let's wait until we get to that item.
20 DR. SHEWMON: Okay.
21 DR. SIESS: Can I ask a general question. You 22 have used the existing Part 72 to license three 23 applications. Are any of the proposed changes, based on 24 your personal -- have you found things that you wanted to 25 change aa a result of using it three times?
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l 1 MR. ROUSE: There is one very specific thing i
f 2 that John is going to touch on. It has to do with 3 integrity of the cladding, basically.
4 DR. SIESS: Okay.
5 MR. ROUSE: The emergency planning was something 6 which is kind of nice, to get .away from Part 50 because 7 Appendix E is a little --
8 DR. REMICK: Amen. I hope you stay away from 9 Appendix R, also.
10 MR. ROUSE: And QA requirements. It gives us a 11 little flexibility by getting away from Appendix B and 12 actually incorporated the OA criteria right in Part 72.
(~T 13 Those are about the only things I can think of.
%)
14 DR. REMICK: Going back to your definition of 15 high-level waste, has the Commission determined any 16 low-level waste is high-level-waste that should be isolated?
17 MR. ROUSE: Not yet, but that's part of this 18 very explicitly, Dr. Remick, part of this.
19 DR. REMICK: But I -- there's nothing you are 20 aware of that they have defined in that category; is that 21 correct? Low level --
22 DR. SIESS: High-level waste is in the revision 23 but not in the original?
24 DR. REMICK: Right.
25 MR. ROUSE: Okay. Subpart B of the current rule, o
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U 1 and even the revised rule, deals with the license 2 application and its content. I don't intend to say too 3 much about that because most of that will come out as John 4 and Tom talk later. However, on Section 72.14, does 5 specify the technical information that is included in the 6 safety analysis report. If one looks at Section 72.14, it 7 is quite-comprehensive. There's quite a list of things 8 there. I don't intend to run down them all with you. But --
i 9 DR. SIESS: Excuse me. I have a reg guide, 3.5.
10 That covers the same thing, does it?
11 MR. ROUSE: Which one?
12 DR. SIESS: Proposed revision to Regulatory
() 13 Guide 3.5, guidance on preparing the license application to 14 store spent fuel and high-level radioactive waste?
+
15 MR. ROUSE: Do you want to explain that one?
16 MR. ROBERTS: That's 3.50, isn't it?
17 DR. SIESS: That's right. I was ignoring the --
18 MR. ROBERTS: That's just an overview guide to a 19 license applicant, telling them what they need in terms 20 of --
21 DR. SIESS: But it's an expansion on 72.147 22 MR. ROBERTS: 72.15.
23 DR. SIESS: 72.15.
24 MR. ROBERTS: It is in conjunction with other
< 25 guides like, for example, 3.48 which specifies the standard O
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s 1 format and content for the SAR, and so forth. But that, 2 really, gets into a listing of what you need to include in 3 your application with respect to your SAR, your environment, 4 et cetera. And it goes through and basically lists them 5 out for.the Applicant.
6 If you look over in 72.21 there's a list of 7 required licensing documents. Basically what I think 3.50 8 does is explain in more detail how, to the licensee, how to 9 go about getting everything required for the license.
10 DR. SIESS: -And then 3.48 is the format?
11 MR. ROBERTS: Yes. Standard format and content.
12 SAR.
(} 13 DR. REMICK: Incidentally, why is it dropped in I thought it was a good idea to tell 14 the proposed version?
15 people how many copies of reports they have to submit.
16 That's tough to find --
17 DR. SIESS: That ought to be in the reg guide 18 rather than the rule.
19 DR. REMICK: That's true, but the reg guide is 20 usually out of date and hard to find and hard to remember.
21 I notice it's not in the proposed rule.
- 22 MR. ROUSE
- I don't know.
23 One point I want to make about the safety 24 analysis report, though. We have indicated before Part 72 25 is a material license. It is a single-stage licensino O
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1 process and, thus, the SAR that you receive has to be, 2 es:sentially, final design level of detail. This is before 3 construction is permitted. Because the SAR, then, has to 4 cover or support the design and-the construction as well as 5 operation.
, 6 The SAR content for our dry cask, we found, as 7 required or specified, there are some things you don't need 8 for dry cask. You don't need to have the applicant 9 describe, as the rule would require, effluent controls.
10 Because the cask is sealed. You know, if you have an 11 accident that's another thing, but normally you have no 12 effluent. So we have actually had to explicitly exclude i
(~T 13 the licensing for some requirements.
A-)
14 on the other hand, it is sufficiently 15 comprehensive with all these requirements to cover the type 16 of facility like MRS, where, you know, it's all the 17 handling and everything.
18 DR. SIESS: Is the one-step review in Part 72 19 unique?
l 20 MR. ROUSE: No. That's really true for all l 21 material licensing.
22 DR. SIESS: Do you have other material licenses 23 that involve structures, systems and components?
1 24 MR. ROUSE: Plutonium plants would have been.
25 DR. REMICK: Cobalt 60 facilities?
o u
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(\) 1 MR. ROUSE: Yes.
2 DR. SIESS: So that gives ample precedent and 3 experience with that?
4 MR. ROUSE: Yes. Right. We felt when we looked 5 at MRS, now, although this is a fairly large facility it's 6 still the kind of technology we looked at before. We 7 didn't feel there was any reason the DOE couldn't come in 8 with final design.
9 DR. SIESS: Now, on a SAR, do you operate the 10 same way NRR does: an iterative process of questions and 11 answers and updating the SARs, until you get one that's in 12 satisfactory shape?
() 11 MR. ROUSE: Yes. Yes.
14 DR. SIESS: And 72.21 is omitted from the 15 revised and you don't know why?
16 MR. ROUSE: Oh, that's the listing. I 17 personally can't explain it. I don't recall why that was.
18 DR. SIESS: We could get all the numbers 19 straight --
20 DR. REMICK: I agree. It should be in the 21 regulatory guide but it's awfully nice to have it spelled 22 out in the regulations. I bet there's one person in 1000 23 who knows where to find that type of information in the reg 24 guide if it exists, and it's outdated if it does. I think 25 it's 10 in the reg guides, Part 10.
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U 1 DR. SIESS: There's been a pattern of trying to 2 get that kind of detail out of regulations. If somebody 3 decides'they need 49 copies instead of 48, you don't have 4 to have a rule change.
5 DR. REMICK: The other thing is people writing 6 the rule probably have a better idea than the people who 7 eventually write the reg guide and try to combine all kinds 8 of information.
9 DR. SIESS: It's supposed to be the same people.
10 DR. REMICK: When you are sitting out there 11 trying to comply it's tough knowing what the requirements 12 are.
(( ) 13 DR. SIESS: It's an interesting point because 14 they are moving in that direction. Appendix A, the seismic 15 effects -- am I right, Leon? -- it's going to be much more 16 general --
17 MR. BERATAN: If it ever gets revised.
18 DR. SIESS: Well, the legendary seismic appendix 19 is going to be much more general and then have a reg guide 20 to spell out the details and we have done that in a number 21 of other areas. There's the new Appendix B on leak rate 22 testing is going the same route. There, of course, they 23 could cite industry standards in the reg guides.
24 DR. REMICK: In principle it's very good. As a 25 current situation it's tough to find the number of reports O
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1 you have to have.
2 MR. BERATAN: The lawyers like to have all this 3 prescriptive material in the regulation. One of the 4 arguments we get is that it's easier to regulate that way 5 than to put it in the regulatory guide. .We have an 6 argument going back and forth whether to take it out or 7 leave it. <
8 DR. SIESS: I won't express publicly my opinion 9 on that. '
10 MR. ROUSE: One further point I wanted to make 11 on emergency plan. We did talk about that a little. I 12 mentioned to you the Commission did come -- this is with
() 13 14 respect to MRS, as opposed to the dry storage reactor --
came back to us and asked us to put in some limited-15 off-site -- limited emergency planning for off-site 16 response. That was handled -- it is fairly limited -- the l
17 key oature of it requires the Applicant, such as DOE and 18 MRS, to go out to the local agencies, give them 60 days to 19 comment on their proposed emergency response, and then the 20 Applicant would have to provide us with those comments so 21 we would see what the local agencies thought about the 22 planning.
23 I want to add one other point. Most recently I 24 think the ACRS was involved at one time. There is a 25 proposed emergency preparedness rula for fuel cycle and n
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1 other material licensee-type facilities, which covers in 2 its scope these kind of Part 72 licenses. That proposed 3 rule was sent back very recently by the Commission to the 4 Staff for some directions to do something else and I'm 5 sorry I can't tell you what "something else" is. But that 6 rule might, again, affect Part 72 here, depending on what 7 the Commission has asked for. I'm just not familiar with 8 it. But we will track that.
l 9 DR. SIESS: Let me go back to 72.1 for a minute.
j 10 Will that information be supplied in some document? That's 11 the list of documents, and how many copies and how many
(
12 signed originals?
13 MR. ROUSE: I think it is. It is covered in the 14 text to some extent. Yes, it's covered in the text in 15 general but Dr. Remick has a point. Someplace it says how 16 many copies of your application you shall send in to us, 17 how many copies of the environmental report and maybe of 18 the SAR. But it doesn't break it out exactly like this.
19 DR. SIESS: But it will still be in the rule i
20 somewhere?
21 MR. ROUSE: Yes.
22 DR. SIESS: Emergency plan, you have a complete 23 statement without a reference; is that right?
24 MR. ROUSE: That is correct. It's section 72.19, 25 Dr. Moeller, of the proposed rule.
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l DR. REMICK: It seems rational.
2 DR. MOELLER: Yes. I had gone over that.
3 DR. SIESS: It's now self-contained.
4 DR. REMICK: In fact, that's what I thought was 5 one of the advantages of the original 72 was to have things 6 self-contained was a real advantage rather than dig these 7 things out of Part 50 and wonder if they apply or what.
8 MR. ROUSE: What happens, as you know, 9 Dr. Remick, is they invented Appendix E, and it got a 10 little more complex than when the first reference was made.
11 Now, the lawyers will tell you that, depending on when your 12 rule references, legal -- but nobody remembers that.
() 13 DR. SIESS: Okay.
14 MR. ROUSE: I'm going to just quickly skip 15 through a few other points.
16 Section 72.31 is the issuance of the license.
17 That's basically the findings. But there is a point there
, 18 that's a little different for the materials license of this 19 type than you may be familiar with -- with Part 50.
20 72.31(b) has a statement in it that basically 21 says: The grounds for denial of the license may be start 22 of construction before we have completed -- the NRC has 23 completed its environmental review.
! 24 That's subtle words but the lawyers just will i
25 not let us talk about prohibition of construction with a 4
O I
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28861.0 52 BRT l_ materials license. It stems from the Atomic Energy Act.
2 They have always said a construction permit was called out 3 for a production utilization facility. If they wanted the 4 NRC to put a construction permit on anything else, by God, 5 if they did, they would have said so. So we get around it 6 that way.
7 The language looks a little weak but over time, 8 that appears in Part 70, Part 30, Part 40 -- we have found 9 that gives us a lot of leverage. We have never had any 10 difficulty with constructing before we complete the {
11 environmental portion of the review.
12 DR. SIESS: So the change you have made, then, 13 is in --
14 MR. ROUSE: That is really no change whatsoever.
15 That was in the existing rule.
16 DR. SIESS: The lawyers understand it?
17 MR. ROUSE: Right.
18 DR. SIESS: Okay.
19 DR. REMICK: I guess I didn't completely follow 20 what you were saying. You are saying that grounds for 21 denial would be if they did start construction before 22 approval?
23 MR. ROUSE: It may be grounds. It's a handle, a 24 lever. No one has ever pushed it to court, Dr. Remick.
25 In the case of Surry, for example, VEPCO wanted O
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l to go ahead and get the pad built for the -- to sit the 2 cask on. They came in to us and asked us. This was before 3 we had completed the licensing process. The Staff then, 4 with the Commission's negative consent, we informed them, 5 did tell them they could go ahead. But they did see fit to 6 come in and ask us.
7 DR. REMICK: To be partially facetious here, 8 suppose you were finally located at Clinch River where 9 there had been some ground breaking and so forth, would 10 that entitle people to claim that that should be 11 implemented?
12 MR. ROBERTS: That's its natural state. ,
13 DR. SIESS: Natural state, as found state.
s 14 (Laughing.)
15 MR. ROUSE: On duration of a license under 16 renewal, the MRS was a change after 40 years. We mentioned 17 we are getting some comment on that. It stems from the
. 18 fact that DOE in its environmental assessment with its 19 proposal, only talked about the MRS over a period of 27 20 years, I think it was. It was an odd number. That number 21 coincided with, at receipt and handling rates at the 22 depository, how long MRS might be needed before you got the 23 70,000 tons at the repository.
24 We think 40 years is reasonable.
25 DR. REMICK: Has any consideration been given to O
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1 changing ISFSI to 40 years instead of 20 years at the same 2 time?
3 MR. ROUSE: Not really, Dr. Remick, because that 4 kind of sits fairly close to the expiration dates of some 5 OLs. I think with the waste confidence proceeding we issue 6 a Part 72 for a reactor like Surry, we check that OL.
7 I don't even think we could issue a 20-year 8 license if the license expired before that because of the 9 waste proceeding and the rules that came out of it.
10 DR. SIESS: The OL can be extended.
11 MR. ROUSE: Yes. And so can Part 72 be extended.
12 But just the way the rule was written for Part 50 and 51 --
(es) 13 51 refers to 72 as well as 50.
14 DR. SHEWMON: Does your license, say at Surry 15 require that Surry have an operating license active on the 16 site before they -- this is valid? The license is valid?
17 MR. ROUSE: No. Well -- just about. Because 18 they do reference portions of their operating license. So 19 I think in a way it does.
20 MR. ROBERTS: You could not operate under your 21 Part 72 license if you didn't have this sharing and 22 services and so forth on the Part 50 license.
. 23 MR. ROUSE: You are speaking practically. He
- 24 was talking about a requirement.
25 MR. ROBERTS: Well, you would basically be in l (^h t)
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2 DR. REMICK: But it is possible that you would 3 terminate the reactor license and modify the Part 72 4 license. I guess I don't see why 20 years should be tied 5 to the fact that the OL might be terminated at the 40-year 6 period?
7 MR. ROBERTS: You have to have the capability to 8 decommission under Part 72. And, effectively, right now, 9 with no off-site transportation directly, what you are 10 saying is that you have to be able to unload either the 11 concrete modules or the storage cask at the reactor pool, 12 which means --
() 13 MR. ROUSE: Dr. Remick, you and John are much 14 more expert in that waste confidence proceeding than I.
15 DR. REMICK: Don't remind me.
4 16 MR. ROUSE: I thought that the rules that came 17 out would have made it --
i 18 MR. ROBERTS: You do have to give advance for
, 19 identification to plants to get rid of that fuel and that's 20 why I say, practically speaking --
21 DR. REMICK: But isn't it possible one of the 22 ways to get rid of the fuel if you had an independent spent 23 fuel storage installation is to operate that as the storage 24 facility, terminate the reactor license?
'l 25 MR. ROBERTS: Oh, yes.
- (Z)
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u y1 1 DR. .REMICKr I guess'I don't see that one has. to -
2 be necessarily tied yto the other. I don't see the
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3 restriction. .-
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1 4 MR. ROBil TS:fI understand what you are saying 5 and it is the things we discussed back in the waste ,
6- confidence proceeding. You could license part of'the
~
w > ,, s 7 reactor under Part 72, basically the fuel handling area or 8 something like that. Or if it, if the ISFSI had its own
, 9 handling, you could do it that way.'
10 DR.'REMICK:- Was anything in the 20 years tied 11 to waste confidence? The Commission said it had confidence 12 up to that tiene -- I forget -- ,
13 MR. ROUSE: No. As I recall they had. confidence 14 up to 2007, 2009.
15 DR. 'SIESS: To extend the license they must 16 apply two years pr'ior to the expiration of,the existing 17 license.
18 It seem.s to me.for an operating license for a w
19 plant the advanced period is much shorter than two years.
20 I think it simply., stated it's t'imely, isn't 'it?
21 MR.-ROUSE: Well,f i t's actually 30 days. And
, . ~ , ,
l 22 that two years is in Part 72 at the explicit request ,of
( 23 then-commissioner Bradford..
24 DR. SIESS: The Administrative Trocadures Act, t
25 which I think that reflects -- I readIhiscomewhere'the O -
1 l
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(>} 1 other> day -- simply says " timely." And you define " timely."
2 ' - MR. ROUSE: Part 2 actually says 30 days, and 3 Parts 30, 40 and 70 say 30 days. If you get it in 30 days 4 ahead of time it shall be considered timely. And yet Part y
5 72 says two years.
6 DR. SIESS: You haven't considered changing that
'7 now to be consistent?
8 MR. ROUSE: No. I don't think we did.
9 DR.'SIESS: I don't think it's that important.
\
10 MR. ROUSE: It is sort of an anomaly in the regs
, ' ' 11 ' '
" though. >
t.
'7 12 DR. SIESS: If you postulate the thing you were
( 13 talking' about, the operating license is going to be expired,
,- .c' "M-14 they are going to dhcommission the application for an
.s A, 15 '
' extension might be a fairly complex thing.
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s MR. ROUSE: That's correct.
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- 3) 17 DR. MOELLER: Well, one plant recently slipped
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18 ' up . ,
20 r DR. SIESS: On the CP. But where it is obvious 21 in the reactor business is the full-time license; the old
'N 22 provisio'nal operating license and the full term. As long s 23 as you applied for the full term you could operate forever 4 '
\
24 until NRC acted on it.
25 I guess we had several plants that had been O
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1 running several years under the provisional operating 2 license. They simply took it to apply and that was it.
3 MR. ROUSE: I might mention'along with that the 4 rulemaking that came,out of the waste confidence proceeding, 5 explicitly Part 51, I think, tells the' reactor that five 6 years before the expiration of your OL, you shall come in 7 with a plan to the Commission on what you.are going to do 8 with your fuel. s 9 DR. SIESS: I just find it strange that people 10 seem to be more concerned about the spent. fuel than they do 11 about the operating plants.
MR. ROUSE: I'm not going to say anything about '
12
() 13 licensing tech specs because John is going to cover that 14 later and I think answer your questions.
15 Public hearings: I did mention there is a 16 policy decision to be made with respect to MRS. The 17 present rule requires noticing and an opportunity for 18 hearing upon receipt of the application.
19 DR. SIESS: That's not something the ACRS is 20 usually concerned with. We'll leave that up to you.
21 MR. ROUSE: I think you might be interested in 22 one point about this policy decision because -- perhaps not, 23 and you stop me.
24 Part of this question on whether or not the 25 Commission considers a second hearing just after the o
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28861.0 59 BRT v 1 license is issued but before the MRS would receive spent 2 fuel after it is constructed, brought up the question, the 3 lawyers mentioned, there is no requirement in Part 72 for a 4 formal finding before fuel is received that the facility 5 has been constructed in accordance with the application.
6 DR. SIESS: There's no provision for that?
7 MR. ROUSE: No formal provision. It is the 8 Staff's position, and we feel rather strongly about that, 9 that the system of inspection and enforcement, combined 10 with a requirement to update the SAR every six months 11 during construction period and at least 90 days before 12 start, provides us with a system, and the type of licensing
() 13 we've done would do --.there would be check points, hold 14 points, self-fulfilling conditions, preop testing, et 15 cetera, that we don't need that formal finding. That's the 16 Staff's position.
17 Our position, and the lawyers say, if you go by 18 license condition or by the rule, there must be a formal 19 finding of completion of construction. That in itself 20 triggers opportunity for the second hearing.
21 DR. SIESS: That sounds like it has implication 22 for one-step licensing for power plants, too.
23 MR. ROUSE: They covered it in the proposed 24 legislation.
25 DR. REMICK: You do plan, Staff plans to have o
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28861.0 60 i BRT l es' U 1 hold points or perhaps readiness review or something like 2 that?
3 MR. ROUSE: Yes. That's correct. And that )
l 4 would be built right into the license conditions, tech-5 specs.
6 DR. REMICK: I guess anybody would have a right
)
l 7 to request a hearing anyhow if something came up that had '
l 8 not been considered.
1 9 MR. ROUSE: That's correct. Keep in mind also 10 that you really have a license out there. It's not a 11 construction permit, it's a license. There's a 2206 12 procedure available, too. Enough of that.
() 13 MR. ROUSE: Just quickly, 72.35 remains unchanged 14 but that's the equivalent in Part 72 of 50.59.
15 DR. SIESS: Yes.
16 MR. ROUSE: SAR updating I mentioned, there's no 17 change, six months during construction; 90 days before the 18 facility --
u.
i 19 DR. SIESS: You skipped backfitting.
20 MR. ROUSE: Oh, backfitting. Yes.
21 We have an old definition of backfitting that 22 used to be somewhat equivalent to the old definition of 23 backfitting in Part 50. We were asked by the Commission to 24 consider whether or not there was any urgent need to make a 25 change now to be more consistent with the current Part 50 0
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l backfitting rule. We will probably -- probably do that.
2 The only thing I wanted to mention about 72.51, 3 which is material balance inventory kinds of things, that 4 if there's any question on that I'd defer it until Carl 5 sawyer talks about the physical security plant. That's the 6 only accountability requirements'that appear in Part 72. ,
7 DR. SIESS: Thank you.
8 Let's take a 10-minute break.
9 (Recess.)
10 DR. SIESS: We are down to subpart E, siting 11 evaluation. Mr. Beratan is going to explain the siting for 12 me?
13 MR. BERATAN: I'll try.
(( )
14 MR. CLARK: I'm Tom Clark to talk about siting 15 evaluation factors. I think the reason I'm discussing this 16 is because of my experience in the past with the number.of 17 things we have looked at, with earthquakes and tornadoes, 18 et cetera.
19 I think if you look at the handout I have r
20 provided --
l l 21 DR. SIESS: Just a second.
22 MR. CLARK: As was discussed earlier the l 23 original intent was to provide a rule for several 24 f acilities which DOE might have to restore spent fuel. I 25 think at that time people wanted to recognize that, unlike O
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p 1 a reactor, an independent spent fuel storage installation 2 could be sited at a lot of different sitings. It didn't 3 need to have a water supply and so forth that a reactor 4 might need to have, and therefore, could avoid, perhaps, 5 certain features that a reactor would have to look at.
6 So that criterion was developed that way and, if 7 you look at the criteria, they are fairly general. That is 8 some more leeway --
9 DR. SIESS: This is 72.66 now?
10 MR. CLARK: I'm using 72.61. In looking at, for 11 instance -- before we mentioned just briefly, Reg Guide 3.48, 12 which has to do with the standard format and content of an 13 application. If you look at the section having to do with
.(v1 14 site evaluation factors, you can see that it is fairly 15 generally written, allowing people to sort of match what 16 they think the site requires with their -- where they are 17 going to store.
18 The intent is to look at the possible impact of 19 surrounding features on the facility and, conversely, look 20 at the impact of the facility on surrounding features.
21 This, I would claim, is no different than reactors except 22 that it's expected that probably the impact would be a lot 23 less, and that should be accounted for.
24 As a practical matter we haven't had to use this 25 criteria at all. In fact it appears that we may not ever (2)
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I 2 For Morris, the first plant that was licensed, 3 it was already accepted by Part 72 itself and was on a site 4 that was actually a reactor-reprocessing plant combination 5 and had been evaluated anyway.
6 Part 2 that we looked at for ISFSI, it looks
~
7 like'quite a number will be on reactor sites. It has 8 already been licensed for a reactor that has been 9 thoroughly investigated.
10 For MRS, currently, we are looking at 11 previously investigated reactor sites. So we don't see any 12 areas right now where we are going to be tested on this (qj 13 criteria, to have to do this type of evaluation. And 14 that's important because we can't claim that we have staff 15 experience on how to do this, other than reactor experience.
16 And it looks to me as though what you have is sort of a 17 fallback position to reactor criteria.
18 If you look at the first two sections, 72.61, it 19 does permit that broader review; and 72.62, 63, 64, 65 all 20 have to do with this idea of investigating the region 21 around the site, far enough away so that you know that 22 anything that would have an impact on the site would be 23 considered.
24 So, it would be similar to a reactor although 25 one might decide, for instance, that certain kinds of -
s U
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1 impact that might impact on the reactor is so far away it 2 really couldn't impact on ISFSI or MRS.
3 Conversely, the impact of the ISFSI or MRS on 4 the region would be carried out as far as one could 5 determine that it had an. impact.
6 For instance, one might not wish to go out to 7 the 50-mile radius for impacts if, by analysis you can see 8 there's really very little impact beyond 10 miles or 15 9 miles.
10 So that's the general idea of the siting 11 evaluation factors.
12 There have been some questions raised, in
(') 13 particular about the geological and seismological 14 characteristics. Fortunately we have Leon Beratan who I 15 think might have been involved to some extent when this was 16 prepared and I think he's ready to go through this a little 17 on the differences and so forth.
18 MR. BERATAN: There's really two sets of 19 criteria.
20 DR. SIESS: Only two? I've got four.
21 MR. BERATAN: Well, okay.
22 DR. SIESS: I'm listening.
23 MR. BERATAN: So far as anything west of the 104 24 degree west longitude, which is west of the Rocky Mountain 25 front -- and that's mostly on the West Coast -- we use ra ACE-FEDERAL REPORTERS, INC.
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28861.0 65 BRT N.] 1 Appendix A criteria. That's a given.
2 DR. SIESS: That's fine.
3 MR. BERATAN: Now, east of the 104 line we have 4 -- well, we've broken it down into screening criteria and 5 design criteria.
6 When we get into areas outside of New Madrid, 7 Charleston and Attica where you have low seismic activity, 8 for screening purposes only if you do a rather substantial 9 literature review and a cursory foundation investigation of 10 an area and if the vibratory ground motion at the site is 11 not in excess of a response spectra anchored at .2 g, that 12 site is deemed to be acceptable.
() 13 DR. SIESS: That is A-1?
14 MR. BERATAN: Right. Correct.
15 DR. SIESS: To get that .2 g, you've got to do 16 what Appendix A reveals?
17 MR. BERATAN: No.
18 DR. SIESS: How do you arrive at the number 19 without the Appendix A review? You are at a new site now.
20 MR. BERATAN: Okay, and it's in a low seismic 21 area.
22 DR. SIESS: Well, it's east of the Rockies.
23 MR. BERATAN: And it's outside of seismically 24 active areas like Charleston, New Madrid, et cetera -- so 25 you get into an area of low seismic activity. You look,
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1 you do a literature review of the area and then you do some 2 foundation investigation and decide that, if it's -- for 3 instance if it were a soil site you look at it for 4 liquefaction potential, sliding potential --
5 DR. SIESS: Tell me what you don't do that 6 Appendix A requires? So far everything you are saying is 7 in Appendix A.
8 MR. BERATAN: But I don't think you need to do 9 it in the detail -- you don't need to go out and look at 10 the closest fault systen and find out what the attenuation 11 is into the site and that sort of thing.
12 DR. SIESS: We didn't do that for other sites.
MR. BERATAN:
t() 13 You do it for reactor sites.
14 DR. SIESS: Some of them.
15 Suppose you do that limited investigation and 16 you come out with .22 g?
17 MR. BERATAN: Then you would reject the site.
18 DR. SIESS: All right. But now, isn't there 4
19 another requirement, another paragraph here that I could go 20 to?
21 MR. BERATAN: Yes.
22 DR. SIESS: And accept the site?
23 MR. BERATAN: You could accept the site if you 24 did a full-blown Appendix A evaluation.
25 DR. SIESS: Preliminary gives me .22. Now you
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.U l~ say I don't believe .22, you go out and do a full-fledged 2 examination to prove it's .22.
3 But if my preliminary gives me .2 you are going 4 'to believe it?
5 MR. BERATAN: Yes.
6 DR. SIESS: I don't understand why you believe 7 at one level and not at the other?
8 MR. BERATAN: Well, I think just from our 9 experience with reactor siting, in these low seismic areas
- 10 if the ground conditions are good you are not going to get 11 up to .22.
4 12 DR. SIESS: I just don't see it within a
() 13 regulatory framework. Let's skip that one for a minute.
14 Item A-2 is clear. That's west of the Rockies, 15 full-fledged investigation.
16 MR. BERATAN: Now, the next case is that.you can
- 17 choose to do a full-blown Appendix A evaluation.
18 DR. SIESS: Just a minute. I want to go through 19 it step by step. 1 I'll come back to.
20 2, west of the Rockies, a full-fledged 21 investiga. ion.
22 3 says: For any site evaluate it for e-23 liquefaction whether it's west of the Rockies, east of the 24 Rockies, .2 g or whatever.
l 25 4 says -- well, soil has to be adequatt for the O
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1 proposed foundation loading. I wouldn't really put that 2 under geological and seismological but -- okay.
3 And 5 is alternate sites. Okay. I'll skip it.
4 MR. BERATAN: Now, 6 starts with the design.
5 DR. SIESS: 6 says how to get the design 6 earthquake, and you separate 6, now, from 1, which you 7 considered screening. I was how to get the design 8 earthquake, isn't it?
9 MR. BERATAN: 1 is for sites being evaluated 10 under criteria of Appendix A. If you have evaluated the 11 site for Appendix A, then you can get your --
12 DR. SIESS: No, 1, the first paragraph up at the
() 13 top, A-1. Not I.
14 MR. BERATAN: Okay.
15 DR. SIESS: Right?
16 MR. BERATAN: You are not doing a full blown 17 Appendix A evaluation.
18 DR. SIESS: What I can't see is the hierarchy, 19 l here, i in the numbers. I meet 1, however you defined it.
20 You are happy, I come out with .18 and you are happy. Now, 21 does 6 apply?
22 MR. BERATAN: No. Because if you are happy with 23 the site under 1, then you automatically do the structural 24 design based on .25 g.
25 DR. SIESS: It doesn't say that. You O
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2 MR. BERATAN: Yes.
3 DR. SIESS: Where does it say that? I'm still 4 on 6. I'm trying to decide if 6 applies.
5 MR. BERATAN: 6-II.
6 DR. SIESS: 6-II. I refuse to call that 2. I 7 get confused if I call it 2.
8 So I now come to 6 and now I'm going to do the 9 design earthquake and I found a site which my cursory 10 inspection showed was .2 g. So I skip I, because I didn't 11 do it under Appendix A.
12 MR. BERATAN:. So you go to II.
() 13 DR. SIESS: I go to II. Now I use .25?
14 MR. BERATAN: That's correct.
15 DR. SIESS: And even if A-1 gave me 1, I would 16 still use .25.
17 MR. BERATAN: We felt that there was some 18 economy in doing that since most structures would probably 19 take .25 g whether you design for it or not. We felt there 20 was the economy in -- some economy effected by not having 21 to go to a full-blown Appendix A-type investigation.
22 DR. SIESS: What is confusing here is the way 23 this is arranged because 1 through 5, under A, are, I think 24 what you call screening criteria. And 6 is a completely 25 separate thing.
l O 1
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28861.0 70 BRT V 1 MR. BERATAN: Yes. One is screening, one is 2 . design. They are separate.
3 DR. SIESS: But that is not clear. But I guess 4 it could be interpreted.
5 I want to come back to 1. Now let's go to B. B 6 applies to what we-are talking about, casks; right?
7 MR. BERATAN: Yes.
8 DR. SIESS: A applies only to pools and 9 air-cooled canyons, which we haven't seen any air-cooled 10 canyons. So Morris and the other three, the three types of 11 ISFSIs -- the three types all come under B. I mean one 12 comes under A, a water basin, I don't know what a mass
()
v 13 water basin is but I assume that's one that holds more than 14 one --
15 MR. ROBERTS: 750 metric-tons.
16 DR. SIESS: Okay. The Surry type, Robinson type:
17 and MRS will come under B. Okay.
18 Now, what does this say about one that is at an 19 existing reactor site?
20 MR. BERATAN: That has already had an Appendix 21 A-type evaluation. .You can use the g value, design values
! 22 for the site.
23 DR. SIESS: For the site. Now, what happens at 24 one of these sites that everybody thinks it ought to be a 25 little higher now? The uniform hazard.
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.U 1 Maine Yankee, for example, is a .15 SSE, I 2 believe, and it's now undergoing the seismic margin review 3 but.there has been talk about raising that to .18 based on 4 the uniform hazards study. What would you use at Maine 5 Yankee? .15? Or .18?
6 MR. BERATAN: I think that's a licensing 7 decision. If the licensing people decide they want to 8 invoke the higher value, so be it.
9 DR. SIESS: Spoken like a Research man. You 10 have been in licensing. You know that's --
11 MR. CLARK: If we are talking about a cask'I 12 believe it would be a question that wouldn't make too much
() 13 difference. It could even have a higher g value input to a 14 cask, it knocks the cask over.
15 DR. SIESS: You could. But I just want to know 16 what this would require. I'm reading words now. I'm not 17 trying to make, you know, make a commonsense judgment.
18 I'd design it for .2 g and forget about it, 19 apparently. I'm one of those that believes if we had a 20 floor of .2 g we wouldn't have as much trouble as we have 21 now. The floor is still .1 g in here.
22 I understand now it is confusing because the 23 screening and the design basis are not clearly separated.
24 It's just a sequential set of 1, 2, 3, 4, 5, and then 6 25 comes in at the end. But I still don't understand that n
(-)
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1 first one, that screening criteria, how you distinguish 2 between the level of investigation that is needed and the
- 3. Appendix A investigation.
4 I know what you mean and I know what I would do 5 if I wasn't being regulated.
6 MR. BERATAN: If I had a site that came out .21 7 and I really wanted to use that site, I would go to -- I 8 would be forced to go to an Appendix A-type evaluation, and 9 then use whatever came out of the Appendix A evaluation.
10 The idea here was to effect some economy.
11 DR. SIESS: I understand that part. But what I 12 don't understand is how somebody judges the extent of the
()
f 13 investigation needed for that screening as opposed to the 14 Appendix A.
15 The Applicant comes in and says, I've looked at 16 this thing and done all of this, he submits his SAR, and 17 he's come out with .2 g and he says, okay, I'll design it 18 for .25.
19 How is the Staff going to look at that 20 seismological, geological investigation as compared to the 21 Appendix A, and what questions are they going to ask about 22 what he did to get the .2?
23 DR. SHEWMON: Chet, if this is on an existing 24 reactor site --
25 DR. SIESS: Then there's no problem.
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.1 DR. SHEWMON: But we got earlier the 2 introduction, the comment was so far these have all been on 3 sites that have been reviewed once.
4 DR. SIESS: MRS won't be it.
5 MR. CLARK: So far MRS will be. The sites 6 selected are -- have already been evaluated by the NRC.
7 DR. SIESS: You have more confidence in 8 precedent than I do. If it gets controversial enough I'm 9 not sure it won't go through another one.
10 MR. ROUSE: Oh, it certainly has gotten 11 controversial. I think all Tom is saying the sites they 12 have identified and the reason it's in court right now is
() 13 the Clinch River, Hartsville --
14 DR. SIESS: I still don't see how this would be 15 applied to a new site. If there's not going to be any new 16 sites, then I don't care, but it's still a regulation that, 17 if one comes up with it, it's going to be difficult. I 18 suspect what will happen is we will do a full-fledged 19 Appendix A at any new site, period.
20 There's another inconsistency, if I do a 21 full-fledged Appendix A, I can get away with .21. And I 22 can do this other one and as long as I can come out at .2 I 23 can design it for .25.
24 MR. BERATAN: .25. Right.
25 DR. SIESS: That's strange. Do you think a .25 o
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'm) 1 versus .2, compensates for the reduced scope of the 2 investigation?
3 MR. BERATAN: Right.
4 DR. SIESS: It sounds great. Except after 5 having looked at the seismic evaluation for probably 50 6 plants and looked at the questions that were asked by the 7 Staff -- I assume NMSS will be asking those questions.
8 They don't have all the --
9 MR. ROUSE: We'd probably be using the same --
10 DR. SIESS: Using the same geologists and 11 seismologists as work now? I hate to see them without a 12 better -- it took how much pages of Appendix A to define
() 13 that and now we've got something less than that that isn't 14 defined at all.
15 The objective, I think, is great. Personally 16 I'd be willing to say design it for .3 g, stay way from New 17 Madrid and Charleston, and that's it.
18 This is what Bob Bernero came in with, I think,'
19 in '69, he said -- and we didn't have that much trouble
- 20 with it. NRR didn't like it because they thought it was 21 going to mean a higher g value of existing plant. I don't 22 believe you allowed them to use the existing value at that 23 time on that one.
14 Well, I would think it could be made clearer.
l
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l don't think it's a safety significance because we are not 2 going to have any.
3 DR. REMICK: I have a question for clarification.
4 DR. SIESS: It is confusing as hell.
5 DR. REMICK: I have a question on B, for the 6 other types of ISFSI designs, it talks about a 7 site-specific investigation. Are there site-specific 8 investigations other than under Appendix A to Part 100?
9 MR. BERATAN: I think it does.
10 DR. REMICK: I wonder why, under A, we very 11 specifically, looking at I, there, you specifically talk 12 about Appendix A, Part 100 and so forth. That's very clear
() 13 to me. But you don't have an equivalent statement under B.
14 You talk about site-specific investigations. My question 15 comes: Are we talking about Appendix A or is it something 16 different? It sure sounds like it's different but 17 apparently it isn't. I wonder why the inconsistency.
18 MR. BERATAN: I think it is different. I think 19 it refers back to this, what we would do for screening. We 20 would do the literature investigation, maybe poke a few 21 holes down and do some preliminary testing, but we wouldn't 22 do the extent or the amount of detail. There wouldn't be 23 the amount of detail in the investigation as you probably 24 do for Appendix A.
25 MR. ROBERTS: Could I make a comment? And this u/ \
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%d 1 has come up before and I think you said it, Dr. Siess. The 2 types of designs we are talking about here on these other 3 types of designs are modular designs. In particular for 4 the cask, basically seismic is not a serious consideration.
5 We are talking about casks that you are going to pick up 6 and drop from several feet up against hard surfaces.
7 DR. SIESS: But they are not quantified.
8 MR. ROBERTS: Basically when you are doing the 9 structural analysis, it is beyond, basically, what a .2 or 10 .25 g earthquake. In most cases these designs wouldn't tip 11 over, you still look at tipover.
12 DR. SIESS: But these casks aren't qualified for
() 13 transportation.
14 MR. ROUSE: But we look at a drop, for example, 15 the 5-feet drop.
16 DR. REMICK: Wait a minute. That hasn't been 17 answered yet for me.
18 DR. SIESS: Let me ask another question -- why 19 the difference between A and B? Why do you separate mass 20 water basin and air-cooled canyon types frora other designs?
l 21 MR. ROBERTS: Precisely because of this l
22 consideration. What you've kind of done is mixed design 23 and siting in this area here. But the fact is for the 24 modular designs, other considerations, as I said for the 25 casks, such as the transport of the cask and potential for l (1)
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N-1 accidents and dropping and tipover and stuff, exceed the 2 type of thing -- stresses you would see in a seismic 3 situation.
4 DR. SIESS: You are the one that's mixing siting 5 and design. I don't know whether it exceeds it or not 6 until I know what the design earthquake is. If the design 7 earthquake is high enough maybe it doesn't exceed it for 8 certain conditions. So don't mix them.
9 MR. ROBERTS: I would agree with you if you get 10 out to certain areas, 11 DR. SIESS: I think that's part of the confusion 12 here. And MRS would come under B. And MRS includts a lot
,m 13 of facilities other than the casks, some of which may be
(_)
14 important.
15 MR. CLARK: Excuse me, I think the MRS is an 16 air-cooled canyon.
17 DR. SIESS: Those casks sitting out there?
18 MR. CLARK: The casks is part of the design.
19 It's combination of both. It's an air-cooled canyon and 20 some cask storage, both.
21 DR. SIESS: Gentlemen, you are confusing design 22 and siting and design basis with design. These are the 23 geological and seismological characteristics of a site.
24 Are you going to apply different criteria to the 25 consolidation building than you are to the cask storage?
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1 MR. CLARK: Yes. That's conceivable.
2 DR. SIESS: That is not at all clear. I would 3 look at this as selecting a site for the MRS or something 4 equivalent to it and I would'see nothing in here that talks 5 about -- maybe the woro is " structures" in A and not in B, 6 but that's a very legalistic distinction. I think if you 7 want to say the structures, components and systems are 8 designed for one g value and the storage cask is designed 9 for another g value, you should come out explicitly and say 10 so. But I think you are looking at a kind of design you've 11 seen and saying, well, this would work. I think that may 12 work because you are not going to see many designs but I l
13 don't think that's the way to write the rules.
14 DR. REMICK: What was giving me trouble, I saw B 15 as being more stringent than f'ou might possibly have under 16 A, and I was trying to understand why that would be the 17 case?
18 DR. SIESS: I agree. And I dismissed it. But 19 if B comes under A-1, there ain't no way B comes under A-l.
20 They are under separate headings. You see? If you try to 21 do a logic tree, decision tree on it, it won't work.
I 22 MR. ROBERTS: I agree. It's confusing. Casks l' l
l 23 or module storage, though, would be for all intents and 24 purposes, at reactor storage on Part 100 --
25 DR. SIESS: But I'm looking at an independent m
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1 spent fuel storage situation and away from reactor. And I .
2 find the definitions in the headings of A and B -- I don't 3 remember whether they were back in the definitions or not; 4 I didn't recall them -- confusing, not clear, and I find 5 the screening versus design criteria not clearly separated.
6 If I tried to do a logic -- decision tree on this I'd have 7 trouble. I think you are mixing design and siting.
8 DR. REMICK: I would interpret this as the MRS 9 definitely would require Appendix A, Part 100. You are 10 saying it might not.
11 MR. CLARK: Parts of it.
12 DR. REMICK: I can see you being challenged on
) 13 what the regulation really says when it comes to the MRS.
v 14 DR. SIESS: A site-specific investigation, not 15 defined -- I'm going to look back for other words somewhere 16 and I don't find the site-specific investigation elsewhere 17 in here.
18 DR. REMICK: On A-4, there's a reference to it 19 but I'm not sure what it means.
20 DR. SIESS: That's for soil conditions --
21 seismological, geotechnical -- I guess --
22 DR. REMICK: Yes. I tried to find it elsewhere.
23 DR. SIESS: There are words in A-1 that describe 24 a type of investigation. 6-I, it says Appendix A, 25 specifically. 6-II says Appendix A, specifically. So I
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1 agree. I just didn't read that right.
2 Then when I see words " commensurate with 3 proposed requirements of ISFSI," that assumes there's a reg 4 guide that defines what that would be.
5 MR. CLARK: There would have been but because of 6 the use of Staff resources, and we don't see anyone coming 7 in asking for that, we haven't developed such reg guides.
8 DR. SIESS: You just made some changes in this 9 thing to accommodate MRS and some other things you hadn't 10 anticipated -- I have a problem with the extent of the 11 investigation in A-1, and I guess in B, now. I doubt in 12 the -- the first is probably not important. The second --
() 13 DR. REMICK: It seems like you could, if you 14 agree there's confusion here, this would be the time to 15 clarify the intent under B.
16 DR. SIESS: You see, you have gone to this to 17 avoid an Appendix A type investigation. It's a noble 18 approach. You won't need it for any on-site storage. And 19 for a MRS, if it's maybe at the CR BR site where it has 20 been done -- I forget what the other sites are, abandoned 21 reactor sites -- it's not at all clear if it's anywhere 22 near Charleston or anywhere on the East Coast -- well, if 23 it's anywhere on the East Coast now within the Charleston 24 domain, it has got to go through it or else you'll never 25 get through the first hearing.
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gy 1 This option you offered here, I don't think 2 would ever be taken. I think you've got something 3 confusi -j that doesn't have to be confusing and the A and B, 4 if you are thinking of the difference between the structure 5 and the cask, is even more confusing. Because, let's face 6 it, the cask can meet .3 g, .4 g without any trouble, so 7 why try to separate it out in some obscure fashion. It is 8 obscure. Has to be interpreted.
9 If I were doing it I would just simply say 10 siting is like anything else. If the site has already been.
11 established, if a SSE has been established for the site it 12 may be used.
13 There are a lot of sites, you know, this whole f( )
14 East Coast business is under review. We are looking at 15 seismic margins on existing plants to try to get out from 16 under that. Uniform hazard-study on 10 plants came up with 17 some higher values. There's been a lot of problems and a 18 lot of expense and a lot of concern, simply because the g 19 value wasn't taken a little bit higher to begin with.
20 If I were building something, I'd think twice 21 before I kept it down below .2.
22 MR. BERATAN: Part of that is reflected in 23 establishing the .25. We felt if they did this examination, 24 at this point -- if it is .25 g, there'd be no problem as 25 long as the foundation itself was stable.
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1 DR. SIESS: I don't have any problem with that 2 concept. I simply have a serious problem of somebody 3 defining what you just called a. cursory-type examination.
4 I just don't think the geologists, seismologists know what 5 it is and then when they start anking the questions you end 6 up right back where you were before.
7 MR. BERATAN: You end up with an Appendix A-type 8 evaluation.
9 DR. SIESS: And we wrote Appendix A to get away 10 from an open-ended scope in the first place; remember?
11 Before Appendix A, nobody knew where to stop. Now the 12 probabilistic people have gotten in, you know.
()
f, 13 DR. REMICK: But it does enable somebody to try, 14 anyhow. I have no objection with the concept. You might 15 be right; they might not be successful but it gives them at 16 least an opportunity to try.
17 DR. SIESS: The concept doesn't bother me. If I 18 were an Applicant I wouldn't take a chance on that, 19 probably. But there is a confusion here between A and B 29 that I think needs to be cleared up. Whether it needs to 21 be a distinction at all. I think somebody needs to think 22 seriously as to whether the heading A and all of B can't 23 simply be eliminated. Don't make a distinction and let it 24 go at that.
25 I don't know what the implications are. There (3
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'l may be some that.I don't see. But if the only implication 2 is to the cask itself I can't believe that any east site is 3 going to end up much higher than .25, and I don't see any 4 difficulty in designing a cask.and the pad it is sitting on 5 'for .25 g.
L 6 DR. SHEWMON: .One of the points I wanted to 7 bring up, thinking the casks are going to be pretty safe at 8 .25 g, but there's a certain amount of plumbing having to 9 do with the monitoring of leakage and other things. Is it 10 a concern that that is likely or part of its piping system 11 would give you grief? Whereas the casks would be there 12 forever?
f() 13 MR. CLARK: The purpose of the criteria is to 14 look at possible accidents.
15 DR. SHEWMON: But the plumbing is such that if 16 you broke some of the piping or tubing that would be a'"no, 17 never mind," at least in the short term?
18 MR. CLARK: Well, that's certainly a subject of 19 analysis. It would have to be.
^
20 MR. ROBERTS: It wouldn't be a problem. What we
. 21 are basically talking about is the fuel sitting in a basket 22 that is also analyzed and the casks are-double-sealed with 5
23 metallic seals. So there really is no piping, et cetera, 24 to go awry there. Basically what you have is pressure 25 switch to indicate if you ever got any leak. But there is O
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l no piping. It's not an active-type system.
2 DR. SHEWMON: Thsisadifferent;quejtionbut 3 the only monitoring you have, then, is what;comes'out of 4 the cask and whether you've still got a pressure-tight 5 boundary?
6 MR. ROBERTS: What you normally.havevis an'%.% ,
7 overpressure between two lids ~or between two seals. And -
8 basically, if there is any leakage, there's no effluent lo 9 the outside and you have an alarm system that tells you one 10 of the seals possibly has deteriorated and you go out and 11 you check it. If necessary you bring it back to the ,
12 reactor, take the lid off and replace one of the seals. ,
~
13 DR. SHEWMON: Okay.
( _)
14 DR. SIESS: We do of course have a negative 15 uplift to go along with the overturning; it's a shape 16 factor.
17 Do you understand our concerns?
18 MR. ROUSE: Yes.
19 DR. SIESS: .If we do end up writing a letter on 20 it I'm sure we'd find something to say on it but I would 21 boil it down now to whether there needs to be a distinction 22 between A and B. And the question, the separation of' i 23 screening and design, could be handled by some numbering 24 system.
! 25 DR. REMICK: And I add if you find it is
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1 necessary then I think some clarification is called for. I'
- 2- would interpret, reading those, I came out with the 3 . opposite of what I think your intent was. I read site 4 specific as Pa'rt'100 type of evaluation. You are saying it 5 would be somethlng much less than that.
w 6 '
MR. ROUSE: It's very clear we have a problem.
7 DR. SkESS: Well, you haven't had anything you 8 applied it to and you probably won't for anything in the 9 near future except the A-B might. I'd hate to try to claim 10 that to even MRS.
11 Incidentally, 6-I says if it had been evaluated 12 in Appendix A you simply use the SSE. Nothing says that r's
( j 13 ,appli.es to B. That's under A.
. 14' MR. ROUSE: I did want'to make one point. You 15 said one. method we might simplify it would be just to cut 16 it back to A, and get rid of B for the cask and the pad. I 17 want to make it very clear that we have not at Surry 18 considered the pad as important to safety, required to meet 19 seismic criteria. Because we looked at the cask, it can 20 tip over.
21 At Surry it would -- what we did, Virginia Power 22 made it very clear, designer category 1 type of pad would 23 have been extremely expensive for them because of the 24 pilings they would have had to put in.
25 DR. SIESS: To take the overturning force on the o
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I cask.
2 MR. ROUSE: The pad, I'll assure you, is very, 3 very substantial, if it went through an analysis, but we 4 didn't look at it that way.
5 DR. SIESS: So if there were an earthquake it's 6 possible there would be some failure in the pad.
7 MR. ROUSE: Possible.
8 DR. SIESS: I can't believe -- might be some 9 -local crushing in the pad I suspect but --
10 MR. ROUSE: They did look at it for a .07 g, for 15 the static loads. The static loads it turned out by the 12 time you get 20 or 30 of these casks on a pad of 120 tons
() 13 each, it did require a fairly substantive concrete pad.
14 DR. SIESS: I don't care whether it settles or 15 not. I guess it doesn't hurt.
16 I think the thing you would want to think about 17 -- it's not really a safety issue, but suppose you had 20 18 casks sitting out on a pad and had an earthquake and they 19 all ended up over on one side. They are still just as safe 20 as they were before but I can read the headlines. I know 21 it would make the 6:00 news, it would be a beautiful 22 picture. I just don't think it would be nice for them to 23 fall over in any credible earthquake, let's say.
24 MR. ROUSE: As I say they did look at it and, 25 what might be termed, you know --
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1 MR. ROBERTS: The SSE for Surry is .1, 1.35 --
2 this is in the neighborhood of an OBE, for example?
3 DR. SIESS: Are you saying they would turn over 4 at .14, .15?
5 MR. ROBERTS: It's problem at California but 6 it's not designed for it.
7 DR. SIESS: I don't see how they could tip over.
8 Those pads:must be at least 3 or 4 feet thick?
9 MR. ROUSE: It is.
10 DR. SIESS: Fairly heavily reinforced?
11 MR. ROUSE: Very heavily.
12 DR. SIESS: Concentrate all the load on a corner
() 13 I'm going to crush something but -- anyway. That doesn't
- 14 really -- that's not a safety issue, although I don't think 15 it would be very nice to have them all laying on their side, 16 have to pick them up.
17 You know, we talked about the MRS/ DOE submittal 18 as to whether the cask was category 1, seismic category 1.
19 I thought that you told us it was.
20 They said something in their review, either your 21 review or their SAR, said it wasn't considered. Yes, it 22 was.
23 What does it mean to say the cask is seismic 24 category l? It will resist tipping? It is safe if it's
.25 tipped over or it will be safe if it's tipped over.
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1 MR. CLARK: . Maintain the radioactivity material 2 but it would not necessarily meet all-the reg guide --
3 MR. ROUSE: It could tip over and yet maintain 4 its confinement integrity.
5 DR. SIESS: Tip over-because of geometry or 6 because of assumed failure under the toe of the cask which 7 would tip it over.
8 MR. CLARK: .That question -- remember, on the 9 .MRS we did not do a detailed design review so we didn't do 10 anything'like that. We know, generally, what the analysis 11 says. It says the cask will have to be able to be tipped 2 12 over and still maintain confinement.
()' 13 DR. SIESS: But I'm still figuring out will it 14 tip over. If I have .2 g here and two-thirds of that, then 15 I've got one-third of the almost -- I have some reduction 16 in the vertical gravity force, I've got a resultant --
, 17 MR. ROUSE: Those kind of analyses we havi 18 looked at, for the metal casks, let's say. We have not i 19 looked at that for the MRS.
20 DR. SIESS: Will they tip?
21 MR. ROUSE: No. Not until over about .22.
22 DR. SIESS: The question is whether they were 23 crushed at the base or :3omething. Crushing at the base or
)
24 punching ---digging a hole into the slab is not tipping 25 over. I said the tipping over to me is just a public
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1 perception, public reaction issue that I would consider if 2 I were DOE. They've got enough problems.
3 MR. ROBERTS: I think, if you assume things 4 crush or something like that, how do you assume it stays 5 upright or doesn't stay upright? We always tend to take 6 the most conservative approach, I think. Assume they tip 7 over --
8 DR. SIESS: Like a lot of other things you 9 compute it as well as you can conveniently and then assume 10 everything goes to hell beyond that point, which ain't true, 11 But if you are concerned about the casks separately from 12 -the rest of the system I think it can be said a lot more
() 13 clearly than the A and B does.
14' MR. ROUSE: We agree.
15 DR. SIESS: B does not to me spell out that it 16 applies to the cask. It applies to ISFSI, with cask 17 storage, and that's not what you had in mind. And I 18 wouldn't see any problem, technically, safety point of view, 19 of defining in design what the cask was -- how it must 20 perform. I don't think that has anything to do with what 21 the level of the earthquake is. I think the level of
'22 earthquake -- make that anything you want. Then on the 23 design criteria you have say how the structure shall behave 24 under that earthquake. it shall not fail, however we do it, 25 and we shall say the cask shall not lose its integrity to O
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1 contain its contents. By omission you let it fall over.
2 Somebody can calculate it will fall over but that's.a 3 design problem. That's not the seismic criteria problem.
4 So I still think you could combine A and B, and 5 use your A for screening and SSE definitions. But I think 6 it needs a little further thought and certainly doesn't 7 apply to anything that's going to happen in the next year e
8 or so.
9 MR. BERATAN: If you invoke the Appendix A type 10 evaluation, then you could eliminate this section on
-11 screening of design.
12 DR. SIESS: Or if you want to clearly make the p
() 13 difference between screening and design, as I say it was a 14 noble effort. It makes sense.
15 MR. BERATAN: We thought we were simplifying the 16 whole process when we did it.
17 MR. CLARK: There are three other sections, 18 Dr. Siess, under site evaluation factors. 72.67 has to do 19 with the geological impact off site; the criteria there are 20 the EPA criteria. That would include impacts from all 21 nearby nuclear facilities.
22 DR. SIESS: In total.
23 MR. CLARK: In total. Of course ALARA would 24 require that.
25 '
72.68 --
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DR. MOELLER: Excuse me, on 72.67, let me offer 1
2 a comment. I really have no solution to what you should do 3 but I mainly wanted to comment on it.
4 The NRC apparently has 10 CFR 20 under --
5 proposed revision for that. The objective in revising the 6 10 CFR 20 is to incorporate the thinking of ICRP' 7 publication 26 which, when you think-about it now, was 8 issued in 1977. So it is about time for the NRC to respond.
9 In the ICRP 26, one of the major changes that 10 4 10 CFR 20, the revised version, will attempt to incorporate is.
11 the concept of weighting factors and effective dose 12 equivalent. Well, here you are complying with an EPA
() 13 standard which, in many ways, is just as much out of'date 14 as 10 CFR 20, in that they are talking about a 25 millirem 15 whole body dose and a 75 millirem thyroid, which is --
16 which follows 10 CFR 20, 3 to 1, single organ to whole body 17 dose ratios. The ICRP weighting factor for the thyroid is 18 between 30 and 35. In their recommendations for dose 19 limits and in the revised 10 CFR 20, they use a ratio of.10
-20 to 1.
21 DR. SHEWMON: Does one of these go down by a 22 factor of 3 or one go up by a factor of 3?
23 DR. MOELLER: I really don't know but let's 24 assume the whole body is the one they want. A comparable 25 thyroid dose would be at least 250.
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1 So I just wonder -- see, you are moving along.
2 You'll have this come out. Then let's say 10 CFR 20 is 3 revised. Well, that will make this, in a sense, not in 4 agreement with 10 CFR 20, which really, I guess, it does 5 not have to be.
6 Maybe what should be done is someone should go 7 to EPA and say to them: When do you plan to revise 40 CFR ;
8 190, to make it compatible with ICRP recommendations? Or, 9 if you don't intend to do it just say so and give us a 10 reason for not doing.
11 MR. STEYER: We really can't put anything in the 12 rules for what's already there. We can't really change
() 13 what's going to happen in the future.
14 MR. ROUSE: Your point is certainly well taken, 15' Dr. Moeller. As you are aware, EPA, on the other hand, is 16 coming out with guidance for occupational, using, at least 17 a lot more closely, the ICRP weighting factors. So they 18 have --
19 DR. MOELLER: Well, there's a minimum. I think 20 the chairman of the Commission maybe should write a letter 21 to the administrator of EPA and just say: Do you have any 4
22 plans for revising 40 CFR 190 because we are doing a lot of 23 things that tie into it and we'd like to be up to date.
24 MR. ROUSE: Well, more recently they came out 25 with their standard under the Clean Air Act and they did n
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1 the same thing.
2 DR. MOELLER: It's nothing, not your problem but 3 it could impact upon you, well, in a minor way.
4 MR. STEYER: We have been trying to get 5 something similar for decommissioning. They are taking 6 their time.
7 MR. CLARK: 72.68 has to do with the control 8 area, which is similar, except that probably for ISFSI and 9 MRS, you'd find it was much closer in but as a practical 4
10 matter it might be the same, same boundaries.
11 The 5 rem design basis limit is used as compared 12 to the 25 rem reactor criterion, primarily on the basis 13 that it is very easy for this type of facility to meet such f~)h w
14 a criterion. And we have no problem with analysis for that.
15 On emergency planning zone, 72.61 --
16 DR. SHEWMON: Stay with that for a minute. Most
_ 17 sites are at least 300 meters in diameter, minimum?
18 MR. ROBERTS: Or more.
19 DR. SHEWMON: I wasn't concerned about the ones 20 that are bigger.
21 MR. ROBERTS: I was thinking if you are cited at 22 the reactor site you've got it.
23 DR. SHEWMON: Go ahead.
24 MR. CLARK: All of our analyses so far have 25 shown doses under 1 rem.
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1 For 72.69, emergency planning zone, first of all 2 we just can't see any need for any kind of evaluation 3 on-site. That certainly is not in there. And, as I say 4 there's a possibility of having a new version. That's 5 because it followed, as I recall, somewhat Appendix E, Part 6 50.
7 There is a new section on siting, 72.75, put in 8 -- that's the new section now, new Part 72, put in because 9 the Nuclear Waste Policy Act states these things, just 10 states them in the act. It's a requirement of the law.
11 MRS cannot be in the same state as the 12 repository and if it's within 50 miles of a state having a 13 That concludes what I (s) repository can't have over -- that.
14 had to say on the site evaluation plans.
15 DR. SIESS: Okay. The next item is GDC sub F.
16 Is that right?
17 MR. ROBERTS: That's right. I think everybody 18 has the handout I had here.
19 I think, as Dr. Remick remarked quite some time 20 earlier, Part 72 tends to go into a little more detail, 21 probably, certainly than Part 70 ever did. It didn't have 22 much. I think perhaps the heart of it is subpart F, where 23 we have gone into some detail on design criteria.
24 72.71 of course is just general considerations 25 more or less spelling things out. I think, perhaps to me
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1 one of the important things is the statement on minimum 2 requirenents; basically that any omissions in these general 3 design criteria don't relieve the Applicant of the 4 requirement of providing necessary features of the design, 5 of the ISFSI. And I think this is important when you get 6 to site specific areas and so forth and perhaps I can touch 7 on that a little later after lunch when we are talking 8 about specific, site-specific issues with respect to design 9 and so forth.
10 72.72 is the overall requirements. It leads off 11 with a statement on-quality standards that -- on structural 12 distances of components that support the safety, being
() 13 designed -- commensurate with the importance to safety that 14 it's the function to perform. We'll be hitting on the 15 quality assurance program later. Basically now in the old 16 rule we are Appendix B, Part 50. So I guess there's enough 17 said about that at this point.
18 Protection against environmental conditions.
19 That should be natural phenomena. There are a couple of 20 typos I noticed in here last night, including one which was 21 generated in correcting another, I think.
22 I would say, again, again 1 there, in discussing 23 structure systems -- it simply states the obvious: You 24 design to accommodate the site and environmental conditions 25 for normal -- in this case it says maintenance and testing g)
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-3 that would vary, obviously, with the range of designs.
-4 It is a fairly straightforward thing, I think, 5 on cask designs. When you go into other areas, I think you 6 were going to pool designs which we are not interested in 7 here today particularly, but pool designs and other large 8 structures, then it becomes a more of a situation of going 9 through and classifying what is and is not under, 10 essentially, Appendix B, Part 50, and your QA program.
11 Step two, we talk about structures, systems and 12 ' components that support safety and withstand natural 13 phenomena. I think we have gone pretty well back and forth l( )
14 over seismic and the question of separating out the siting 1
15 considerations versus design. And the other natural 16 phenomena that are considered are listed here in the 17 particular: tornado, lightning, hurricane, flood, et 18 cetera. One point I would like to make is there is a 19 change in the new rule for MRS: tornado missiles.
20 If you look closely here, the discussion on 21 tornado missiles says that you do not have to consider it.
22 However, if you go back and look at the history of the rule 23 here and the considerations, basically people were 24 considering pool-type storage and of course the pool-type 25 storage we are familiar with is, for example, Morris, where (1)
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O 1 the pool would be below grade and people were factors in, 2 okay, you are dealing with your own fuel and that sort of 3 thing so you are' not going to get a significant off-site 4 dose and with the below-grade structure, in fact, Morris 5 has been evaluated for tornado missile impact end there are 6 no serious consequences.
7 However, when you go to above-grade type of 8 structures and modular structures, I think that -- and in 9 the new rule, tornado missiles are explicitly called out.
10 And I think in fact we have never done any analysis, de 11 facto, of casks,.and in the licensing of Surry and Robinson, 12 they do not include tornado missiles. I think the
() 13 necessity for putting that in, I think, is simply if you do 14 not design for above-grade structures how do you not ensure 15 you will not get a situation where --
16 DR. SHEWMON: I didn't understand. You said you 17 did have missiles in Surry and Robinson or did not?
18 MR. ROBERTS: We did.
19 DR. SHEWMON: The AC telephone pole at 150 miles 20 an hour or not?
21 MR. ROBERTS: The NUREG-800, 3.5.1.4, where you 22 have the spectrum of missiles.
23 DR. SHEWMON: I'm sorry, let me come back. My 24 experience on this is older, trying to harden plutonium 25 facilities for DOD pools. There were telephone poles that O .
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1 EPRI postulated that EPRI said they could never find on the 2 market when they wanted to throw one. And I wanted to know 3 whether you went that full package or whether you thought 4 out one of your own?
5 MR. ROBERTS: We did go the full package but 6 nowadays it's an 1800-kilogram automobile and an 7 armor-piercing shell and possibly steel shot --
8 DR. SHEWMON: How fast is the auto moving?
9 MR. ROBERTS: Reg Guide 1.716, the total wind 10 speed is 360 miles per hour and -- it winds up at 126 mile 11 per hour horizontal speed.
12 DR. SHEWMON: 126.
(3 r
,.,j 13 DR. SIESS: The fastest a VW ever went.
14 MR. ROBERTS: I'll cover this again in the site 15 specific but it helps, in a way. In a way.
16 So, these are the types of things we have looked 17 at. That is the change that is involved in the new rule.
18 Then, as you work on down through here, 3, 19 basically, capability for determining the intensity of 20 natural phenomena. That really gets into continuing 21 measurements and so forth. Again, as we say for the 22 reactor site, that's a capability that's basically in place.
23 Cle-arly for a separate site facility such as Morris, it has 24 to be maintained directly as a part of the Part 72 license.
25 Then there is a concern here that was, I think, U
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V' 1 basically again goes back more or less to pool storage, the 2 aquifer, consideration of building over an aquifer and 3 possible leakage and so forth.
4 Then the manmade hazards: protection against 5- fires and explosions, designing for that, selection of 6 materials, nonflammable materials; provision of detection 7 alarm and suppression systems; and then that, all of that 8 -- finally sharing of structures, systems and components.
9 I think that was touched upon earlier by Lee, where you get 10 into the considerations there that you do not impair the 11 capability of either facility to perform its safety 12 functions in order to return to a safe condition. That is
-( ) 13 something for the at reactor site that we go into in quite 14 a bit of detail and I'll explain when I get there. Both 15 that for the Part 72 site and the Part 50 site.
16 Proximity of sites. Cumulative. We are looking 17 at cumulative effects here. The only thing I would say 18 here is that we talked earlier about 25 millirem, 75 19 millirem, 72.67. Really what we are looking at when we 20 place one of these on a reactor site is a very small 21 fraction of that should be available from the ISFSI; 22 otherwise it's not likely you'd be putting that type of 23 design on reactor site.
24 Testing and maintenance, F --
25 DR. REMICK: Before you leave the proximity of O
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M 1 sites. A thought comes to mind that's hard to express but 2 let's say the MRS might be located at Oak Ridge where you 3 have DOE f acilities. Are you sucking in the possibility 4 that those sites and so forth would be part of a hearing to 5 demonstrate this would be met?
6 MR. ROBERTS: Right. If there are adjacent 7 sites then depending on the analysis that tells you what 8 the total -- that's a cumulative effect. That's right.
9 I can understand what you are saying because it 10 is not so expressed, really, in this guide because I don't 11 think spent fuel storage even got addressed in 40 CFR 190 12 as part of the fuel cycle because the two were kind of
() 13 right coming at the same time. But it was explicitly 14 picked up in this rule and there is, obviously, the 15 recognition that this is cumulative and it is cumulative 16 not only where you are building on the site of a reactor 17 site but as you say, if you have a facility next to another 18 one. So you do have to look at the overall effects.
19 DR. REMICK: I wasn't thinking so much when the 20 various sites are licensed facilities but I was thinking 21 specifically of Oak Ridge where the facilities are not 22 licensed facilities and some restricted areas. I wonder 23 what problems eventually you could introduce --
24 MR. CLARK: At this time, I did investigate that
! 25 somewhat informally with DOE. That Clinch River site l ()
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1 really is pretty far away. It's hard to see anything on 2 that site that would affect it. We will have to look at 3 that. We will.
4 MR. ROBERTS: Testing and maintenance of systems 5 and components. This is basically an overall requirement, 6 to be able to do this and really, of course, it's 7 applicable to the particular design and types of components 8 and so forth you are looking at.
9 I think we have already -- Lee has discussed the 10 emergency capability but here we are talking about, really, il a general design concern that you have accessibility to 12 equipment on-site, available off-site emergency facilities
() 13 and the like. So it's not only your emergency plan but you 14 are covered basically with designing towards capability.
15 okay, the next part I think is of particular 16 interest. When we get into confinement barriers and 17 systems.
18 Point 1 discusses in the existing rule the fuel 19 cladding shall be protected against degradation and gross 20 ruptures. This has a certain flavor of pool storage added 21 to it at the beginning in the sense that when you are 22 talking pool storage the cladding is essentially the first 23 bearer and then what you've got above that is the water for 24 confinement and shielding.
25 However, in the new rule, MRS, you are talking o>
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1 -- now -- we always realized that you could wind up canning 2 fuel assemblies. If something was really an assembly that 3 had a lot of problems, it already had,.perhaps, failed clad, 4 structurally the fuel rods might have problems, you could 5 wind up canning. That was always -- it was just a given.
6 Now with the MRS you are talking about, 7 potentially you are going to do rod consolidation. .And, 8 also, you are going to be handling. solidified high-level 9 wastes. So there is a discussion of canning explicitly now 10 and Tom could probably address that.
11 MR. CLARK: First of all, Dr. Remick, I must say 12 -- this is something the Department of Energy has a 13 demonstration program for. What we were trying to do is,
{)
14 to cooperate, to have us follci. along on a consolidation 15 program.
16 The point is, there are a number of questions 17 like this that have to be pursued to understand what.
18 fraction of fuel there might be a problem with.
19 Right.now the information looks pretty good.
20 Literally thousands of rods have been reconstituted in 21 reactors, and so far we feel it probably is going to work 22 out. But you have to see a lot of this demonstration work.
23 DR. SHEWMON: It's standard practice now that if l
24 somebody has a leaker that they find, say, by sipping a BWR, 25 they can pull these out, find out which ones are bad, put O
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v 1 the rest back in a subassembly and go ahead and put it back 2 in the reactor and do that on-site?
3 MR. CLARK: I think that's what's being done. I 4 don't work on reactors but I know we had a technical 5 specification in Morris tnat said, if you can detect a 6 leaker then it had to be canned.
7 DR. REMICK: I think it might be 8 miscommunication. I thought what you were saying, Paul, is 9 people would take out the leaking pin and put in a new pin?
10 DR. SHEWMON: They can do that now or they can 11 find out which pin it was, so my impression was that pool 12 side, they can now disassemble subassemblies and put them
() 13 back. That's what I was asking for confirmation on.
14 MR. ROBERTS: That is correct, and over the 15 years for reconstitution of BWR assemblies there's been a' 16 large amount of that. The figures I've heard are possibly 17 as many as 1000 assemblies, that sort of thing. I'm not 18 sure it's that large.
19 DR. REMICK: Taking out the pins?
20 MR. ROBERTS: For the detection of the rods that 21 can be done, too, with ultrasonic measurements and that is 22 available technology. It has been done in some pools.
23 DR. SHEWMON: Early on, GE had a lot of trouble 24 with leaking fuel and you can sip the whole subassembly, l
25 which is 8 by 8, or 14 by 14 or something, now -- but (2)
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1 that's in a can, basically. Reassembly, how they do after 2 that, they don't throw the whole subassembly away --
3 DR. REMICK: They take the channel off. But I 4 wasn't aware they were reconstituting assemblies but maybe 5 you are right.
6 MR. ROBERTS: That has been done. This is 7 because of variations in enrichment. But, sipping is 8 generally for fuel. That may be why they are doing it --
9 generally for fuel that is not too long decayed. I think 10 it gets unreliabic for older fuel and that's where 11 ultrasonic measurement can help; whether there has been a 12 pinhole leak for example in a fuel rod where water is now
- () 13 within the fuel cladding, that sort of thing.
- 14 . DR. SHEWMON
- The ultrasonic wouldn't detect the 15 pinhole but would detect the water. So the argument is 16 that this reconstitution is really nothing different than 17 what they have been doing before and so we don't think that 18 this is going to be dangerous?
19 MR. CLARK: There's a number of questions. The
! 20 purpose for consolidation is to get the fuel in a more 21 compact form in cannisters under seal, weld it up. So I 22 think there's a procedure which I will be going through to 23 get it in that shape so you have the assemblies 24 uncannistered at first in the storage area -- then the l _
25 question is, can they do a number of these assemblies this
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1 way if you are looking at a manufacturing process, and not 2 have a whole lot of these rods fail?
3 Ne conservatively estimate maybe 10 percent of
- 4 all the samples would have to be, perhaps, individually 5 cannistered without consolidation or, if you have pieces 6 that come off they would have to be separately cannistered.
7 That's in the plant or the MRS.
8 DR. SHEWMON: But with regard to the places like 9 Surry and Robinson, they take a whole subassembly, put half 10 a dozen of them or more in one of these big containers and 11 put a seal over it, and there's the requirements that these 12 can't leak when they go in? Or they can leak?
() 13 MR. ROBERTS: Basically, our requirement is that 14 you don't put in this somewhat -- I think it's somewhat 15 similar to Part 71, transportation -- you don't put in fuel 15 that is known to be defective. However, let's not overplay 4
17 this, in the sense that for storage in like the Surry casks
- i. 18 we are talking about storage in helium. So, basically the 19 task drydown proceduto and everything like that, for pinhole 20 leaks and that sort of thing, it's really not a problem.
21 But for purposes of -- and, as I say, the -- like the Surry I
22 cask, it's a double-lidded structure with metallic seals 23 and an overpressure so you are not getting anything out.
24 It's just in general, I think, for purposes of 25 not getting grossly defective fuel you want somebody to at ACE-FEDERAL REPORTERS, INC.
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28861.0 106 BRT O 1 least visually inspect it. Even grossly defective fuel, 2 though, I think you could make the point that it's either 3 going to be in the reactor coolant or it's going to be in 4 the cask. It is in a helium atmosphero. What's going to 5 happen --
6 DR. REMICK: It might be safer in the cask.
7 MR. ROBERTS: Then under H-2, that's purely 8 water storage and it's addressing maintenance of purity, 9 maintenance of water level, after-void falling of vater 10 below a safe level and alarm systems therefor.
11 Ventilation and off-gas systems, this is with 1 12 respect to radioactive particulate, again, this tends to be
() 13 for systems like pool systems or perhaps vault systems and 14 so forth, larger systems rather than systems such as dry 15 modular systems where basically the operations of-loading 16 and unloading are within the reactor system, done within 17 Part 50 and the waste systems there.
18 Then item I, which is instrumentation and 19 control systems. This is basically designing monitoring 20 systems and for normal operation and in order to be able to 21 -facilitate operations after an accident type thing. And I 22 think, again -- we can perhaps discuss this a little this 23 afternoon, for an at reactor site, small modular operation, 24 this is pretty minimal because you have on-site monitoring 25 and so forth.
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(.) 1 We have put up things like BLDs, fenced areas 2 immediately around there, and we do have for the cask 3 designs the pressure monitoring systems.
4 DR. MOELLOR: Excuse me. I guess, too, by the 5 wording of this, you are carefully saying, are you, that 6 they need not consider any noble gas recovery or removal 7 system?
8 MR. ROBERTS: Basically not. Because we -- and 9 maybe I kind of got -- we kind of got diverted off on this 10 degradation and gross ruptures but basically we have 11 considered in the design of the dry storage, maintenance of 12 temperatures. Generally this would be below about 380
() 13 degrees Celsius, to ensure that the long-term capacity of 14 the cladding and so forth is not inhibited or degraded and 15 that, therefore, you would not expect any, essentially, 16 significant number of rod failures or anything like that.
17 And that's the way we have approached it.
18 DR. MOELLER: No, I'm not objecting. I just 19 wanted to confirm it.
20 MR. ROBERTS: I un,9rstand. I just didn't bring 21 that up at the time that I probably should have.
22 Control room or control areas. Again, this is 23 for a large design like Morris, you have a control room.
24 ~For on-site facilities basically you have things like 25 control panels with lights for alarming, for people who are ACE-FEDERAL REPORTERS, INC.
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1 patrolling to be aware.
2 All you would be doing in that case is basically 3 looking to -- that would tell you that for some reason one 4 of the seals might have failed and you were starting to get 5 a pressure loss in that inner lid pressure space so there-6 would be no release per se. You would simply, at that 7 point, perhaps, pull the cask back for an inspection.
8 We do, in item K, utility services. Here we are 9 talking, again, if you are talking about a separate site 10 facility, design it to meet the emergency situations that 11 keep _ utilities going. There really is little redundancy of 12 systems required. Even in the case of Morris the cooling l .() 13 system at points -- it has been a few years ago when Tom 14 was PM on that,-I think -- it was off for about six weeks 15 as I recall and, really, basically when you are dealing 16 with old, cold fuel, there's not much that's going to 17 happen. You get a few degrees rise in temperature in the 18 pool.
19 The dry systems are basically passive systems.
20 There is some consideration, as I'll discuss in the 21 Robinson design, where you've got, if you are depending on 22 circulating air you-have to assure you are monitoring and 23 that sort of thing so you don't get into a blocking 24 situation. Yes?
25 DR. SHEWMON: A couple of other questions I had O
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1 here. Can you tell me what the initial -- what I would 2 like to know is, roughly, what's inside these elements at 3 end of life? What was the initial enrichment? If you 4 burnt up 1 percent then you have .6 plutonium? Or .57 Or 5 what?
6 MR. ROBERTS: These elements are generally 3.5 7 percent initial enrichment and you are about a 35,000 8 megawatt-days per metric-ton burn-up. You would be down 9 around -- I guess you'd be around .6.
10 DR. SHEWMON: Can you convert megawatt-days per 11 ton to percent burn-up?
12 MR. ROBERTS: I think it's around 1000
() 13 megawatt-days per tenth of ton reactivity --
14 DR. SHEWMON: You have as much plutonium as 15 uranium reactivity at 35 megawatt-days?
16 MR. ROBERTS: Yes. I think you are pretty close 17 to balancing at that point after three years of burn-up, 18 say.
19 DR. MOELLER: I notice all of your enrichment 20 limits are original. You don't calculate what it is now.
21 DR. SHEWMON: Let me stay with that for a minute.
22 Why do you say 2.2 or 2.5 then if they go in at 3.5?
23 MR. ROBERTS: We are getting into the specifics.
24 Right now the license board -- when we looked at the design 25 of the cask, initially looking at the borated steel. We O
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( l came to the conclusion that there were problems with 2 Dorated steel and we are still looking at that. If you 3 look at the provisions of the license it basically says 4 that is an open issue and until an acceptable analysis is 5 accepted by the Staff you are restricted to 2.2 percent, in 6 an all-stainless steel basket.
7 DR. SHEWMON: That's not in the regulations, 8 then? It's just in the licensing --
9 MR. ROBERTS: Right.
10 DR. MOELLER: A couple of other items which I'll 11 wait if you are going to cover them. I notice they are --
12 72.74 is rad protection and so forth. Fat looking at the
() 13 Surry license, I guess it was, you had contamination limits.
14 MR. ROBERTS: Yes. -
15 DR. MOELLER: Are they in here somewhere?
16 MR. ROBERTS: No. Basically what we have done 17 is, I think for Surry, the cask exterior it was 1000 dpm 18 for 100 centimeters --
19 DR. MOELLER: How is that controlled here?
20 MR. ROBERTS: It's not directly controlled.
21 Ramember, this is more a decontamination limit for purposes, 22 because these casks are going to be sitting out on a pad in 23 open air and people have to handle them at least initially 24 in the emplacement of the cask and so forth. So we went to 25 limits that are comparable to -- to the transportation cask (3
V.)
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28861.0 111 BRT (n) 1 ~ limits where it would be out in public, essentially. I 2 think that's reasonable, and basically ALARA. It reduces 3 potential contamination. But it's not in the rule. You 4 are right. It's a consideration.
5 DR. MOELLER: Why not? You.see I don't 6 understand.
7 MR. ROBERTS: It's a performance criteria.
8 DR. MOELLER: It will be covered in j
9 supplementary --
4 10 MR. ROUSE: Basically I thought I indicated 11 before, Part 72 is sort of a performance- oriented rule.
12 It does leave some flexibility. One of the reasons for
() 13 this, we knew we were going to be looking at different 14 kinds of storage and facilities. It is a 15 performance-oriented kind of criteria and it does give the 16 Staff come flexibility. On the other hand, it also gives 17 the applicants some flexibility, for his particular case.
18 There wasn't anything particular wrong with the 19 cask. They suggested -- let's use the transportation 20 contamination limits for the cask.
21 DR. MOELLER: I have no problem with that. I 22 just don't understand the basis for not including 23 contamination limits in the regulations. Is it because 24 they are a detail that you'll handle over here somewhere?
25 MR. ROBERTS: In a sense I think you have hit CE)
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28861.0 112 1 the point. We have a wide range of designs here,.from the 2 pool to possibly large vault structures.
3 DR. MOELLER: If it's underwater I'm not so 4 interested.
5 MR. ROBERTS: What I'm saying is given the wide 6 range of designs and so forth, a hard and fast number stuck 7 down in a rule may not be applicable.
8 DR. MOELLER: Okay. Correct.
9 MR. ROBERTS: But you still come in, when you've 10 got'all necessary other criteria involved with respect to 11 operational -- personnel exposure and that sort of thing, I
.12 think that you work your way towards a rule of reason, if
()
n 13 you will, on this type of thing. But, as I say, we have 14 such a wide variety of designs that I think a hard and fast 15 number would be hard to apply.
16 DR. REMICK: You think of that as a tech spec 17 type of --
i 18 MR. ROBERTS: Yes. That's what it is. Tech 19 spec.
20 DR. MOELLER: And the equivalent on a pool would l 21 be some kind of water quality thing.
t l
22 MR. ROUSE: Yes.
23 DR. MOELLER: Okay. Another type of thing. You 24 have in the Surry license, monitoring of neutrons. Here I l
25 gather you just simply say so many millirem, regardless of O
L
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.BRT 1 source. That's fine.
2 MR. ROBERTS: I think we were moving through 3 item K, I guess utility services. And I think we've pretty 4 well, perhaps, discussed that.
5 Section 72.73. Here's where we get into 6 criteria for nuclear criticality safety. Basically, in 7 item A you are talking about design for criticality safety, 8 maintaining subcriticality, accident prevention and 9 maintenance of safety margins.
10 In practice the figure for K effective that we 11 were talking about is .95.
12' DR. REMICK: The same you are using for the
() 13 spent fuel pools.
14 MR. ROBERTS: R!ght.
15 DR. REMICK: Where is that spelled out? In the 16 reg guide?
17 MR. ROBERTS: Well, it was spelled out in ANSI 18 50.57 which was endorsed as Reg Guide 33.59 for the pool.
19 We have another reg guide, CE-10-4 which 20 endorses ANSI 57.9 which is criteria used for -- standards i
21 for design of dry storage. That covered a variety of dry 22 storage designs.
23 That, though, in that case, my recollection is 24 that the ANSI standard references another standard, ANS 25 8.17, which there is some endorsement of going on in
, (1)
(
l l
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.1 another reg guide area. It's a general endorsement.
2 DR. REMICK: In the two cases you've licensed 3 the dry storage do you happen-to recall just roughly what 4 kind of.K effective is involved?
5 MR. ROBERTS: The Surry area I think was about 6 .92, .93. For the new tech design used at Robinson, it was 7 abo 2t .85.
8 DR. REMICK:- Both those include any poison 9 consideration?
10 -
MR. ROBERTS: That's right.
11 DR. REMICK: I couldn't tell from the 12 description, could these modules be flooded? I notice they
() 13 had vents in the top.
14 MR. ROBERTS: Theoretically the module could be
! 15 flooded if it weren't in the flood-free area but that has-16 been looked at basically in the top of the. report. It i 17 doesn't have -- yes?
18 DR. SHEWMON: When you get done I would like to 19 know just how theoretical this flooding is since we have a 20 vacuum tight and pretty thick wall and a few other things 21 in there.
22 MR. ROBERTS: The point I wanted to make is you
. 23 can't flood the steel cannister. You can flood the 24 intervening space between the concrete wall and the steel 25 cannister in there. The same thing with the cask.
O
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L28861.0 115 BRT x-1 But remember we designed -- when we say "K 2 effective," we are designing for water because you have to 3 load and unload in a pool, in a pool environment.
4 DR. REMICK: So those numbers you gave me are 5 basically the maximum?
6 MR. ROBERTS: When you get out to the dry 7 condition it's probably down around .4, the dry cask.
8 DR. SIESS: It seems to me when we were last 9 meeting we were talking about the MRS, and the 10 consolidation facility. The question of flooding that came 11 up.
12 MR. ROBERTS: Tom could probably address that.
() 13 MR. CLARK: What was the question, Dr. Siess?
14 DR. SIESS: Flooding the MRS consolidation 15 facility, whether' criticality was a problem.
16 MR. CLARK: It was planned for the Clinch River 17 site, which was above the probable maximum flood.
18 DR. SIESS: Let's talk about the effect of 19 flooding on criticality and leave out for the moment the 20 probability of flooding.
21 MR. CLARK: I had a little information prepared 22 after that meeting and it was discussed with the Department 23 of Energy -- we discussed that topic with the Department of 24 Energy. As I understood the problem it had to do with, if 25 you had total flooding, regardless of what the probable x
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28861.0 116 BRT 1 maximum flood was, what would the water do to the MRS.
2 There are three locations within the plant 3 structure in the handling building where there's lag 4 storage. Two of those areas are storage of cannistered 5 fuel, quite large storage areas -- 5500 tons a piece. Then 6 there is actually --
7 DR. SIESS: These cannisters are all loaded dry; 8 right?
9 MR. CLARK: All loaded dry. Then four operating 10 cells where the fuel is not yet cannistered.
11 In that instance if you had that kind of 12 flooding there's a possibility of criticality. DOE said as
() 13 far as they were concerned if people thought this was a 14 credible thing they would have to prevent they would just 15 position all the racks so it would be prevented as far as 16 criticality.
17 The other question would be the casks outside 18 and they can't float, they are sealed, the cannisters are 19 sealed and they just sit there.
20 DR. SIESS: I don't remember what the PMF was at 21 the Clinch River site. I know we failed a dam upstream and 22 a few other things and flooded Knoxville. But the problem 23 does come up simply because the PMF is not that low 24 probability of an event. Nobody quite knows what the 25 probability is.
l
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Gi 1 There's a general feeling you need to look at 2 what the consequences might be rather than try to rely on 3 the probabilities alone.
4- DR. SHEWMON: I thought I understood the 5 presentation back here on why this stuff was going to have 6 a hard time going critical if it wasn't critical inside the J
7 fuel pool when they loaded it. Now there's talk about --
8 DR. SIESS: MRS is dry.
9 DR. SHEWMON: Well, maybe I'm going to Surry, 10 then. The stainless steel with boron, why do they need 11 boron in there?
12 MR. ROBERTS: There are two enrichment levels
() 13 that we have a restriction on in that license. One is they 14 are limited to, basically, the 2.2 percent initial 15 enrichment. That comes out of what was start-up, of course.
16 We do not take credit for burn-up or anything like that, 17 but their normal fuel license level would be 3.5 percent 18 initial enrichment. We are still evaluating the borated 19 steel basket design, particularly the borated steel itself.
20 DR. SHEWMON: Why is the borated steel necessary?
21 MR. ROBERTS: Because if you put 3.5 percent 22 initial in it would be necessary to keep it below a K 23 effective of 3.5. The 2.2, you can use all steel.
24 DR. SHEWMON: That assumes you are putting fresh 25 fluid in here for your calculation? Don't you feel you
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28861.0 118 BRT 1 could sort of put a Geiger counter next to the fuel and~say 2 indeed it had been burned up a little bit and give them 3 credit for some of that?
4 MR. ROBERTS: Actually I was at a session of the 5 ANS' yesterday which was specifically addressing burn-up 6 credited and meesurement systems for burn-up and for K 7 effective in casks and so forth. So that is something that 8 is of interest to the industry and it is a question we will
- 9. face in the future. But up to now we haven't faced it.
10 DR. SIESS: Why would anybody want to store 11 fresh fuel?
12 DR. REMICK: Bad leakers.
l () 13 DR. SIESS: Okay.
14 MR. ROBERTS: This goes back to two things. One, 15 there is always the possibility that, as you say, leakers; 16 somebody has a very short burn-up on an assembly. The 17 other really goes back to, if you look at the history of 18 the development of the codes and everything, the margins of 19 uncertainty and that sort of thing, historically we are l 20 looking towards, mainly, initial enrichment or maximum 21 reactivity.
22 DR. MOELLER: And how do you assure --
23 MR. ROBERTS: The other thing is how do you
{ 24 determine burn-up. Right now some of the reactor pools, as 25 Lee mentioned earlier, there are two region pools and by i
l
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28861.0 119 BRT O 1 administrative measures because they have the history of 2 the pool they can set a minimum burn-up and that fuel goes 3 into the region that allows you to take burn-up credit and 4 the other region doesn't allow you to take it.
5 When you get to our types of systems, then this 6 is something we haven't faced yet. We may get an 7 application or something in the future where we have to 8 evaluate it.
9 DR. SHEWMON: So it's conservatism and 10 convenience now. As we both know, there's a very strong 11 economic motivation on the utility to pay attention to 12 whether or not they burned up their fuel before they threw
() 13 it out.
14 MR. ROBERTS: They've got the historical data; 15 that is correct.
16 DR. SHEWMON: So it would seem to me that you 17 could probably do pretty well at saying they had records to 18 show it. It's just you haven't had to give them credit for 19 it yet and so you haven't; is that it?
20 MR. ROBERTS: That is correct.
21 DR. MOELLER: I guess my question was along the 22 same lines. I just wondered what assurance you had that q 23 the fuel going into the surface storage or MRS, was not 24 greater than such and such an enrichment and it, indeed, in 25 so many days of burn-up --
O ACE-FEDERAL REPORTERS, INC.
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28861.0 120 BRT 1 MR. ROBERTS: Again that goes back into the 2 administrative procedures.
3 DR. MOELLER: Back on the 40 CPR 190, when you 4 said you are complying with that. If you are taking into 5 consideration the total dose, your monitoring system and 6 your requirements are limited to the concentrations and the 7 amounts of radioactive materials released, and any direct 8 radiation therefrom.
9 MR. ROBERTS: Yes. And direct radiation is the 10 dominant, basically.
11 DR. MOELLER: I don't want to complicate this t
12 but I guess I could have looked for it to say that the
() 13 licensee must monitor the amounts of radioactive materials l 14 released, both in air and in water; and, then utilizing 15 acceptable environmental transport and food, aquatic
! 16 terrestrial food chain models, then estimate and show that
, 17 this real individual is not being -- not receiving more 18 than the given dose.
19 I mean where do you -- of course you have that 20 in reg guides, anyway. Maybe that's what you are going to 21 use.
I 22 MR. ROBERTS: This almost gets into the
! 23 environmental side of things. Rick, do you want to say I 24 anything at this point?
l 25 MR. STURZ: Really the experience has been with ACE-FEDERAL REPORTERS, INC.
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28861.0 121 BRT 1 on-site reactors and the reactors, all the effluents that 2 are generated are in loading of the cask and that takes 3 place within the reactor and under their tech specs. So 4 the effluents would be accounted for under the reactor tech 5 specs and then just --
6 DR. MOELLER: At the MRS that's not the case.
7 MR. ROUSE: That's not the case.
8 MR. STURZ: That's not the case, no.
9 DR. MOELLER: You might have thought about it --
10 MR. ROBERTS: At a separate site facility you 11 might have to go through the whole process.
12 MR. STURZ: Indeed, you would have to come up I
() 13 with some off-site dose calculation manuals.
14 DR. MOELLER: And I noticed, again, of course, 15 in the Surry thing you required a certain degree of 16 environmental monitoring.
17 MR. ROBERTS: Yes.
18 DR. MOELLER: Okay.
19 MR. ROBERTS: I think we pretty well hit 20 criticality and methods, of course, geometry and absorbing 21 materials.
22 72.74, back to criteria for radiological 23 protection.
24 Basically A is the admonition on exposure 25 control and that your systems will be provided for areas O
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~28861.0 122 BRT 1 and operations, for exposure of on-site personnel to 2 radiation or airborne radioactive materials. Again you are t 3 talking about structure of systems, components for 4 operation, maintenance, required inspections and so forth; 5 that they will be designed -- et cetera. And it controls, 6 as it says here, both external and internal exposures to 7 personnel.
8 Basically, part B, we are talking about
- 9 provision of radiological alarm systems.
l l 10 DR. MOELLER: There I'm curious, and I know you 11 don't want to be too prescriptive but you don't say whether 12 it is an audible alarm or visual or what.
() 13 MR. ROBERTS: Okay. And Tom can probably pick 14 up on Morris that we were talking about a separate site, 15 pool storage and you would have alarm systems. Along the l 16 lines, perhaps, that this is talking about when you are 17 talking about a separate site and pool operation and alarm i 18 systems in the pool area and all of that. But for the dry 19 storage cask design here, basically where you've got this 20 double-lidded system with no effluents and so forth and an 21 overpressure between the two lids so that, in the event of
, 22 a failure of a seal you are not getting any dose out --
23 basically you are not -- therefore you are not seeing the 24 type of thing that requires the type of systems that you
! 25 are thinking about for a large, separate site facility.
(E)
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28861.0 123 BRT O I DR. MOELLER: Will these alarms show up in the 2 control room, meaning of the MRS?
3 MR. CLARK: Yes. Yes.
4 MR. ROBERTS: Okay.
5 DR. MOELLER: I guess what I was saying, are 6 they audible or visual?
7 DR. SIESS: Is this kind of detail in the 8 general design criteria?
9 DR. MOELLER: I assume it would not be.
10 DR. SIESS: Where is it, then?
11 DR. MOELLER: Well, see, ANSI, isn't it? Or one 12 of them has a radiation alarm --
() 13 MR. ROUSE: Your guidance, Dr. Moeller, as you 14 recall, typically it requires what kind of levels you 15 anticipated. If you expect high levels, you know we always 16 would require audible alarms. If you are talking about 17 lower levels then you probably can get by with just a 18 visual.
' 19 DR. SIESS: Where are those requirements?
f 20 MR. ROUSE: They are in some ANSI documents --
l 21 MR. ROBERTS: 57.7, 57.9.
22 DR. SIESS: A reg guide that endorses that? So
- 23 it's essentially in the reg guide but nowhere in the 24 regulations?
25 MR. ROUSE: No.
i (2) i ACE-FEDERAL REPORTERS, INC.
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28361.0 124 1 DR. SIESS: You don't have a standard review 2 plan, do you?
3 MR. ROUSE: No, sir, we do not. We plan to work 4 on it.
5 DR. SIESS: Good. Oh, you do?
6 MR. ROUSE: We have been directed to do so.
7 DR. MOELLER: That's fine for me. I have what.I 8 need.
9 MR. ROBERTS: Of course the rest of it --
10 DR. MOELLER: We've covered the rest.
11 MR. ROBERTS: Well, basically, then, you design 12 for the handling of the fuel and waste and so forth and
() 13 that really comes back to designing your systems for being 14 able to test and monitor shielding, confinement, heat 15 removal, minimumization of waste generation -- in part, 16 it's more or less a summary of what we've gone through 17 before in some like 72.72 but oriented --
18 DR. SIESS: Are those shared systems for the 19 reactor sites?
20 MR. ROBERTS: When we talked about minimizing 21 waste generation, it's shared in the sense that the 22 ef fluents are really confined to the loading and of f-loading 23 and that is taken up by the reactor waste system.
24 Other than that, we don't generate any waste and 25 shielding, confinement -- that sort of thing are for the O
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[ 28861.0 125 BRT 1 system itself so there's really little other sharing.
I 2 Waste treatment --
3 DR. MOELLER: Your criteria for decommissioning L
{ 4 do not seem to say to restore the area to its original 5 state?
l 6 MR. ROBERTS: I know they don't say that but l
7 that's what de facto it is. Particularly with the dry 8 storage thing. .There's a pad out there and you walk away, 9 you look at the cask and see if there's any long-term 1
j 10 activation or anything. Otherwise, it is, in some cases, e
{ 11 be just a generally releasable.
! 12 DR. SIESS: Are you going to make them dig up
() 13 that concrete pad?
14 MR. ROBERTS: Make it a parking lot.
15 Now, we are into Subpart G, quality assurance.
j 16 DR. SIESS: Just a minute. We'll pause as we i 17 reach the end of a section. It's now 12:06. I generally 1
18 run by the clock or agenda. Would you guys like to have l
i
- 19 lunch ncw? Okay. We'll be back at 1
- 05, more or less, i
20 (Whereupon, at 12:05 p.m., the meeting was l 21 recessed, to reconvene at 1:05 p.m., this same day.)
! 22 I
23 i
24 l 25 i i
()
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1 AFTERNOON SESSION (1:05 p.m.)
2 DR. SIESS: Let's come to order.
3 MR. ROBERTS: All right. The existing quality 4 assurance program reference is Appendix B to Part 50. As I 5 think everybody is aware,,there.is a separate incorporated.
6 subpart in the new rule for MRS, and, again, it's 7 commensurate with importance to safety.
8 There is no significant difference, I don't L 9 think, to Part B, and as a matter of fact in the new rule 10 for those facilities, utilities and so forth operating 11 under Appendix B to Part 50, they would simply be able to 12 continue operating under B.
13 Basically there is a little discussion here on 14 the coverage of the rule and records and so forth. But, 15 really as the rule exists now, what you do is go to 16 Appendix B Part 50.
17 We do have a branch technical position out with 18 respect to this, which was drafted by OAP, and which we 19 hope will eventually be incorporated as a reg guide giving 20 guidance to applicants with respect to the quality 21 assurance program -- that's really about all I have to say 22 about that.
23 DR. SIESS: In the new rule you don't refer to 24 Appendix B, except for the previous --
25 MR. ROBERTS: Right.
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- 28861.0 127 BRT 1 DR. SIESS: You don't refer to anything, do you?
2 MR. ROBERTS: No. It's all incorporated, all 18 3 points and everything.
4 MR. STEYER: Almost word for word.
5 DR. SIESS: Wait a minute. I'm looking at --
2 6 okay. I see it now. You've got all of Appendix B stuck in 7 there. 72 through 72.135. Okay.
) 8' Think that's good?
4 9 MR. ROBERTS: Now we are on to subpart I, 10 training. Basically, what is probably of interest here in
- 11 this is that, more along the lines of how we apply it, we ,
12- do have a setup for certification program by the licensee,
() 13 and this has been in operation, for example, at a separate i 14 site, like Morris. For at-reactor sites, what you are 15 really doing is adding a training module onto the existing 16 training for the people who are involved in the fuel 17 handling and cask operations so they are familiar with the 18 ISFSI and tech specs and everything else.
I 19 DR. SIESS: What does certification vice '
l 20 licensing -- one problem you have here is you license the 21 installation -- what certified means compared to licensed?
l I
22 MR. CLARK: I'll be happy to address it. When i
- 23 we started with this part with Morris, for instance, the j 24 operators at Morris had individual licenses for the spent i
25 fuel storage -- for Morris, they were planning to have a
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U 1 reprocessing plant and each operator, individual operator 2 would be required to have their own license that we would 3 issue. So we had, actually, gone through a drill and had 4' licensed some 30 or 40 operators.
5 Included in that, part of that license was for 6 operating fuel receipt and storage area. So they were 7 already trained and had licensed them before that. The 8 plant didn't start up so they didn't really need a license.
9 The difference between certification and licensing is we do 10 not issue a license to the operator but each operator is 11 certified by the licensee, that they've met, really, the 12 same kind of requirements for licensing.
() 13 So we inspect their program, look for all the 14 same elements --
15 DR. SIESS: The training program --
16 MR. CLARK: Every element we had in our 17 licensing program they had in their program except we 18 administer it and inspect it. That's the difference. .
19 DR. SIESS: Does NMSS issue licenses for 20 individuals in other areas?
21 MR. ROUSE: No, sir.
22 DR. SIESS: Radiography technicians and those j
23 people -- same sort of thing as certification?
,e 24 MR. ROUSE: Under most material licensing it's 25 not even quite this formal, Dr. Siess. There is a review O
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i 1 of a training program but here in Part 72 there's actually
.2 a commitment for the licensee to have the certification --
3 actually certified. It's a little more formal than a lot J
4 of the other training programs: You shall have a training I
5 program, you shall keep records of your training. That's 6 about all it says. -
! 7 There's been talk once in-a while for certifying 8 radiographers but that has never come to pass.
9 DR. S1ESS: Are there any industry standards j
10 people can use for this or any attempt to develop them, as I
11 to what should be included in the training program or what 4 12 qualifications for the operator are?
l() 13 MR. ROUSE: Not really.
14 MR. CLARK: I thought we had worked on a branch 4
15 technical position for training, as I recall. I haven't l
16 looked at it for a long time but I think --
- 17 MR. ROUSE
- The problem with that that developed, 18 Tom, was it was oriented and built on the GE Morris program.
i 19 They had an excellent program. It was oriented to pools.
20 It doesn't fit the dry storage as well.
i 21 DR. SHEWMON: .Isn't most of the risk that you j 22 have got when the guy is loading the cannister in the pool l 23 and so why are the qualifications appreciably different
- 24 from what you already need for whoever is doing that sort l 25 of thing?
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- 1 MR. ROUSE: That's exactly the case.
?
2 DR. REMICK: With the exception now, you are 3 going to have an independent, away-from-a-reactor licensee 4 and there are criticality considerations. It's a little l
j 5 different.
6 DR. SIESS: There's two separate things here.
1 7 If you take the Surry-Robinson situation, how steady is i 8 their loading?
l 9 MR. ROBERTS: They have a fairly steady loading 10 because VEPCO has been shipping fuel fairly regularly out 11 to Idaho, so they have a lot of experience. And of course 12 they have an IP-300 cask they own at CP&L, and have been
() 13 involved, at least previously, in transshipment operations.
} 14 DR. SIESS: So this is a process where there l
15 will essentially be a dedicated staff?
16 MR. ROBERTS: Yes.
17 DR. SIESS: Not pick up.
18 MR. ROUSE: No.
l 19 DR. SIESS: When you load spent fuel at a
! 20 reactor into a cask, does that have to be done by licensed 21 operators?
l 22 DR. REMICK: They do have fuel handling people, i
23 I think generally they are reactor licensees but I don't l 24 think they have to be.
i
! 25 DR. SIESS: That's for taking fuel in and out of l (2)
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(_) I the reactor, isn't it? I think the fuel handling license, 2 does that apply in the spent fuel pool as well?
3 DR. REMICK: To the best of my knowledge it does, 4 but I can't say for sure.
5 DR. SIESS: So these people would then be the 6 equivalent of somebody with a reactor operator license for 7 fuel handling which can be a separate license from an 8 operator in the control room?
9 DR. REMICK: I don't know if it's a license or 10 designation.
11 MR. ROUSE: I don't know.
12 DR. SIESS: There is some difference because I
() 13 just saw a report from an oddball reactor in Fort St. Vrain 14 and there were some operator examinations given and there 15 was a separate category for spent fuel handling.
16 MR. ROBERTS: That's high enrichment fuel at 17 Fort St. Vrain and that's HTGR fuel.
18 DR. SIESS: That's the only place you think they 19 have that separate category?
20 MR. ROUSE: I don't know.
21 DR. SIESS: I don't know, either.
22 DR. REMICK: I assume none of Part 55 applies to 23 this training at all?
24 MR. ROUSE: That's correct.
25 DR. REMICK: There's no requirement for C)
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a 1 requalifications? Probably no requirements that it be 2 systematic or performance-based training, the words 3 currently.
4 MR. CLARK: There was no requirement because 5 it's not in the act. The act actually requires it for 6 production and utilization facilities; however, it was one 7 of the elements that we wanted to have in the certification 8 program for qualification so it is in there.
9 DR. SIESS: What are they doing at Surry and 10 Robinson? Both of those I'm sure have training programs 11 for reactor operators?
12 MR. ROBERTS: What they are doing is basically
() 13 for the spent fuel handling people involved in the ' cask 14 handling, et cetera, there are additional training modules 15 added on to the normal training which are involved --
16 familiarization with the ISFSI design and other activities.
17 DR. SIESS: You mean they train their reactor 3
18 operators to do this?
19 MR. ROBERTS: The fuel handling people, because
! 20 these are the people that will be handling the cask and/or 21 cannister, moving it out to the site for replacement or --
! 22 DR. SIESS: Has DOE made a proposal for what 23 they plan to do about training operators?
24 MR. CLARK: Well, in a general sense we have not 4
l 25 gotten down to detail on what would be in the MRS. It 4
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I would be the same sort of thing, I'm sure.
2 DR. REMICK: How about educational requirements?
3 Any?
4 MR. ROUSE: No. There are no requirements.
5 DR. SIESS: Some portions of the operations have 6 very little risk attached to them.- And some not -- some do.
7 The criticality potential, that could get serious.
8 DR. REMICK: I think with MRS, with a lot of 9 fuel potentially in it, I have the gut feeling that 10 somebody should know something about criticality. That 11 doesn't say they are not. The training program could 12 include it but you have no guidance on that.
() 13 MR. ROBERTS: Two points with respect to the 14 at-reactor. One, we are looking at initial enrichment.
15 The other is that we are looking -- we have double 16 verification. In other words, the identification of the 17 specific assembly that goes in to track it. That's the 18 at-reactor.
19 DR. REMICK: But what control do you have at the 20 MRS that somebody doesn't do something stupid?
21 MR. ROUSE: It's kinds of like at a fuel 22 facility. I personally think there's no potential at some
, 23 of our high enriched fuel facilities. There the program 24 you rely on for criticality safety is the safety people,
]
25 criticality safety people, and your oversight and your
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28861.0 134 BRT 1 procedures. And there is training of the operators,
'2 workers. But the licensing review is developed looking at 3 that criticality safety program, key safety people and how 4 that is implemented through their procedures. And then of 5 course there's a requirement that the operator be trained 6 in the procedures, be trained in criticality safety to the 7 extent needed to know their job.
8 DR. REMICK: You would see that here also?
9 MR. ROUSE: In the MRS; yes, sir.
10 DR. SIESS: I think the problem is not a concern 11 that they won't be trained operators but the concern that 12 there is no formal. procedure for assuring that they are
() 13 trained operators. NRR's attitude is if it isn't formal, 14 l if it isn't written down, inspected and qualified and 15 requalified, they are not trained.
16 MR. ROUSE: I don't want to imply -- there is j 17 training. It is required. Records are required even in i 18 the fuel fabrication facilities, the high enrichment i
19 facilities. There is training required of these people.
20 DR. SIESS: Required of what? Is there a i 21 requirement in the rules?
, 22 MR. ROUSE: Yes. It says -- there just isn't i
23 great detail that you find in Part 55.
l 4
24 DR. SIESS: But they know what's expected of 25 them from you guys? Suppose you all were replaced tomorrow.
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(V 1 MR. ROBERTS: For one thing, it's involved in
.2 the tech specs of the license and in the safety analysis 3 reports and so forth. So there are clear-cut operations.
4 The other thing is -- I don't see him here --
5 but we do interface very closely with IE, a number of 6 branches in IE, a number of branches in the inspection and 7 enforcement.
8 DR. SIESS: With what? There isn't any. You 9 are going to interface a lot more closely.
10 MR. ROBERTS: They are going to be part of NMSS
- 11 in the future. But we do follow on in the preoperational 12 and proloading and so forth and construction phase,
() 13 interfacing with the people involved at both resident 14 inspector -- we are sent the instructions that go out for 15 inspections and so forth and that sort of thing.
16 MR. ROUSE: The point about training -- I want 17 to talk about material licensing in general as opposed to 18 Part 72. There is a point -- the Sequoyah fuel's, the 19 Kerr-McGee accident, UF-6 accident, there was a case where 20 the training program got sloppy. There's no question about 21 it, because they weren't following procedures.
22 DR. SIESS: Which was this?
23 MR. ROUSE: The Sequoyah fuels, the cylinder 24 ruptured, of UF-6. As a result of that, there's some 25 lessons learned in NMSS, I think 50 something, right now, I
/~)
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- n 1 on last count. Another TMI action plan. But one_of those 2 is training. Training, operating procedures. I suspect 3 we'll see a greater emphasis not only in the staff review 4 but in the inspection function and the emphasis on the 5 licensee. And I think we'll probably see some more 6 guidance developed. I'm talking _very generally, not just 7 Part 70.
8 DR. MOELLER: Dr. Perry reminded me, I think 9 Part 60 has something on the training of people who work at 10 the repository? ,
11 MR. ROUSE: Yes.
12 DR. MOELLER: I don't know if you cross-checked
/~
( 13 these two at all.
14 MR. ROUSE: I am familiar with it, yes.
15 DR. REMICK: I guess some of my concerns were 4
16 the same as Dade was expressing later in rad protection.
17 We are going on as usual and then there's another part of 18 the agency out there that is endorsing systematic training 19 and performance based and they are about ready to introduce 20 a new Part 55 endorsing that context and I don't see any of f 21 it in another office of another building of the agency.
22 DR. SIESS: Let me make a comment. I had the 23 experience a couple of years ago of reviewing rather 24 intensely the difficulties of one branch of NMSS, 25 transportation certification branch. I saw there the same I
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1 thing I'm hearing here: An excellent job being done, 2 excellent results being obtained but the formalities not 3 written down in the rules.
4 DR. REMICK: I'm not thinking necessarily about 5 formality. The general thrust --
6 DR. SIESS: If you look at the result, it was 7 good. It wasn't spelled out, if you will.
^
8 MR. CLARK: Now, Subpart I does specify 9 certification. That's right in the rule, 72.91 through .93.
10 DR. SIESS: I think the feeling is anything you 11 say in that many lines, it can't be good, when NRR takes a 12 book to do it.
() 13 DR. REMICK: It's not only the words. I guess I 14 can see NMSS right now accepting a training program that i
. 15 had none of what they call systematic approach, performance 16 based, which the reactor industry, power reactor industry 17 is going, and not only for operator license but for 18 maintenance personnel, control, health physics, technical 19 staff -- I don't even see any recognition here that that's 20 the way that portion of the industry is going, that portion 21 of the agency is heading in that direction. I don't see it 22 captured here.
23 I'm not saying it's precluded, but I see you 24 accepting a training program that doesn't have those 25 components to it.
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L) 1 MR. CLARK: The only thing I can tell you is 2 they had all the components they had when they were 3' licensed. No difference. They did everything except we 4 did not issue a license.
4 5 DR. REMICK: I'm thinking of MRS, whether I'm 6 looking ahead to the future. Unless you do it through some 7 other mechanism, you have none of those words here which 8 would indicate to people the type of training program.
9 DR. SIESS: What you are assuming, Forrest, is 10 that Surry and Robinson, for example, are training these 11 people the same way they are training the reactor operators.
I 12 DR. REMICK: Reactor operators and automatic
() 13 fuel handlers --
14 DR. SIESS: They recognize the value of it or 15 they have gotten used to it.
16 DR. REMICK: What I'm thinking of is beyond that.
17 I'm not thinking of the ones at reactors but something like 18 the MRS, where it is possible for the licensee to come in 19 and propose, and presumably NMS, in isolation, accept. And 20 it',s not what I would call state of the art.
21 MR. CLARK: We certainly have available to us 22 everything that the reactor people require. We can look it 23 over.
24 I have a little difficulty believing that you 25 would require the same thing from MRS as you would O
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/m 1 require --
2 DR. REMICK: Oh, no. But I don't see a training 3 program which is systematically designed or any of those 4 words which would give you a hint of the type of training 5 program that you would like to see. I just don't see it 6 there. So, to me it's what you would have required five 7 years ago.
8 DR. SHEWMON: 15 years ago it would have been 9 discipline. This time it has to be systematic; is that it?
10 DR. REMICK: That's right. It's a very current 11 word.
12 You know what I mean. It's based on a job and
()
13 task analysis. What does a person really need to do to 14 perform the job and how are you going to go about training 15 him? Where are you going to do it? Classroom? On-the-job 16 training? Do you expect him to come in with some of those 17 skills and abilities?
18 MR. ROBERTS: It's both.
19 DR. SIESS: I think the point is made and 20 received.
21 MR. ROUSE: Received.
22 DR. SIESS: Let's see, does that finish your 23 part?
24 MR. ROBERTS: I think we are finished on that.
25 DR. SIESS: Okay. The next item is Subpart H, C')
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2 DR. REMICK: Going back, I just wanted to 3 emphasize, from my standpoint I'm not looking for a Part 55 4 or tremendous detail.
5 MR. ROUSE: I understand. What I'm thinking, 6 what we could do now is go back to the branch technical 7 position, take a look at that and then go to reactors and 8 see what -- whether it is written, is based on a training 9 program that GE came up with. Maybe take a look at it.
10 We are talking about DOE, we are talking about 11 number 1 license. If we just get the branch technical 12 position out to DOE and say, hey, that's the kind of thing
() 13 we expect.
14 DR. REMICK: And it won't be new to them because 15 they are heading in that direction in their reactor areas.
16 MR. SAWYER: I'm Carl Sawyer from the division 17 of safeguards. With respect to Subpart H, physical 18 protection, as you can see from the handout there are four i
19 provisions.
20 The first calls for a physical security plan, 21 which is to be based on applicable requirements of Part 73, 22 a point to which I'll be returning. The physical security 23 plan is to include a means to demonstrate compliance. This l 24 is largely for the benefit of the inspectors who would go 25 out, to enable them to determine whether or not the O
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2 The design for physical protection sections 72.82 3 include such things as site layout and design features with 4 a view toward making a physical security plan a stand-alone 5 document. The third provision, 72.83, calls for a 6 safeguards contingency plan. This is in response to the 7 statutory requirement. It's prepared in accordance with 8 comprehensive direction, under Appendix C, and finally the 9 changes to these plans must be controlled so that the 10 effectiveness of the plan would not be diluted by the 11 change.
12 DR. MOELLER: Excuse me, say that again? The em f ,) 13 last part?
14 MR. SAWYER: So that the effectiveness of the 15 physical security plan would not be diluted by changes, I 16 might add, licensee changes, unilateral licensee changes.
17 DR. MOELLER: Okay. And they are not, I presume, 18 allowed to make significant changes without NRC's approval?
19 MR. SAWYER: That's correct in spirit, yes. By 20 that I mean the licensee can make minor changes, 21 housekeeping adjustments and the like without coming back 22 to us. But anything that is perceived as being sensitive 23 or having an effect on the performance must be brought 24 before us for approval.
25 Continuing then with this, and referring now to o
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U 1 this notion of applicable requirements in Part 73, when one 2 returns to Part 73 and looks at the material he finds that 3 the most substantive requirements are set forth in 73.50.
4 The objective of these requirements, of course, 5 is to protect against radiological sabotage, and moreover 6 we quickly note that the cask cannot be readily moved and 7 sabotaged. If it is to occur at all, it has to occur at 8 the fixed site.
9 DR. MOELLER: Have you done scenarios? Or is 10 there very little that you see that could be done?
11 MR. SAWYER: With respect or in the context of 12 the softest of the targets that's likely to be available,
() 13 which we see as the dry casks at reactor sites, it strikes 14 us that there is a close parallel in the structure of these
, 15 casks, close parallel to transportation casks. And we have 16 done a great deal of work on transportation casks.
17 What we find -- just assume successful sabotage 18 -- what we find is releases of two kinds when explosives 19 are applied to them very skillfully.
20 One of these releases is some amount of 21 ballistic particles which fall in the immediate vicinity.
22 But more important is a few grams, in the transportation 23 cask situations, a few grams ranging -- one research paper 24 found 18 and another 34 grams respirable release. So what 25 we would like to do is interpret 73.50 in a way that r^>s u-l l
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() 1 programs provide that what we see is appropriate protection 2 against explosive sabotage scenarios against these casks.
3 To do this we think that there should be a 4 security force which may well be the security force on the 5 reactor site with no additional, supplemental force 6 required.
7 We think that there should be a system of 8 barriers. The cask itself can count as one -- there would 9 be-an outer barrier with a view to preventing casual
. 10 accession to the casks.
11 DR. SHEWMON: When you say casual, are you 12 talking about a barbed wire fence or something that would --
() 13 would an impact limiter be of this sort?
l 14 MR. SAWYER: The minimum barrier that we now 15 have in mind is a security fence. This serves a number of 16 purposes, one of which is to simplify access controls.
17 Ideally we would like to have zero access, but of course
- 18 this is not real world.
1 19 So we settled for personnel access based on need.
20 Searches -- this is a fairly simple and straightforward 21 idea because we would be looking for packages of 10s of 22 pounds of explosives or more so it's just a matter of 23 observation; badging to identify people, prohibition of 24 casual vehicles being within the enclosed area; and 25 visitors be escorted.
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l DR. MOELLER: There's not much maintenance that 2 the on-site personnel have to do, is there? I mean you 3 don't have to go out and walk among the surface stored 4 spent fuel?
5 MR. SAWYER: Not from a safeguards viewpoint, no.
6 MR. ROUSE: No.
7 DR. MOELLER: For anything?
8 MR. ROUSE: That's correct.
9 DR. REMICK: Talking about security force, is 10 there a design basis threat?
11 MR. SAWYER: Not from a legal viewpoint. From 12 an actual working viewpoint we have the -- we would use the
() 13 same design basis threat that we developed for 14 transportation casks. This consists of a force with a view 15 toward assaulting the cask with a shaped charge.
16 Continuing, then, with the security features, we 17 would next propose to have a set of detection aids at this 18 outer perimeter; illumination so we could see what was 19 going on at night; surveillance by patrols of several times 20 per shift; a perimeter alarm which would terminate in a 21 continuously planned alarm station; and the alarm station 22 itself.
23 We would next require immediate response in the 24 event of suspicion or a determination that there was ao 25 intrusion within the alarmed area. Someone would go
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1 immediately, evaluate the situation, make a determination 2 of whether there was a threat of sabotage and if there was, 3 would move in the difficult area of neutralizing the threat.
4 There --
5 DR. SHEWMON: Sir, in this area are there any 6 additional men required at Surry to meet these requirements?
7 MR. SAWYER: No.
8 DR. SHEWMON: This is something they are capable 9 of and it wouldn't take so much of their time that it would 10 need additional personnel?
11 MR. SAWYER: That's our present view of the 12 situation.
. ( ji 13 DR. SHEWMON: Okay. Thank you.
14 MR. SAWYER: To neutralize a threat, of course, 15 we anticipate that the security force would immediately 16 contact the police with whom there had been prior 17 coordination. To do that we require that guards carry 18 . radios capable of communicating with the alarm station and 19 that the alarm station be able to communicate with police, 20 both by telephone and two-way radio.
' 21 We also require that this communication s
22 equipment be provided with an independent source of power.
23 We will, a little later in the series of j
24 presentations here, we will be returning to the subject to 25 show in greater detail what the licensing procedure was at O
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28861.0 146 BRT 1 Surry to put this philosophy into practice.
2 DR. REMICK: One that would be helpful, and tell 3 me if I get out of the bounds of an open meeting, but I 4 guess I don't know enough about the transportation design 5 threat to know -- it certainly sounds logical but I don't 6 know what the implications are for MRS.
7 Are we talking about a need for a large force 8 that has developed around reactors? Or is this a much more 9 modest security force? I don't know where that design 10 basis threat leads us.
11 MR. SAWYER: I think what we are looking at is a 12 definite difference in scale, for openers.
e (m_,1 13 We are talking at an MRS of a fairly sizable 14 site. So from that point of view alone I would expect more 15 people, a larger security force.
16 Much would also depend upon how rapidly, within 17 whatever locality this MRS is to be located, how rapidly 18 one could build up a defense force. That is, drawing from 19 local police, how soon could they get the force that we 20 would be looking for.
21 If the response time of a sizable force of 22 police is short, then we would require a smaller force.
23 And likewise, if it were longer, we would require a larger 24 force.
i l 25 DR. REMICK: I can understand what you are O
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1 saying, if it's a larger perimeter, you might need a larger 2 force than would otherwise be the case, but is that 3 otherwise than a typical power reactor? We are talking 4 sometimes of hundreds of people. Counting all shifts.
5 MR. SAWYER: I would certainly expect a security
'6 force at an MRS to run, I would say at least equivalent to 7 a reactor.
8 DR. REMICK: Even though the risk of the 9 application of that shaped charge can't be as large a 10 public risk if they were successful?
11 MR. SAWYER: Well, if it were the cask form 12 alone that we were thinking about, I would sey that you are
() 13 correct. But there are so many other facets of MRS.
14 There passes through my mind material in 15 situations that we are just not familiar with at this time, 16 we just don't know enough about. But if I had to make a 17 conjecture as to what the security force at an MRS would 18 look like, I would toss out as a first guess, comparable to 19 that of a reactor.
20 DR. REMICK: I must admit that worries me, I 21 guess.
22 DR. SIESS: Do you want it bigger or smaller?
23 DR. REMICK: Certainly not bigger. I look at
, 24 the Japanese, with four units, total force of 40. We'd 25 probably have that on the first sheet at our power reactors.
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\_J l I have my own biases. I just think we have gotten out of 2 bounds and reason. I'd much rather have more people 3 worried about criticality, I guess, than the other.
4 MR. SAWYER: It's certainly conjecture at this 5 stage. -MRS is a very pleasant thing, at least in my mind.
6 We know very little about what is planned, but I have seen
.7 some of the brochures and the like and we of course have 8 read the DOE conceptual design proposal and evaluated it.
9 It didn't help much in terms of defining the force.
10 DR. REMICK: This is going to be basically kind 11 of a fortress?
12 MR. SAWYER: I would not characterize it that
() 13 way.
14 DR. REMICK: It's going to be a constant small 15 SWAT team going to have to be there, assuming there's no 16 local forces to be brought in. Chances of that are to be 17 slim, I would think, at both sites. Unless it's a DOE 18 reservation or something.
19 You are going to have a much larger guard force 20 than we are going to have an operating staff, probably.
21 Well, I'm trying to understand. I expressed my 22 concerns. It's hypothetical.
23 DR. SIESS: It seems to me the MRS has a large 24 processing facility with a lot of fuel laying around loose, 25 and then a storage area which is something else. These are Os ACE-FEDERAL REPORTERS, INC.
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28861.0 149 BRT 1 almost two'different kinds of things to protect.
2 The processing facility is going to end up 3 something like a reactor plant with a lot of doors --
4 DR. REMICK: We are basically talking about cold 5 fuel. You break apart the cold fuel, the public risk is 6 probably pretty small, I would guess.
7 DR. SIESS: Whoever said these things were done 8 proportional to risk? ,
9 I noticed something interesting, comparing the 10 present version with the proposed version in Part H -- I 11 didn't notice it anywhere else because I didn't look for 12 the detail -- the word "shall" was changed to the word
() 13 "must."
14 MR. ROUSE: That's our legal staff. You use the 15 term "must" when it's an inanimate object and "shall" when 16 it's a person. "You shall" and "it must."
17 DR. SIESS: That's interesting. I don't think 18 that has permeated the rest of the industry.
19 MR. ROUSE: I think it's getting there. That's 20 one of the things that counsel are doing in their review.
21 DR. SHEWMON: You wouldn't want the counsel not 22 to be doing anything, would you?
23 DR. SIESS: Oh, no. We've had enough trouble
! 24 with "shalls" and "shoulds." "Must" and "shall," at least l'
25 to the same degree.
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- 1 Any other questions? Are you through?
2 MR. SAWYER: Yes.
3 DR. SIESS: Any other questions on the 4 safeguards aspect? Okay. That brings us down to -- well, 5 that brings us to the end of Part 72, doesn't it, as such.
6 I noticed here we had an item on the - comments 7 on proposed changes to Part 72. What did that mean?
8 Public comments?
9 MR. STEYER: Yes. Public comments.
10 DR. SIESS: Somebody was going to deal with 11 those?
12 MR. NILSON: I can give you a few minutes on
() 13 that. It won't take long.
14 DR. SIESS: Let's do that now and then the 15 applications to Surry-Robinson. So let's skip on down to VII.
16 Mr. McKinley will pass the handout around for you. You can 17 sit down and start talking, I guess.
18 MR. NILSON: A lot of the information I was 19 going to cover was covered in piecemeal. It was published 20 in May in the '86 comment period; we received over 180 21 comments from individuals and various other corporations, 22 et cetera. Approximately two-thirds of the comment letters 23 are of a single consensus, meaning they are -- they were 24 written in response to the representative from the state of i 25 Tennessee to his constituents and they all say: License O
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b 1 the facility twice and not in Tennessee.
2 They go all the way, one of them is signed by a 3 10-year-old girl and on up to retired people, et cetera.
4 The remaining comments we received, we got four 5 from the states: Mississippi, Tennessee, Maryland and I 6 think it was North Carolina. Then 11 utilities, some 7 reactor operators, EEI; we got comments from DOE, obviously.
8 DR. MOELLER: When you say from a state, is that 9 from the governor?
10 MR. NILSON: They were not signed by the 11 governor but were signed by Department of Environmental 12 Safety and those kind of situations. None of the letters 4
() 13 were signed by the governor.
1 14 DR. SHEWMON: When you went out for this, was 15 that on siting it at Clinch River or only 72?
16 MR. NILSON: What was published was the proposed 17 change to Part 72 including the licensing of MRS.
18 DR. SHEWMON: And Maryland was interested just 19 because they were public spirited or something? Is that it?
20 MR. NILSON: Yes.
4 21 MR. ROUSE: I think it's more of -- DOE has 22 proposed that it put the MRS in Tennessee, at Clinch River.
23 The NRC comes out with a rule that would cover the 24 licensing of the MRS, wherever it ends up to be, but they
, 25 have added those together and said we don't want it in
! C)
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f'J s-l Tennessee. They have also written DOE.
2' DR. SHEUMON: The question is whether they war:
3 it in Maryland. But then go ahead.
4 MR. NILSON: Okay. There are approximately'50 5 identifiable comments in addition to the ones not in 6 Tennessee. The majority are procedural or clarifying in 7 nature. Examples -- a lot of them we've discussed. The 40 8 years versus the 20 years; a lot of people are commenting 9 on the fact that they thought, because the regulations said ,
10 high-level waste, we were talking about liquid high-level 11 waste which would be stored in the repository. As we are 12 well aware that won't happen.
. () 13 Comments about the emergency planning. Some of 14 the comment letters said that nothing should be done on the 15 proposed regulation until Congress has acted, saying that 16 one should be built.
17 Various comments like: DOE should provide 18 funding. These are all the procedural type of comments 19 that were received that were spoken to.
20 There were a limited number of safety-related 21 technical comments. Again, they have all been covered.
22 The one comment on the seismic activity that we went 23 through extensively. Tornado missiles. Criticality 24 aspects.
25 But, really, no -- I have to say in all honesty O
1 l
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28861.0 153 BRT r3 b 1 that at this point in time there were no technically-oriented 2 safety comments that were not considered somewhat in 3 regulations. No one brought up any new and unique items 4 that we hadn't discussed.
5 We will be working on those comments and writing 6 a position paper for permission to go ahead. That's all I 7 have.
8 DR. REMICK: What kind of comments did the
- 9 operators have?
10 MR. NILSON: The utilities mainly go down the 11 road that they don't want to go through a second licensing 12 type of an activity. It's the way you would normally see,
() 13 the less regulation the better.
14 MR. ROUSE: It's on that policy question whether 15 or not there's opportunity at the second hearing prior to 16 receipt of fuel. They were unanimously opposed.
17 DR. REMICK: When you said operators, I meant i
j 18 reactor operators.
19 MR. NILSON: Some of them were reactor operators.
I 20 DR. REMICK: But that was the point: one-step
, 21 licensing.
22 DR. SHEWMON: What is the position that you have 23 for at-reactor site licensing?
24 MR. ROUSE: At-reactor site there is a notice of 25 opportunity for hearing when we receive the application.
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28861.0 154 BRT O 1 There is nothing, no opportunity after that.
2 The license would be issued and --
3 DR. SHEWMON: Is that what you did then at Surry 4 and Robinson?
5 MR. ROUSE: Yes.
6 DR. SHEWMON: Published this in the Federal
- 7 Register. Did you get any response on either?
8 MR. ROUSE: We had no request for hearing.
9 In the case of the reactor, the cask, they can
} 10 buy the cask ahead of time. Once we issued the license --
. 11 they already loaded the cask. The MRS, the rationale for 12 the second look, it's going to take them quite a while to g
I'\ 13 construct the MRS, about four years, and with some thought 14 from our management, maybe at the Commission discretion you l 15 ought to be able to say -- if there's anything new, we 16 ought to be able to provide the opportunity for a hearing.
17 In actual fact, the lawyers say the Commission can call a 18 hearing anyway.
19 DR. REMICK: And I assume the public could, too, 20 if they had something.
i 21 MR. ROUSE: I assume. So it has become sort of i
22 an emotional item.
23 DR. REMICK: In the case where you do have an 24 on-site one, where you notice the opportunity for a hearing, 25 do you have -- I can't think of the words -- determine that
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v 1 there's no subsequent hazard? Substantive hazard?
2 MR. ROUSE: For amendments, yes, we do. We 3 don't fall under the shally procedure, per se, but we 4 follow it pretty closely.
5 DR. REMICK: What's the coin word, I don't 6 think --
7 MR. ROUSE: No significant hazards --
8 consideration.
9 DR. REMICK: You do go thrcugh that?
10 MR. ROUSE: Yes.
11 DR. MOELLER: And two-thirds of the letter'were 12 of a single consensus and that means they were opposed?
() 13 MR. NILSON: They were opposed. They followed 14 their representatives' comments and they were opposed to 15 Tennessee and wanted to license it twice.
16 Their nomenclature and licensing twice, they 17 obviously are parroting their representatives' words and 18 they don't identify what they mean by this.
19 Most of them feel that they misread the 4
20 regulations, as we explained all during this period of 21 construction, I&E were in there, we update the SAR. A lot 22 of people thought that once the license was issued there 23 would be no follow-up by the NRC whatsoever.
24 DR. REMICK: DOE comments? What were the DOE 25 comments?
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28861.0 156 BRT 1 MR. NILSON: Well, mainly commenting on the 2 aspects of publishing the opportunity for notice of the 3 second hearing. There were three questions that were asked 4 by the Commission and they respond to those three questions 5 about that notice: What things could be opened at the 6 hearing and the type of a hearing, the form that the 7 hearing should take. They comment on those.
8 They also commented on the aspects of physical 9 protection; the aspect that in the regulation it currently 10 says that the physical protection at this facility will --
11 should be identical, or equivalent to DOE facilities of 12 similar nature or something; and wondering what similar was
() 13 and also the comment of some of their facilities are also 14 classified or, you notice, weapons type. And the other was 15 the aspect of in the regulations we say that the casks 16 should be continuously monitored and they -- this is 17 something that we will have to speak to in the -- going out 18 with the proposed rule as an effective rule.
19 We tried to follow the words that were in the 20 Waste Management Act but I think we slipped up on it.
21 DR. SIESS: What I suggested was that the 22 application of the Part 72 to Surry and Robinson might be 23 of interest, at least of examples-of explaining things. A I 24 lot of this has been done, I think, during the discussion.
25 But you do have a couple of presentations on this? I think o)
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]v 1 we --
2 MR. ROUSE: Since we did bounce in and out of 3 Surry fairly often, I think John could probably cover it 4 fairly rapidly.
5 DR. SIESS: Do what you think would be helpful.
6 MR. ROBERTS: Okay. I think Owen has passed 7 around a couple of pages I pulled out of our documentation 8 here. Dr. Shewmon asked earlier if there were other types 9 of casks.
10 If you look at the picture behind caster 5 here, 11 horizontal, are a number of other casks and they are 12 associated with other reactors in Germany. The colors
() 13 don't show through but I think bluish -- I think a brick is 14 another one.
15 The only other point I would make --
16 DR. SIESS: You mean each reactor has-its own?
17 MR. ROBERTS: There are several types, depending 18 on PWR, BWR, and size of cask. You'll notice caster 5 is 19 probably the largest. It's probably 10 metric tons of 20 uranium. 21 PWR assemblies.
21 DR. MOELLER: This is for dry open air --
i 22 MR. ROBERTS: No. Dry in helium and it's a 23 double lid configuration.
24 DR. MOELLER: I'm sorry. In helium.
25 MR. ROBERTS: You'll notice the over model casks O
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1 have vertical fins, they are cast-on fins. In the case of 2 caster 5 it's a machining situation, horizontal fins.
3 DR. MOELLER: Is helium 5 a good conductor of 4 heat?
5 MR. ROBERTS: Yes.
6 DR. MOELLER: Plus no corrosion, I presume?
i.
7 MR. ROBERTS: Yes. And the other drawing is for 4
8 the HB Robinson three modules.
9 DR. SHEWMON: Before we look at that other 10 picture, there's 8- or 10-inch pipe coming out of the top i
11 of these things.
12 MR. ROBERTS: No. Those are the trunnions.
() 13 DR. SHEWMON: No, standing behind you. Those 14 are trunnions on the lid, too?
4 15 MR. ROBERTS: Here is the lid. Where are you 16 referring to?
17 DR. SHEWMON: The ones behind, standing up, out 18 of the top. Each one has --
19 MR. ROBERTS: Those are probably bolts that have 20 been withdrawn a little. I think. If you notice the bolt 21 structure here, you are dealing with rather large bolts.
22 DR. SHEWMON: They are hollow --
23 MR. ROBERTS: Those are trunnions on the sides.
24 Those are trunnions, if that's what you mean.
25 This particular site which I happened to have CE)
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28861.0 159 BRT (v) 1 visited is the craft work union fabrication works at 2 Mulheim and they do all the work there on fabricating the 3 castings. The castings are done -- I think there are 4 probably three foundries that are qualified in Germany, two 5 of which I visited. One is Siempelkamp and 6 Goentermann-Piepers.
7 Getting to the site-specific thing here, as you t
8 are aware we have had twc licenses out on this. I think 9 I'll probably, unless you are interested otherwise, 10 concentrate more on Surry since that is cast. The site is 11 located at the Virginia Power, Surry Power Station in Surry 12 County, Virginia, which is across the river from (v ') 13 Williamsburg, 14 The particular site for the three pads that they 15 are licensed for is about 1000 meters from the reactor.
16 Basically they're licensed for up to 84 casks 17 with 21 assemblies per cask.
18 DR. SIESS: Are they physically limited? They 19 have plenty of room?
20 MR. ROUSE: They have plenty of space.
21 MR. ROBERTS: That's all they requested for the 22 20-year period.
23 DR. SIESS: Why would the license put a limit on 24 it? Materials license --
25 MR. ROBERTS: We are required to establish a D.
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<3 1 capacity for the ISFSI.
2 Okay. Basically then, Robinson is the type 3 right now. I understand these modules have just been 4 completed at the Robinson 2 site. You have a set of three 5 modules here together which are about, oh, it's I think 22
- 6 feet across and 25 feet long and 13-l/2 feet high.
7 DR. SIESS: Three of these?
8 MR. ROBERTS: Yes. You'll notice the cutaway
(
9 shows the first one and then the steel --
10 DR. SIESS: This block. Three blocks like this 11 or just one?
12 MR. ROBERTS: No, no. One block of three.
() 13 MR. ROUSE: They authorized eight modules.
14 MR. ROBERTS: But three are all they've 15 constructed. Each of these -- these are three modules.
16 DR. SIESS: Authorized eight. That doesn't come 17 out as multiples of 3.
18 MR. ROBERTS: I know. I know. But what it i
19 amounts to is this: the outer wall is about 3.5 feet thick.
i 4
20 If they want to build an odd number, they are going to have 21 to build one module separate. They are attached to the 4
22 foundation.
23 Yes?
24 DR. SHEWMON: The dry shielded cannister is 25 basically something that is gas tight and will hold one
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-O 1 atmosphere of helium?
2 MR. ROBERTS: Half-inch thing, 304 stainless 3' poly, there are plugs, double welded. The welding 4 procedure is the inner weld is a standard helium leak rat.e 5 test, 10 to the minus 6 cc per second and the outer weld is 6 done by a dye penetrant testing technique.
7 DR. SIESS: What's the pressure?
8 MR. ROBERTS: These are specified in the tech 9 specs. The pressure is ambient pressure at the time of 10 loading, basically, for the cannister. Helium, 11 There is no leak detection system in this case 12 because the thing is welded completely shut.
() 13 On the cask --
14 DR. SIESS: Or reactor buildings.
15 MR. ROBERTS: On the casks where we have the 16 possibility of lid removal, we have metallic seals.
17 Because of the length of the elastomer seals, we don't feel 18 they will last for a 20-year period and we have a double 19 seal as we do in this.
i 20 DR. SIESS: They are loaded as in this block, 21 horizontally?
22 MR. ROBERTS: Yes.
1 23 DR. SIESS: Is the cavity lined?
24 MR. ROBERTS: They are loaded, you can basically
- 25 see a steel railing and block in there.
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1 DR. SIESS: Is the cavity lined with steel?
2 MR. ROBERTS: No. The safety is not lined with 3 steel. It's concrete. Reinforced concrete.
4 DR. SIESS: Anything in the gap or it just lies 5 in there?
6 MR. ROBERTS: Just lies there. Air comes in the 7 bottom inlets and circulates through.
)
8 DR. SIESS: It's on rails so it has an annulus 9 base around it?
10 MR. ROBERTS: That's right.
11 DR. SIESS: In to the block simply provides 12 tornado protection, missile protection --
i
() 13 MR. ROUSE: Shielding.
14 DR. SIESS: Shielding. What is the activity on 15 the surface?
16 MR. ROBERTS: Oh, I think we've got a tech spec 17 of 200 millirem or it's down around 50 at the front doors 18 and stuff.
4 19 What you've got is, remember it's not just the 20 concrete. Because you have air circulating, you do have l
21 gaps there. That's covered by these shield blocks at the 22 top. Although you can't see it here, there's -- the
- 23 pathway here is not a direct pathway through these inlets 24 and there is a concrete block mechanism shielding within, 25 in the interior. So you don't get any direct pathways.
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Y, ]
1 DR. SHEWMON: Are the dry casks of Robinson 2 about 21 subassemblies like the ones at Surry? What is the 3 relative diameter?
4 MR. ROBERTS: Each cannister only holds seven 5 assemblies. They are PWR assemblies, also 3.5 percent 6 initial enrichment and 35,000 megawatt-days --
7 DR. SHEWMON: I'm sorry, 3.5 in this case?
8 MR. ROBERTS: In both cases. The Surry's 9 ultimate is 3.5.
10 DR. SIESS: Let me get some nomenclature 11 straightened out. The steel thing is the cannister and the 12 block you call a cask here?
() 13 MR. ROBERTS: No. This is the horizontal 14 shielded module. This is the dry shielded cannister.
15 This cannister is transferred to --
16 DR. SIESS: No. You are not listening. I want 17 to get some nomenclature straightened out. The steel thing 18 that has the fuel in it is a cannister?
19 MR. ROBERTS: Right.
20 DR. SIESS: At the site. What do you call the
- 21 concrete block?
22 MR. ROUSE: I use the' term, the horizontal 23 concrete silo.
24 DR. SIESS: They call it a horizontal concrete 1 25 silo. Now there's something called cask indentation.
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1 What's that refer to?
2 MR. ROBERTS: The way the cannister is 3 transported to this module, it's loaded --
4 DR. SIESS: It's in a cask.
5 MR. ROBERTS: And there's a docking collar.
6 DR. SIESS: The cask is the thing they store at 7 the other site. You call that a cask?
8 MR. ROUSE: Cask.
9 DR. SIESS: It has cannisters in it?
10 MR. ROBERTS: No. Just loaded with fuel in the 11 assembly, in the pool area.
12 DR. SIESS: I thought I heard "cannister" used
() 13 there. I'm clear now.
14 DR. REMICK: The seven assemblies in the 15 Robinson case, there's a support structure _ that is borated?
16 DR. SIESS: It's just like a shipping cask?
17 DR. REMICK: It's a borated structure in there 18 to hold the subassembly?
19 MR. ROBERTS: In the cannister, borile sleeves, 20 guide sleeves.
21 DR. SIESS: He's asking about the caster.
22 DR. REMICK: No. This one.
23 DR. SIESS: This one? Okay.
24 MR. ROBERTS: That is correct.
25 DR. SIESS: These are subassemblies, not
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\-)
1 consolidated or --
2 MR. ROBERTS: That's right; intact assemblies.
3 DR. SIESS: At Surry?
4 MR. ROBERTS: The same.
5 DR. SIESS: It's just like you see in a shipping 6 cask, same assembly --
7 MR. ROBERTS: Basically, yes.
8 MR. ROUSE: Virginia Power is considering 9 consolidated fuel in the cask. Part of the demonstration L
, 11 information and that, of course, would double the capacity 12 of the cask.
.(). 13 DR. SIESS: Are both of these loaded - the fuel 14 in both cases is loaded vertically?'
15 MR. ROBERTS: Yes. At the pool.
16 DR. SIESS: And this one is tipped over.
17 DR. SHEWMON: Both of them are, apparently.
18 MR. ROBERTS: No.
19 DR. SIESS: Caster is cited vertically.
20 MR. ROBERTS: Let me pass this around. It 21 showed up in Power Engineering but it's the type of 22 procedure by which the cask would be moved from the fuel 23 building area at Surry out to emplacement. Actually the 24 cask will be no more than a foot off the ground at a time.
25 It stands vertical.
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2'8861.0 166 BRT-O 1 DR. SHEWMON: This thing with the pretty 2 circumferential slots stand vertically so the slots are the 3 wrong direction when it stands up?
4 MR. ROBERTS: The slots are horizontal when it 5 stands vertically.
6 DR. SHEWMON: Why did they go to the expense of 7 machining them in?
8 MR. ROBERTS: It works. That's all we can say.
9 It does dissipate the heat.
10 DR. SIESS: I think that's designed as a 11 transportation cask, normally horizontal transportation.
12 DR. SHEWMON: Maybe radiant heat is a lot of it.
() 13 DR. REMICK: Do you have any feel for the 14 relevant economics of the two types of designs?
15 MR. ROBERTS: I haven't, really. We haven't
~
16 gotten into it. .I don't think the costs on some of these i 17 initial things are representative. Plus in the case of the 18 caster, you had the rate changes in the dollar versus the 19 deutschemark. So it's really not too easy to tell at this o
20 point.
i
- 21 DR. REMICK: Am I correct, inferring from what 22- you said today, that there's nobody currently licensed to 23 store fuel that has been consolidated? Pins that have been f 24 consolidated?
- 25 MR. ROBERTS
- Let me say this. Under 50.59
- ()
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l there has been a demonstration at Oconee by Duke. So it 2 has been done there. And Tom, you can tell them, there's 3 been some demonstration at West Valley.
4 But again, these are not in the context of, like 5 Millstone 2 application where you are going to expand your 6 spent fuel pool ppplication capacity, in two-story fuel, 7 that has not been licensed yet.
8 DR. REMICK: I thought we were farther along. I 9 thought people had been doing it but I infer it's not 10 routine, not done yet.
11 DR. SIESS: MRS will load the fuel horizontally; 12 is that right?
() 13 M R'. ROUSE: In the cannister; yes, sir. That's 14 the present concept.
15 DR. SIESS: Is some dsmonstration on that going 16 on somewhere?
17 MR. ROUSE: Not yet.
t 18 'MR. CLARK: The demonstration is going rather 19 slowly. As I say, we want to stay; attuned to what is going 20 on. We really don't have much information yet.
21 MR. ROBERTS: Perhaps we can just get into more 22 or less what we do in the site-specific review.
23 Obviously we have three major areas of review:
i 24 safety, environment and safeguards. I'm going to i
25 concentrate on the safety here.
i fq
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l l
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28861.0 168 BRT 1 Fritz was involved in the environmental and Carl 2 can speak to the safeguards later. He's on the program.
3 In the case of the Surry case, this is what I 4 guess you'd call more or less a pure one. We received a 5 topical report on the cask and evaluated that and issued a 6 letter of approval pursuant to the cask so when we came to 7 the site-specific application, we were looking at more of 8 an approach to see if this cask was suitable for this site.
9 If it fell, if the credible events fell within 10 the parameters and accident scenarios, operations that we 11 had looked at for the cask.
12 So our first step off, basically, involved site f[ ) 13 review which involved going back through the safety 14 analysis report for the site and ultimately for going to 15 site visits. Both in the case of the Surry case and I 16 think the Robinson as well, basically this was -- worked 17 out to be about three visits. The reason I say three is 18 the first people to go down were basically people involved 19 with the environmental review, in cross-checking on various 20 site aspects. The safeguards people have gone through and 21 visited the site, too. And at the end of our review when 22 we were basically, essentially complete, based on the 23 submitted information we did go down through the sites to 24 verify, essentially, what we had been told and also to see 25 if there was anything else that we saw that might have an n
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O 1 impact.
2 This, in fact, is usually -- this is the case in 3 some cases. I'll give you a couple of minor items. They 4 are minor items, basically.
5 In evaluating the transport path from the 6 reactor to the site, we did notice a small upward grade 7 area as you were coming out of the immediate reactor 8 vicinity area near diesel fuel oil tanks. We provided the 9 safeguard of a bulldozer behind this device, when it rolls 10 away. That way -- and also a check of the fuel lines 11 underneath as it crosses over, that sort of thing.
12 Robinson, there was some new construction planned. We f~D
%) 13 cross-checked that.
14 These are the types of things that happen.
15 Basically we determined the site phenomena 16 severity and we cross-checked that. Then you do a 17 comparison of the site and the cask to make sure that the 18 site falls with in the parameter and determine whether or 19 not the design is acceptable or whether modifications have 20 to be made.
21 Then you look basically at the aspect of 1
22 transportation. As stated earlier, we picked this up 23 basically at the time we are leaving the fuel building and 24 go out to the storage area.
25 However, other items involved with the l (2) i i ACE-FEDERAL REPORTERS, INC.
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/~T k) operations within the reactor building and the overall site, 1
2 there is a 50.59 review by the Reactor Safety Committee 3 where things are documented and we are assured basically 4 that procedures and so forth are developed and everything 5 is in line.
6 This is also where we get into the determination 7 that the impact of one facility on the other is negligible.
8 Finally you look at the storage aspects, 9 monitoring, health and safety and determination of 10 licensing conditions for this particular application.
11 That's basically the approach in both cases.
12 The Robinson case, there were some significant
() 13 design changes by the Applicant. Because of a number of 14 factors, including the IP-300 cask resulted in the loading 15 of the thing being a pull, hydraulic pulling mechanism from 16 -- which meant you had to run a hydraulic pulling mechanism 17 through the rear of the module there so there's a sheer 18 plug there at the back rather than having a plug mechanism 19 that pushed it out of the cask and then to the facility.
20 The other, the drop and burn-up were increased.
21 And those were the major changes and those were factored in 22 the report which we already showed you and compared with 23 the earlier design. And then, ultimately, everything was 24 written up and as I say, the license division -- the tech 25 specs. And that's basically the approach.
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l DR. SIESS: How many volumes is their SAR?
2 MR. ROBERTS: Well, one to two volumes in each 3 case.
4 DR. SHEWMON: Someplace in here I heard about 5 impact limiters. Those are only during transportation that 6 you have those?
7 MR. ROBERTS: Yes.
8 DR. SHEWMON: This is some crushable material of 9 some kind.
10 MR. ROBERTS: As you'll notice here when we 11 evaluated the caster 5 and top core report, we evaluated it 12 including impact limiters if they chose to raise the cask
() 13 more than 15 inches, up to a total of 5 feet. We had a -
14 limit of 5 feet operationally.
15 This was a site modification. Virginia Power 16 said we will move the cask vertically with this mechanism 17 and limit it to less than the 15 inches so we need not use 18 the impact limiters. Of course we have evaluated the cask 19 without the impact limiter for tipover and that sort of 20 thing. So basically -- all bases are covered.
21 DR. SIESS: How far apart are they spaced?
22 MR. ROBERTS: 16 feet, center to center.
23 DR. SIESS: How tall are they? So if one falls, 24 it won't hit the other one?
25 MR. ROBERTS: Basically.
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'BRT 1 DR. SIESS: The chances of doing this (gesturing) '
2 I guess are pretty slim. It would take a pretty good 3 earthquake.
4 Any other questions?
5 DR. SHEWMON: You said you had one more 6 application for this? Or by looking at the gray book you 7 deduced that you were likely to get one more pretty soon?
8 MR. ROBERTS: We know that Duke Power has gone 9 out with a request for a proposal from cask vendors and a 10 number of vendors apparently respond. But we are waiting.
11 DR. SIESS: Okay?
12 DR. SHEWMON: Yes.
The safeguards licensing in Surry 1() 13 MR. SAWYER:
14 was carried out as shown in the handout you have before you.
15 We asked the licensee to prepare his protection plan 16 showing how 73.50 requirements would be met.
17 From our point of view, not necessarily that --
18 not necessarily from the licensee's, we view 73.50 as a 19 subset of 73.55, that is, the reactor protection 20 requirements.
21 We knew that the licensee knows he has to 22 satisfy the 73.55 requirements -- or assume the 73.53 23 requirements would be reasonably simple to satisfy. We 24 were also aware that numerous security assets already in 25 place at Surry to meet 73.75 can be extended and used to o
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b 1 meet 73.50. Among these are structures such as the 2 hardened alarm station.
3 Personnel, we have.a guard force on site. And 4 finally, soft assets such as their contingency plans and 5 numerous security procedures.
6 In due course the draft plan was submitted for j 7 safeguards review and we reviewed the draft against 73.50, j 8 but there were iterations and very shortly the' plan emerged 9 that was satisfactory to us and the license does, or will-l 10 contain a condition requiring the licensee to carry out the 11 plan.
i i 12 DR. SIESS: Why is that necessary? That last
() 13 necessary? Is that always a condition of the license, that j 14 they do what they say they were going to do?
15 MR. SAWYER: It's my understanding that the 16 license contains a clause, an operative clause, which says:
l 17 Carry out the terms of this plan that you have provided.
18 DR. SIESS: Only in connection with the 19 safeguards plan?
20 MR. SAWYER: And we inspect largely according to 21 the plan that we've all agreed to.
f-22 DR. SIESS: It just references that specific I
23 plan by name and date there?
j 24 MR. SAWYER: That's my understanding.
I 25 DR. SIESS: Why don't I see a similar item for (2) t i
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V 1 Robinson?
2 MR. SAWYER: Well, at Robinson the structures 3 containing the spent fuel are located within the protected 4 area and we considered it to be not really an independent 5 facility but rather just an additional component of the 6 reactor.
7 DR. REMICK: Surry was outside the normal site 8 area, adjacent to it. Robinson was inside the reactor area.
9 MR. SAWYER: In the Robinson case there was 10 simply a modification to the plan. The Robinson 11 representatives provided us information showing that the 12 cask -- that the fuel would be protected in a reinforced
() 13 concrete storage module and would be in a protected area, 14 that accession would be controlled, and that all the 15 special equipment needed to gain access to the storage J
16 casks -- that's transportation, too -- would be secured to 17 prevent misuse. We were of course aware that the module 18 was protected by the full set of reactor protection i
19 measures already in force. On that basis it was determined 20 the proposal was satisfactory and accepted.
21 DR. REMICK: In the case of Surry, did they just t
22 expand their security base to accomplish this? Or,is it 23 separate?
24 MR. ROUSE: Separate. About a half mile away.
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V 1 sort of, .they have a contingency low-level waste s'orage t 2 structure down there. As I say, about a half mile from the 3 protected area.
4 MR. ROBERTS: I think I left a misimpression.
5 As I said, these ' casks are on the 16-foot centers. They 6 are 8 feet in diameter. So they are not 16 feet apart. I 7 think the impression that they would not necessarily come 8 in contact with each other if one fell --
9 DR. SIESS: Have you investigated the domino 10 effect? -
11 MR. ROBERTS: We haven't really gotten into it.
12 DR. MOELLER: Excuse me. Help me on that. They
() 13 are not touching one another? There's roughly 8 feet 14 between them?
15 MR. ROBERTS: If you were looking at the surface 16 of one to the surface of the other, it would be basically 17 about 8 feet.
18 DR. REMICK: What determined that spacing?
19 MR. ROBERTS: I think it was just basically an 20 array chosen with an examination of the heating effects and 21 so forth and -- I think really the dominant area was the 22 radiation at a distance to the fence, possibly. It does 23 allow for some shelf shielding in various directions.
24 DR. REMICK: How about the transporter; did it 25 need some space?
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1 MR. ROBERTS: That's the other thing. You go up 2 in two rows.
3 DR. SIESS: Suppose one of them fell over, could
~4 they get in to pick it up?
5 MR. ROBERTS: They should be able to get in to 6 pick it up. They might have to move one of the upright 7 ones away and work'their way in.
8 DR. SIESS: How many do they have?
9 MR. ROBERTS: Potentially up to 84, 28 per pad, f
10 The pads are 280 feet long.
11 DR. SIESS: What's the array?
12 MR. ROBERTS: 2 by 2 by 20 along the pad, 2 by
() 13 14.
14 DR. SIESS: They get it from either side then?
15 MR. ROBERTS: Yes.
16 DR. SIESS: Okay. Item 5, or V, as it says here 17 on the agenda, has been canceled. Most of what Mr. Chapell 18 said dealt with the transportation aspects which is not the 19 function of this Subcommittee but is the function of 20 another subcommittee that will meet at an appropriate time l
21 to deal with it. There was some misunderstanding on my f 22 part. Dr. Shewmon was interested in it and he had lunch
[ 23 with Mr. Chape11 and took care of that, which was sort of 24 outside the scope of immediate concern.
l 25 MRS update.
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V 1 DR. REMICK: I was just thinking, I wonder if a 2 couple of thousand miles from now they'll discover Surry 3 and think of it as a new Stonehenge, wonder what those 4 things are for.
5 DR. SIESS: I'll tell you a little story on that.
6 One of my former students was building a building that had r
7 a very large concrete mat. They were worried about the 8 temperature rise in the concrete so they were going to cool 9 the concrete with ice and so forth but they made a test 10 cube of about 10 foot on a side, dug a hole, cast the 11 concrete in it, bedded some thermocouples in it, the dirt 12 insulated it, like a large expanse.
() 13 I said, what did you do with it when you got 14 through with it? Did you break it out?
- 15 No, we just filled the hole up.
16 Have you ever thought what the archeologist is 17 going to think 1000 years from now when they dig up that i 18 10-foot concrete cube?
19 MR. ROBERTS: It's good for a dissertation.
20 MR. CLARK:- MRS update. There are actually two 21 handouts. There's one just two pages and then one with 22 several pages.
- 23 I wasn't sure, Dr. Siess, if you wanted to go 24 back through an explanation of the MRS? That's what the 25 thicker one is about.
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28861.0 178 BRT O 1 DR. SIESS: I think not. If you get questions, 2 let's use it to refer to. We got a pretty good description 3 of that in the previous Subcommittee meeting and although 4 we might have some people that weren't, I would rather let 5 them ask questions.
6 MR. CLARK: The purpose of putting down 7 something called MRS update in case something happened, I 8 would tell you about it. Nothing has happened. It's still 9 in the Sixth Circuit Court of Appeals and that's where it 10 was in March so I can't really say anything.
11 The one thing that I had prepared that I thought 12 you might be interested in, really, is the second page.
() 13 It's a two-page handout.
14 If you look at that, this is my perspective of 15 beyond design basis for a place like the MRS.
16 What I've got, it's like a matrix, three 17 different kinds of natural phenomena threats, and then the 18 casks which are outside the receipt and handling building i
19 and the cells, which are really the handling building.
20 Talking about fuel, it's either in a cask, in a cannister, 21 on a pad outside, or fuel in storage, either in a cannister 22 or not in a cannister, in thick-walled cells.
23 The question is, if we went beyond design basis, 24 how do we think things stand? You had just asked about 25 flooding but I wanted to cover the topics in some fashion (2) .
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28861.0 179 BRT t-Q) 1 to give you our perspective on it.
2 For the flood the casks, as I '. aid before, just 3 sit there. There's no criticality. We've dealt with that 4 question. There's no criticality. You have water around 5 them.- That shields them.
6 Inside the cells, as I think I mentioned before, 7 this is where -- DOE has gone to a great deal of trouble to 8 make these dry cells. You cannot -- there are, for 9 instance -- there is no access for any fluids of any kind 10 to get into the cells except under very special conditions.
11 There's no fuel -- if they wanted to decontaminate the 12 cells they have to administratively hook up pieces and what
() 13 have you and then go ahead and hook up the cells. Normally 14 there is no way for fluid to get inside the cells.
15 DR. REMICK: I assume if you intentionally put 16 water into the top vents, it would run out the bottom vents 17 on these? I'm thinking specifically of Robinson.
10 MR. CLARK: I'm talking about a very large 19 facility.
20 MR. ROBERTS: You are correct, however, on 21 Robinson.
22 DR. SIESS: I thought there was some fuel in the 23 receiving area that was stored in relatively large 24 quantities that somebody thought might have a criticality 25 problem.
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4 28861.0 180 BRT O- 1 MR. CLARK: .Yes. You note I say criticality.
2 DR. SIESS: You said in cells, watertight and so i 3 forth. Is everything in cells?
i 4 MR. CLARK: Yes. Everything is in cells.
5 DR. SIESS: As soon as the stuff is brought.in, i 6 it's put into a cell.
7 MR. CLARK: The transport cask comes underneath 4
8 the cell. That's all shielded and the fuel is lifted out 9 and from then on it is inside the cells.
10 DR. SIESS: There is no interim fuel utorage J
11 area?
12 MR. CLARK: Well, there could be a one- or 13 two-day lag for the transport cask.
{)
14 DR. SIESS: That's just the cask.
s 16 concerned if we considered that a problem, they would put i
17 in poison racks or something, so even if it were flooded j
18 there couldn't be criticality. I would prefer not to do
, 19 that because I don't think it's necessary in this case.
20 DR. SII:SS: Something we could calculate.
! 21 MR. CLARK: For earthquake, which we did have a j 22 long discussion of, for the casks, again, the cask tips
! 23 over. And this is not as nearly severe an impact as the l- 24 cask drop analysis which is not the same as the i
3 25 transportation analysis, but exceeds what would lap in an i (1) i ACE-FEDERAL REPORTERS, INC.
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1 earthquake. It's 5 feet, that we are talkiiig about.
2 MR. ROUSE: It might be a little different in 3 the MRS. It depends on the means of moving the cask. They 4 plan that MRS right now, some huge track-type vehicle. It 5 would depend on how high the thing lifts the casks.
6 DR. SIESS: The MRS cask is a concrete cask, 7 steel lined and then cannisters, sealed cannisters inside s
8 that.
9 DR. SHEWMON: Reinforced concrete?
10 DR. SIESS: Yes. A lot of it.
11 DR. SHEWMON: A lot of rebar?
12 MR. ROBERTS: A lot of rebar.
() 13 MR. STEYER: A lot of weight.
14 MR. ROUSE: Each cask is expected to weigh 220 15 tons.
16 MR. CLARK: Let's take a step backward. We have 17 not done a detailed review. We reviewed it as much as wo 18 could based on the time we had so I couldn't claim we have 19 done all the analysis, but this is my perspective on the 20 way I think it will turn out.
21 DR. SIESS: In that other handout is a picture 22 of the cask.
23 DR. SHEWMON: What does the first page of that 24 look like?
25 DR. SIESS: Sort of blurry.
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-BRT O 1 MR. CLARK: Then we say for earthquake in the 2 cells, the same thing. It's dry; heavy walls. It's based 3 on, I think I mentioned this last time I was here, based on 4 analysis of other facilities beyond what would be 5 considered design basis earthquake.
6 You can go well beyond design basis and still 7 have the structure stand. Probably talk up in the range of 8 .8 g.
9 DR. SIESS: Is there a crane in the cell that 10 might fall on fuel? So what? It's shielded.
11 MR. CLARK: And also what kind of a release are 12 we talking about. MRS has five filters in series. Even if
() 13 you have particulate, you have a long train before anything 14 can get through.
15 DR. SIESS: What about the cooling systems or 16 support systems that could be damaged by an earthquake?
17 MR. CLARK: We are looking at --
18 DR. SIFSS: Or flood? Any support system that's 19 essential that could be damaged by an earthquake or flood 20 or tornado?
21 MR. CLARK: One question we had had to do with 22 the effect of earthquake or whatever it was, flood, on 23 electrical power supply because there's forced air cooling 24 for the large lag cooling area and that question is not 25 resolved yet as to whether that would be required.
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- n 1 DR. SIESS: Oh.
2 MR. CLARK: Then the question would be how hot 3 would you get in that event to melt down fuel or something i 4 before anything comes out. You have cannisters, fuel 5 cannisters with fuel inside it. We are talking about very 6 high temperatures that would have to be achieved before 7 anything could come out. We haven't done the analysis, but 8 oven in that event --
9 DR. SIESS: These are things that will be looked 10 at.
11 DR. SHEWMON: If you feel that's required to get 12 anything out of it, why is it you need five filters in
() 13 series.
14 MR. CLARK: I didn't say we needed them. I'm
- 15 telling you what they've done, the present design.
16 MR. ROUSE: The five HEPA filters is probably a 17 little overkill, but you are also talking about the u
! 18 consolidation operation, breaking the rods at that time 19 when they are outside of the cannister.
20 You can get some particulate. You are going to 21 scrape off crud from the rods. Five HEPAs are a lot of 22 HEPAs.
1 23 DR. SHEWMON: Five is better than two?
24 DR. SIESS: Well, if you apply ALARA, and if 25 adding two filters makes it readily achievable, I guess you i
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l do it.
2 DR. SHEWMON: There are costs of pushing air 4
3 through those damn things.
4 MR. ROUSE: As a point of reference in the past, 5 we typically required three HEPAs in filter for a plutonium 6 facility. There's a little --
7 DR. SHEWMON: There's some perceivable risk 8 there.
9 MR. CLARK: All the filters don't meet all the 10 requirements, technical requirements, but they are still 11 there. For instance they have filters inside.
12 For tornado, John did mention before missile
(~)
,~j 13 analysis which we are reintroducing because it was excluded 14 because of wet storage. Now with dry storage, especially 15 for the casks, one would have to look at that possibility.
16 I must admit that I do not know what kind of 17 missiles we would be talking about beyond design basis, if 18 that is what was suggested.
19 DR. SIESS: Beyond what?
20 MR. CLARK: This chart I'm looking at that I i
21 have prepared, I'm talking about things that could occur 22 beyond design basis.
i 23 DR. SHEWMON: Design basis was a 146-mile-an-hour l
24 carbon.
25 DR. SIESS: I doubt there are any missiles O
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1 beyond design basis.
2 MR. CLARK: The question is how far beyond that 3 did you want'to go?
4 DR. SIESS: We never worried about tornadoes 5 beyond the design basis because it's only the floods and 6 the earthquakes.
7 MR. CLARK: Certainly there's a lot of walls 8 intervening between the fuel and any missiles so it would 9 not be any problem.
10 DR. SIESS: So even so, the walls should be 11 analyzed for missiles.
12 The Staff, NRR Staff has a simple rule on
() 13 concrete walls. If they are more than so thick, you don't 14 have to worry about missiles.
15 MR. CLARK: That's about 2 feet thick.
16 DR. SIESS: I think it's 2.5. I'm sure these 17 are thicker than that.
18 MR. CLARK: The cell walls are 5 feet thick but 19 there's an external wall too in the large structure.
20 DR. SIESS: And then there are supports. If 21 loss of support systems could be serious -- usually it 22 won't be because you can bring in -- do something about it.
23 Okay.
24 MR. CLARK: The conclusion I draw from this is 25 even for criticality, it's a simple fix. I don't believe i
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28861.0 186 BRT' 1 it would require-it but I don't think it's necessary to 2 talk about risks beyond design basis because it's already 3 well protected.
I 4 DR. SIESS: It's not something you put in the 5 regulations but it's something for people to think about.
6 DR. REMICK: I assume from what you said that 7 airplane crashes of any size airplane is not a problem at 8 the MRS itself?
9 MR. CLARK: We haven't looked at'something like
, 10 very large aircraft. We haven't looked at it with renocct 11 to probability but the airport nearby is a small one.
12 DR. REMICK: Switching back to the modules. I
) 13 read there's a small airport nearby. Are those modules 14 adequate for larger aircraft located elsewhere?
15 MR. ROBERTS: Yes. In fact I said this morning, 16 you'll remember, looking at the tornado missile helped in a
-17 way?. The tornado missile eclipses the light aircraft 18 impact because of the airport 2.5 miles away.
19 DR. REMICK: How about the burning fuel 20 incineration on impact?
21 MR. ROBERTS: We did consider that. You'll i 22 notice there are some waste oil tanks. They are diked 23 around that area but there's also a fire brigade grade and l 24 so forth and basically the only thing you would be worried 25 about is if there were some oil seepage or something --
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- 1. DR. REMICK: I say more of an air crash and the 2 fuel of the plane --
3 MR. ROBERTS: This is a small airport. We are 4 talking Sesna in a 172, probably. Basically you don't have 5 that much fuel. 3-1/2 feet of concrete on the outer area, 6 even with the inlets and outlets it's not serious.
7 DR. REMICK: Suppose you take the outlets at 8 Robinson and want to locate them near the Atlanta airport 9 or something, do you think they are adequate for large 10 planes? Both impact --
11 MR. ROBERTS: My wife has been an aircraft 12 investigator for many years. I can't speak from my own
() 13 knowledge. But if you take a look at a large aircraft 14 accident, unless you are looking at an engine block area, 15 it's aluminum and so forth, it just disintegrates across a 16 lengthy distance. You are not talking necessarily hard 17 impacts. You might move things or something but I don't i
I 18 think, for these types of modules, that you are talking l
19 serious damage to fuel inside -- to the cannisters.
l 20 We would certainly have to look at that if we l 21 were on the path --
22 DR. SIESS: There's the fire from the aircraft l 23 fuel. The shipping cask type has been subjected to fire I 24 checks.
25 MR. ROBERTS: Yes. And so have the casks that O
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() I we have looked at. Generally speaking, we have taken the 2 transportation or at least the applicants have supplied a 3 transportation-type fire, the half-hour 1800 degree. That 4 approach.
5 DR. SIESS: For the cannisters?
6 MR. ROBERTS: For the cannisters? No, we 7 haven't. They are, you'll notice, in transport or in the 8 IP-300, of course, and once they are in the modules, they 9 are sitting there and there's really -- I can't see -- you 10 know, number one, the transportation cask fire is beyond 11 design basis for the reactor site to begin with. But for 12 these types of modules I just think it's not a suitable
() 13 fire. We did look -- realistic.
14 DR. REMICK: Those air vents are fairly small 15 from the picture.
16 DR. SIESS: Concrete is a pretty good insulator.
17 Has anybody looked through this stuff who has 18 any questions about MRS? Keeping in mind all they have is 19 a conceptual design. The kind of sketches you see in here 20 are about as detailed as you have gotten, isn't it?
21 MR. CLARK: Dr. Siess, I did make available last 22 time copies of the report. I have a couple of more copies 1
23 if somebody would like to have them.
1 24 DR. REMICK: I would appreciate a copy.
i 25 DR. SIESS: Those weren't sont out, were they?
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2 DR. SIESS: Pass tnem around. I have one. It's 3 on MRS.
4 DR. REMICK: Are we not going to go through the 5 larger one? Oh, that's the one --
6 DR. SIESS: We went through the essentially at 7 the last meeting.
8 DR. REMICK: Will you give us a minute to scan 9 through here, then?
10 DR. SHEWMON: The environment would be air, 11 according to this plan; is that right? Cask environment?
12 DR. SilEWMON : Yes.
(O wJ 13 MR. CLARK: Yes.
14 MR. ROUSE: The cannisters, however, are inert.
15 DR. S!!EWMON: So what I see in something like 16 this is a leak detector outside the cannister and inside 17 the cask?
18 MR. ROUSE: That's correct.
19 DR. SilEWMON: That's what I wondered about, some, 20 in the ones you have approved. There is none. You trust 21 welds and pipe, is basically your response?
22 MR. ROBERTS: That's correct. Stainless steel 23 pipe and the welds, the welds are helium leak checked. The 24 inner one and the outer one is checked, too.
25 DR. REMICK: I have no questions.
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28861.0 190 BRT 1 DR. SIESS: Item VII?
2 MR. ROUSE: Yes. I have no handout on this but 3 I did want to wind up our day with you to inform the 4 Subcommittee at this stage about some thinking that has 5 been going on for some time about some future rulemaking.
6 The Nuclear Waste Policy Act, in Section 218-A 7 contemplated this rulemaking. By directing DOE to 8 demonstrate certain dry technologies to drive licensing 9 information such that the NRC could provide approvals of 10 these technologies without, to the extent practical, it 11 says, without site-specific approvals. The reason that's 12 in the Wasto Act has some background but fundamentally it
() 13 comes from the sense of looking at dry storage casks. One 14 is capable, as we are doing now with topical reports, of 15 looking at those relatively independently of the site, nor 16 safety.
17 The concept that is coming up is very analogous 18 to Part 71, where, under Part 71 they approve a cask design 19 or a shipping package design and then there is a general 20 license, in Part 71, for a person authorized to have that 21 material and who meets certain specified conditions of the 22 gonoral license to use that cask, simply by registering it. '
23 We think that's entirely feasible for this storage cask. ;
24 Wo would have a certification program akin to -- well, it's 25 really a formalization of the topical report review that wo O
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'a 1 do now, but we'd actually put it in the rule, put in the 2 criteria for getting certification of the storage cask, 3 combining that with a utility, reactor operator who meets 4 these conditions, and then they can use that cask simply by 5 registering with us.
6 The general conditions, conditions of the 7 general license, would follow the kind of evaluations that 8 we saw in the SAR. Looking for independent, written 9 evaluations which could be checked by the inspector to make 10 sure they were done before he actually -- we think that's i 11 entirely feasible. It has not been formally endorsed, t
12 certainly by the EDO yet, but we are working on a
() 13 rulemaking package that would probably go to the EDO sometime 14 later this year and over this next year, then, we would be 15 working on this rule.
i 16 DR. SIESS: In other words, you would license, 17 certify a cask for storage just like you certify a cask for l 18 transportation.
19 MR. ROUSE: Right.
! In order to use it they would have 20 DR. SIESS:
21 to meet certain site criteria. The cask would be designed 22 for envelope earthquake. And the general license will l 23 cover such things as training and certification of people?
i 24 MR. ROUSE: That's correct.
25 DR. SIESS: All it would do is eliminate the O
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2 MR .' ROUSE: Eliminate the site-specific license 3 process. We think that's -- we've gained enough experience.'
4 We think it's feasible. There are some hurdles to go 5 through. I wanted to mention it to the Subcommittee. It's 6 clearly an area that we'll be back with you on very early 7 in the game to get your advice and assistance.
8 DR. SIESS: When I look at the Surry SER, it 9 seems to me that's essentially what you did there?
10 MR. ROUSE: Just about. l 11 DR. SIESS: You said the cask has been the 12 subject of topical reviews, except it wasn't as legal.
() 13 That makes a lot of sense.
14 DR. REMICK: Except the certifications, you need 15 to do that case by case. >
16 MR. ROUSE: The certification would be looking 17 at the tender, here's my cask.
18 DR. REMICK: Design certification --
19 DR. SIESS: But if somebody else came in with 20 the same cask, they could simply reference the same topical 21 report.
22 DR. REMICK: But not currently.
23 MR. ROUSE: They can reference the topical but 24 the regulations still require the specific application, 25 opportunity for hearing. It would eliminate that.
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1 DR. SIESS: It would eliminate a lot of -- you 2 can say I reviewed that topical once, I don't have to 3 review it again but it wouldn't be as clean, legally.
4 MR. ROUSE: That's correct.- One point I want to 5 add there that's very important, early this morning we 6 talked a little bit about storage versus transportation.
7 This certification process for storage casks, with a few 8 exceptions, is something we would have to look at for 9 storage that we might not for transportation. By and large 10 if a cask were acceptable for transport it would be )
11 acceptable for storage. The vice versa wouldn't hold.
12 DR. REMICK: Have you had a chance to think what
() 13 that rulemaking would look like? Is it by comment or 14 legislative hearing? Adjudicatory hearing? When you say 15 rulemaking?
16 MR. ROUSE: By comment.
17 DR. REMICK: By comment. Do you think that 18 would fly, legally?
19 MR. ROUSE: Yes. We have talked with our legal 20 people.
21 DR. REMICK: On the design certification for 22 standardized plants, basically the Staff is saying that's 23 not an acceptable alternative -- rulemaking by comment.
24 DR. SIESS: But you are substantively doing the 25 same thing with a topical report. I O
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1 MR. ROUSE: We have the analogy of Part 71 in 2 front of us. We are talking about a less complex system.
3 I think that's the difference.
4 We haven't had -- Bill Olmsted said you've got 5 some difficultion with getting it down on a piece of paper.
6 We certainly recognize that. But he didn't throw up any 7 legal roadblocks.
1 8 DR. REMICK: As I say, the NRR Staff is going 9 through a rulemaking proposal for standardized plants for 10 design certification and they have various alternatives for 11 the rulemaking. The Staff has concluded that that is not 12 one of the alternatives. But it is different, I agree.
() 13 MR. ROUSE: I don't say -- we may get that 14 advice as we go further down the road. I hadn't 15 contemplated public hearing and everything. But I think 16 it's worth pursuing. It's a way to streamline the 17 licensing process per se. And yet let us focus on what's 18 the real safety issue and that's the piece of hardware.
19 That's about all I wanted to say about that. I 20 just wanted to give you a forewarning we are going to be 21 with you on that.
l 22 DR. SIESS: Anything else you want to take with 23 the Staff? I want to hold an executive session which is 24 completely open and I suggest you stay on what do we do 25 next, before we get into that.
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28861.0 ' 195 BRT x,,/ . i 1 First I want to thank you, it's an excellent 2 presentation. You had all the people here to answer any of 3 the questions we came up with, which doesn't always happen.
4 It's very nice to have it. And we appreciate it. ,
5 I would like to talk to the Subcommittee. I 6 the ght/we needed to review Part 72, not because of3any 7 memorandum of understanding or any of that stuff, but 8 simply because, if weodo review the MRS and the Staff is:
9 going to review the MRS under Part 72, if in the course of 10 our review of the MRS we find something we don't.like about s
11 .72, it's not a very good time to bring it up.
12 So I think we should look at Part 72 from that b) 13 point of view: it will be used for the MRS, and are we 14 satisfied with it that it can be used there with no problem.
15 And we may want to look at it from another point of view, 16' that it may be used for another ISFSI, say Duke Power, 17 Oconee, and if we reviewed that ISFSI, we would have the 18 same situation.
19 So I guess one question to ask is do we think we 20 ; should be reviewing ISFSIs, which we have not been doing, 21 ftwhich is not required of us by.the former Chairman 22 Palladino's letter to review thos'e things relating to the 23 National Waste Policy Act because they do not come under 24 that. The MRS does come under.that, to the extent that 25 that letter indicates.
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'l I guess another way of putting it is given we 2 would be reviewing ISFSIs, and we would be reviewing the 3 MRS, do we have any problems with Part 72 of such a nature 4 that we need to call them to the Commission's attention at 5 this time? That might be the place to start. If we have 6 got no problems in Part 72, the other questions are -- not 7 answered but they are moot for the purposes of this mooting.
8 DR. REMICK: I see them as separate questions in 9 my own mind. On the ISFSI, my own feeling is no. I don't 10 think we should be reviewing those.
11 When it came to Part 72, if you asked me at the
.12 beginning of the meeting I would have said no, but on the
() 13 other hand I'm a little concerned on the seismic and so 14 forth and some modest concerns about the training wording.
15 I'm-one who doesn't like to be writing a lot of letters if 16 it isn't necessary. I do see those as separate issues.
17, DR. SIESS: Mr. Beratan indicated to me that he 18 would like to take another crack at the seismic.
19 MR. ROUSE: He told me that.
20 DR. SHEWMON: It seems to me as long as we are 21 talking about on-site ISFSIs, and I guess ISFSIs, in 22 general, I can't imagine they are a substantial risk to the 23 health and safety of the public so I don't get too excited 24 about reviewing them, though I found this interesting.
25 It's one of these things that is going on that I had not
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2 DR. SIESS: I think what you are saying, Paul, 3 is what I would say. After'this, I feel a lot better about 1
i 4 not having'done it. We haven't missed anything.
! ~5 DR. REMICK: You can always review for I
i 6 ' information purposes. I mean, occasionally.
7 DR. SIESS: We have a good picture of what has 8 been done and I feel rather comfortable with it and with 9 the way Part 72 would apply. '
i~
10 I think MRS is going to be a bigger problem, 11 simply because its focus is a lot larger and maybe because 12 it involves DOE.
() 13 Dade?
14 DR. MOELLER: I agree with what has been said.
15 I do not think we should be reviewing the ISFSIs, the same 16 at we have not been reviewing, you know, consolidation of 17 spent fuel pools.
18 I believe that the points that Forrest brought i
j 19 up or that he has just summarized, a couple of items are 20 'important, the training in that particular section, Chet, 21 that you reviewed and in a similar manner at some point I 22 would like to see the 41 CFR -- 40 CFR 190 corrected.
23 That's not their problem but it's still there.
24 As far as the letter is concerned, I gather the 25 Staff, from what I have understood in interacting with them,
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I would prefer to have heard the message here and let that be 2 the message. On this particular issue. Rather than 3 patting it down in writing. The writing, I gather, is 4 really not necessary and it can cause you a lot of extra 5 work.
6 DR. SIESS: Well, I'm not so sure of that.
7 I don't think it would cause any particular 8 problem if we wrote a letter pointing out certain areas 9 that we thought would be approved in Part 72. It's not a 10 requirement, as you know, to respond to those. The letter 11' goes to the Commission. I'll ask you to respond to it. If 12 you accept our recommendations, you can, and if you don't, 13 you have to argue with them.
( ')
14 MR. ROUSE: I have no -- I'm sure I speak for us 15 -- we have heard you. Leon says as soon as he's back from 16 his trip, he's going to try to rewrite that. I have 17 already chatted with John and Tom here to see if we can dig 18 out that old one, compare it with what they are doing in 19 reactors, maybe update that, use it as input, either for 20 the rule in itself or at the very least hand it to DOE, 21 which we've handed them a lot of other things, and said:
22 As you go forward, be aware these are kinds of things we'll 23 be expecting from you.
24 So I've taken both comments.
25 But as far as a letter, fine.
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28861.0 199 BRT 1 DR. SIESS: I understand the the seismic 2 training issue. I'm not sure I understand Dade's 3 completely but let me try something.
4 I think if we were reviewing MRS next month, 5 next year -- maybe both -- the seismic issue would be clean.
6 What's in there now wouldn't bother me because it's going 7 to be that kind of a site.
8 The training issue would come out in the review, 9 whether it's in the regulation or not; right?
10 DR. REMICK: Yes. Although I don't know -- now 11 I think NMS has to be thinking that way --
12 DR. SIESS: If we were involved in the review,
() 13 we would see that we would be working with the Applicant.
14 MR. ROUSE: We hear you.
15 DR. SIESS: The question, Dade, about part what 16 -- 10 --
17 DR. MOELLER: 40 CFR 190.
18 MR. ROUSE: You have to part with Part 20 there.
19 Part 20 incorporates 40 CFR 190, and it trickles down to 20 every reg.
21 DR. MOELLER: 10 CFR 20. Put it that way.
22 I don't know that it is all that great -- all 23 that big a problem. But it is an inconsistency that I see.
24 MR. ROUSE: I want to make a correction of what 25 I said. Part 72, other than Part 20, is the only one that C)
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2 DR. MOELLER: Correct.
3~ MR. ROUSE: But the reason that it's in Part 72 4 and not in Part 50, 30, 40, and 70, is because by the way 5 they defined, EPA defined uranium fuel cycle, it-left spent 6 fuel storage out of the ball park. So we put on white hats 7 and put it in 72 and EPA thanked us.
8 DR. MOELLER: See, there's another inconsistency 9 in 10 CFR 100 for accident evaluations and even in the EPZs 10 for, you know, emergency preparedness; NUREG-0654 has this 11 same inconsistency.
12 It's not an inconsistency. It didn't exist when i 13 they wrote the thing. The same is true here. It's just C~.s
)
14 that this is coming to the forefront and we ought to try.to 15 get it all harmonized. That's the word they love:
16 Harmonized.
17 DR. SIESS: Better than simonized. I'm not sure 18 there's a big difference.
19 To follow up what I said, suppose the Commission 20 decided we would not be involved in the MRS review. Then g 21 do we feel strongly enough about some of these things that 22 we would like to tell the Commission they ought to be in 23 Part 72 because somebody else should be overseeing that, we 24 won't be around?
25 DR. REMICK: I guess I don't feel that strongly oJ ACE-FEDERAL REPORTERS, INC. l 202-347-3700 Nationwide Coserage 800-33MM6 l
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2 DR. MOELLER: Oh, I do. I believe if you don't 3 review the MRS, then it's ever more important to have input 4 into the rulemaking that the Staff uses to judge that 5 facility.
6 DR. SIESS: Maybe the other advisory committee 7 will be as smart as we are. (Laughing.)
8 Well, one approach to this, and as the 9 Subcommittee members know, I'm not in the habit of 10 proposing letters to the full Committee unless it seems 11 really important. We could report to the full Committee 12 that we had this meeting and we reviewed this; that we had
() 13 some concerns and suggestions that we had discussed with 14 the Staff; that they seemed to be received with interest 15 and some equal concern; and that we don't see any reason to 16 write a letter at this time but that we would like to see 17 the final draft and maybe meet with you at that time.
18 This will go into the record. It will go into 19 what goes to the Commission as a summary type thing. We 4
20 can arrange for that.
21 So, you will know what we said.
22 Would this be an agreeable approach? And then 23 we'll follow it up.
1 24 If they fix some things up, fine. We wouldn't 25 have had to write a lot. If something is still residual we O
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I would want to comment on it.
2 Now, Dade touched on the other issue about 3 reracking. Does anybody think we should be looking at 4 reracking? Phase II or III or whatever stage it is?
5 -That's an NRR issue. These people are not involved in it.
6 DR. REMICK: I don't.
7 DR. SIESS: I see shaking heads. I'll take 8 those as --
9 DR. MOELLER: No.
10 DR. SIESS: I can't think of anything else that 11 I want to bring up.
12 Anything, Dade, that you want to bring up?
() 13 DR. MOELLER: Not that I know of.
! 14 DR. SIESS: Paul? Murray?
15 DR. REMICK: It's an interesting meeting. I 16 have learned a lot from the discussions.
, 17 DR. SIESS: You always learn a lot.
18 DR. REMICK: Sure. Well, not always.
19 DR. SIESS: Did you have something?
20 DR. MOELLER: I'm reminded of what we heard 21 today about rod consolidation. If some of the utilities l
22 went into that in a big way, should we look at it?
23 DR. SIESS: What I have seen of the reviews they 24 have made so far, rod consolidation doesn't really raise
! 25 any new issues. The criticality improves -- and the heat 1 n) q-l l ACE-FEDERAL REPORTERS, INC.
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2 MR. ROUSE: I wanted to make one comment. John 3 and I, as I indicated,-try to follow the spent fuel storage. .
4 We don't get into details of the NRR reviews. We are aware 5 that they are well forward, we have had the application 6 from them for some time and expect them to complete their 7 decision on the Northeast Utilities application, the last I 8 heard was -- May?
9 Spring. Yes. May.
10 I want to indicate what we understand they are-11 looking at. They are looking at storage, increasing the 12 storage of the pool. We are not looking at the
() 13 consolidation per se, because that's just like reconstituting 14 rods or something. ;
15 All they are looking at is basically a 16 structural thermal criticality analysis of storing 17 consolidated fuel.
18 DR. SIESS: It's a minimal, extension of existing 19 racks except for the possibility of the process itself 20- damaging rods.
21 MR. ROUSE: And that, as I say, that's being 22 done under 50.59.
23 DR. SIESS: That's under that and of course the 24 spent fuel pool accident is all the rods in one bundle
.25 being reached and it's highly unlikely that they would ever O
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1 approach that. But I think we can keep an eye on that.
2 The consolidation for ISFSI storage is another.
3 Right now that's the DOE-type thing.
4 DR. REMICK: Along that line earlier, you raised 5 the question about should there be one place for 6 consolidation versus individual reactor. My own personal 7 gut feeling of that is it's better if we have one crew 8 doing it than having 100 crews around the country doing it.
9 But it's just an initial reaction.
10 MR. ROUSE: I sort of turn cold at each reactor 11 doing it.
12 First of all, you keep in mind the depository is
() 13 going to demand, right now, a circular cannister, container.
14 our reactors aren't really very well equipped -- they are 15 square pits all the way.
16 DR. SIESS: The stuff is going to be around for 17 a while and it's going to be above ground for a while.
18 Anything else, anybody? I declare the meeting 19 adjourned. Thank you.
20 (Whereupon, at 3:05 p.m., the meeting was 21 concluded.)
22 23 -
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CERTIFICATE OF OFFICIAL REPORTER (3
This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING: ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCOMMITTEE ON SPENT FUEL STORAGE DOCKET NO.:
PLACE: WASHINGTON, D. C.
DATE: FRIDAY, NOVEMBER.21, 1986 were held- as herein appears, and that this is the original 4 transcript thereof for the file of the United States Nuclear Regulatory Commission.
(sigt) ,e 14 (TYPED) '
JOEL BREITNER Official Reporter ACE-FEDERAL REPORTERS, INC.
Reporter's Affiliation 4
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m OVERVIEW 0F 10 CFR PART 72 GENERAL PROVISIONS - PROCEDURAL REQUIREMENTS (SUBPARTS A, B, C AND D)
O L. C. RcOSE NMSS
, PRESENTED TO ACRS SUBCOMMITTEE ON SPENT FUEL STORAGE NOVEMBER 21, 1986 i
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SUBPART A - GENERAL PROVISIONS S S 72.1 AND 72,2, PURPOSE AND SCOPE
- RULE C0 VERS LICENSES FOR POWER PEACTOR SPENT FUEL (1 YR, AGED)
- REVISION ADDS DOE ISFSI AND NRS (SPENT FUEL AND HIGH-LEVEL WASTE) e S 72,3, DEFINITIONS
- INDEPENDENT SPENT FUEL STORAGE INSTALLATION
- () - HIGH-LEVEL WASTE SUBPART B - LICENSE APPLICATION 8 S 72.14, CONTENT OF APPLICATION: TECHNICAL INFORMATION i
- SAFETY ANALYSIS REPORT CONTENT 8 8 72.18, DECOMMISSIONING PLAN 9 S 72,19, EMERGENCY PLAN i
- COMMISSION DIRECTION FOR LIMITED EMERGENCY
(]) PLANNING PROVISION FOR 0FFSITE RESPONSE
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SUBPART C - LICENSE APPLICATION 0 S 72.31 ISSUANCE OF LICENSE e S 72.32 DURATION OF LICENSE; RENEWAL e S 72.33 LICENSE CONDITIONS AND TECHNICAL SPECIFICATIONS S S-72.34 PUBLIC HEARINGS
- COMMISSION REQUEST FOR PUBLIC COMMENTS
. ($) ON PROVISIONS FOR SECOND STAGE HEARING FOR MRS S S 72.35 CHANGES, TESTS AND EXPERIMENTS S S 72.42 BACKFITTING 4
i SUEPART D - RECORDS, REPORTS, INSPECTIONS 3
0 S 72.50 SAR UPDATING S 72.51, MATERIAL BALANCE, INVENTORY AND RECORDS
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QUALITY ASSURANCE AND TRAINING I
(SUBPARTS G AND I) s 2
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COMMENSURATE WITH IMPORTANCE TO SAFETY 4 B) QAP COVERAGE C) RECORDS e
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SEC 72,91 OPERATOR REQUIREMENTS CERTIFICATION SEC, 72,92 OPERATOR TRAINING AND CERTIFICATION PROGRAM PROGRAM 1
SUBMITTAL i 1
SEC. 72.93 PHYSICAL REQUIREMENTS O PHYSICAL CONDITION GENERAL HEALTH i
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. B) PROTECTION AGAINST ENVIRONMENTAL CONDITIONS AND MATERIAL PHENOMENA
- 1. NORMAL OPERATION 1
MAINTENANCE AND TESTING POSTULATED ACCIDENTS
- 2. NATURAL PHENOMENA EARTHOUAKES
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TORNADO LIGHTNING HURRICANE FLOOD TSUNAMI SEICHE (TORNADO MISSILE)
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- 4. AQUIFER MEASURES C. PROTECTION AGAINST FIRES AND EXPLOSIONS DESIGN MATERIALS DETECTION, ALARM AND SUPPRESSION SYSTEMSs SHARING 0F STRUCTURES, SYSTEMS AND
(]) D.
COMPONENTS FACILITY CAPABILITY RETURN TO SAFE CONDITION i
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} AND COMPONENTS DESIGN G. EMERGENCY CAPABILITY ACCESSIBILITY = ONSITE AND OFFSITE O ..
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- 1. FUEL CLADDING -
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- 2. WATER PURITY LEVEL
- 3. VENTILATION AND OFF-GAS SYSTEMS CONFINEMENT
'. INSTRUMENTATION AND CONTROL SYSTEMS O MONITORING o
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- 2. TESTING FOR TRANSFER
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- SEC, 72,73 CRITERIA FOR NUCLEAR CRITICALITY SAFETY A) DESIGN FOR CRITICALITY SAFETY SUBCRITICALITY ACCIDENT PREVENTION SAFETY MARGINS
! B) METHODS OF CRITICALITY CONTROL O FAVORABLE GEOMETRY l FIXED NEUTRON ABSORBING MATERIALS l
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SEC 72.74 CRITERIA FOR RADIOLOGICAL PROTECTION A) EXPOSURE CONTROL RADIATION PROTECTION SYSTEMS CONTROL 0F INTERNAL AND EXTERNAL PERSONNEL EXPOSURES B)- RADIOLOGICAL ALARM SYSTEMS C) EFFLUENT AND DIRECT RADIATION
([) MONITORING
- 1. RADIONUCLIDES 2, DIRECT RADIATION D) EFFLUENT CONTROL ALARA 72,67 72,68 1
O
O SEC. 72.75. CRITERIA FOR SPENT FUEL AND RADI0 ACTIVE WASTE STORAGE AND HANDLING A) SPENT FUEL AND RADI0 ACTIVE WASTE STORAGE AND HANDLING SYSTEMS TEST AND MONITOR SHIELDING CONFINEMENT HEAT-REMOVAL
($) MINIMIZE WASTE GENERATION
! B) WASTE TREATMENT SEC, 72.76 CRITERIA FOR DECOMMISSIONING FACILITATE DECONTAMINATION MINIMIZE WASTE FACILITATE WASTE REMOVAL i
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Os SITING EVALUATION FACTORS PRESENTED TO O ACRS SUBCOMMITTEE ON SPENT FUEL STORAGE NOVEMBER 21, 1986 l
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SUBPART E - SITING EVALUATION FACTORS e ORIGINAL INTENT - SCREENING PROCESS e PRESENT OUTLOOK - ALL SITES PREVIOUSLY EVALUATED e S 72.61 GENERAL CONSIDERATIONS PERMITS BROADER. RANGE OF REVIEW THAN AS FOR REACTOR LICENSING C) -
INTENT IS TO COVER SITE-REGION RELATIONSHIP e S 72.62,1 9 72.63, S 72.64, S 72.65 NATURAL AND, MAN-INDUCED EXTERNAL EVENTS IMPACTOF'STORA$EONREGION e S 72.66 GE0 LOGICAL AND SEISM 0 LOGICAL CHARACTERISTICS SCREENING' CRITERIA FOR SITE SELECTION:
DESIGN EARTHOUAKE CRITERIA: ,
e APPENDIX A CRITERIA e GENERAL CRITERIA O
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O o S 72.67 RADIOLOGICAL IMPACT OFF-SITE CONFORMS TO EPA CRITERIA e 25 MREM WHOLE BODY e ALARA e S 72.68 CONTROLLED AREA
- SIMILAR TO EXCLUSION AREA, BUT MAY NOT COINCIDE
- 5' REM DESIGN BASIS ACCIDENT LIMIT e S 72,69 EMERGENCY PLANNING ZONE
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- EVACUATION NOT FORESEEN ~
- REMOVED IN NEW VERSION NEW SECTION e S 72,75 SITING LIMITATIONS
- MRS CANNOT BE IN SAME STATE AS REPOSITORY
- LIMIT T0 70K TONNES IF WITHIN 50 MILES OF REPOSITORY IN ADJACENT STATE O
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- HAVE BEEN RECEIVED o MAJORITY OF THE COMPENTS ARE OF PROCEDURAL OR CLARIFICATION NATURE.
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MONITORED RET'RI'EVABLE STORAGE DESIGN DATA e LICENSE LIMIT: 15.,000 MT e YEARLY RECEI' PTS: 3600 MT e CRBR SITE ACREAGE: 1300 (360 secue.e) e APPR0XIMATE PLANT SIZE: 100' NIGN x 60'0' Lono x 600' w!DE
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ECUIPENT PERSONNEL SCFT ASSETS c DRAFT PLAN SUEMITTED FOR SG REVIEW o SG REVIEWED DRAFT AGAINST S 73.50 c SG INF0PE D LICENSEE CF AREAS NEEDING STRENGTHENING
! O PLAN SATISFACTORY TO SG EERGED AFTER ONE OR TWO ITERATICPS o LICENSE WILL CCNTAIN CCNDITION RECUIRING LICENSEE TO CAPRY CUT PLAN O
SAFEGUARDS LICENSIflG: ROBINSON 2 O
o LICENSEE ltDIFIED PHYSICAL PROTECTION PLAN FOR REACTOR SITE o FLAN MODIFICATIONS SHOW THAT FUEL STORAGE CASK IS PRuituw BY A REINFCRCED C0fiCFETE STORAGEFCDULE FCR LE LOCATED WITHIN THE PROTECTED AREA ACCESS TO FCDULE CONTROLLED ALL SPECIAL EQUIFFENT NEEI'ED TO GAIN ACCESS TO STCRAGE CASKS SECURED TO PRE'ENT MISUSE MODULE PFmtuw BY FULL SET OF FEACTOR PHYSICAL
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CASK INDENTION DRY SHIELDED CANISTER H. 8. ROBINSON INDEPENDENT SPENT FUEL
.I STORAGE INSTALLATION SAFETY ANALYSIS REPORT HORIZONTAL STORAGE MODULES Figure 1.2-1
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ACRS SUBCOMMITTEE i ON
- SPENT FUEL STORAGE i NOVEMBER 21, 1986 1
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TYPE: DRY CASK LOCATION: VP SURRY POWER' STATION, SURRY COUNTY, VA f
t i H. B. ROBINSON ISFSI (DOCKET NO. 72-3; SNM 2502 TYPE: DRY CONCRETE MODULE AND
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STAINLESS STEEL CANISTER LOCATION: CPal H. B. ROBINSON
- O STEAM ELECTRIC PLANT, UNIT 2, DARLINGTON COUNTY, SC f
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SAFETY ENVIRONMENTAL O SAFEGUARDS l
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ACCEPTABILITY DETERMINATION i
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! HEALTH AND SAFETY ,
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PUBLIC C0FFENTS ON PROPOSED CHANGES TO 10 CFP PART 72' l o PROPOSED CHANGE PUBLISHED FOR COMPENT ON Pay 27, 19E6 o COMMENT PERIOD ENDED ON AUGUST FS, 1986 o OVER 180 COMMENT LETTERS HAVE BEEN RECEIVED o APPR0XIMATELY 2/3 0F TFE COMMENT LETTERS ARE OF A SINGLE CONSENSUS o COMMENTS ALSO RECEIVED FROM STATES (4) AND 1
UTILITY INDUSTRY (11)
O o APPROXIMATELY 50 INDIVUALLY IDENTIFIABLE COMME.<TS HAVE BEEN RECEIVED o MAJORITY OF THE COMMENTS ARE OF PROCEDURAL OR CLARIFICATION NATURE.
o LIMITED NUMBER OF SAFETY RELATED TECHNICAL COMMENTS.
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E (u i PH'/SICAL FROTECTICE (S EPART H)
PPESBfED TO ACRS SECCf71!11t CN SPENT FUEL STORAGE PUEMBER 21, 1986 EY G
V CAPL B. SAhYER NfES l
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.O CUFPART H - PHYSICAL PROTECTICN c 9 72.81 PHYST. CAL SECURITY FLAN DEMONSTPATES HCW LICENSEE WILL CCFPLY WITH AFFLICAT3LE ECUIREENTS CF PART 73 INCLUDES f9NS TO DEBD' STRATE CCFFLIANCE o S 72.82 DESIGN FOR PHYSICAL PROTECTICN SITE LAYCUT DESIGN FEATURES o S 72.83 SAFEGUARDS CONTINGENCY PLAN STATUTORY PECUIREMENT FREPARED IN ACCOPDANCE WITH APFFRIX C OF PART 73 o S 72.84 CHANGES TO FHYSICAL SECl.'RITY AND SAEGUARD CLVTINGENCY PLANS
_ ._ . - - . .. _. .. . ,_ _ =
FHYSICAL PROTECTICN :
O rtCmRewS c PECUIREENTS SET FCRTH IN S 73.F0 o GBJECTIVE: PROTECTION AGAINST PKICLOGICAL SAE0 TACE o SECURITY FORCE o EARRIEFS TWO BARRIERS ISOLATIONZONE o ACCESS CCNTROLS PERSCtt!EL ACCESS BASED ON NEED l
SEARCHES BAEGING CASUAL VEHICLES PRCHIBITED VISITCRS ESCORTED j
o EETECTION AIDS ILLUMINATION SURVEILLANCE O
PERIETERALAFN ALAPfi STATICN
, o RESPCNSE ,
V l EVALUATE SITUATICN f PAKE DETEPNINATICN r
NEUTPALIZE THREAT USE CF FCRCE AID FPCM POLICE i
o C0lttNICATION O -
GUARD-TO-ALARM STATION l
l -
ALAPM STATICN-TO-POLICE ,
INDEPBEO!T PC'{R i
l l
O
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