ML20236K670

Summary of 870713 Public Hearing on Northern States Power Co Fuel Rod Consolidation Pilot Project in St Paul,Mn

ML20236K670
Person / Time
Site:	Prairie Island
Issue date:	07/13/1987
From:	MINNESOTA INSTITUTE OF CONCERN FOR PUBLIC HEALTH
To:	MINNESOTA INSTITUTE OF CONCERN FOR PUBLIC HEALTH
References
NUDOCS 8708070217
Download: ML20236K670 (34)

Text

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SUMMARY

of PUBLI C HEAR ING on Northern States Power Company's Fuel Rod Consolidation Pilot Project at State Office Building St. Paul, Minnesota July 13, 1987 submitted by Minnesota Institute of Concern for Public Health HCR 84 box 1397 B Walker, Minnesota 56484 (218) 547-3393 /,h B70BO70217 B70713 PDR P

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The public hearing regarding Northern States Power Company's rod consolidation pilot project was attended by over forty individuals.

Representatives from the Prairie Island Community Council, the Minne-sota Public Utilities Commission, the Minnesota Department of Public Service, Senator David Durenburger's office and Congressional and State Legislative districts were among those attending. Private citizens from throughout Minnesota represented many citizen groups and their individual concerns.

Conspicuous by their absense were Northern States Power Company's representatives. NSP exhibited blatant disregard for the public's concern over this issue. NSP's decision regarding their non-attendance at the public hearing was questioned many times during the hearing. The utility lost the opportunity to demonstrate their corporate consciousness to their nuclear power plant neighbors, rate-payers, State agencies and concerned citizens.

] Barbara Johnson, St. Paul attorney and attorney for the Minnesota Public Interest Research Group, was the hearing examiner. Ms. Johnson verbally presented the only information Northern States Power Company provided for public questions regarding the fuel rod consolidation project.

(That information is included.)

Citizen groups and individuals providing verbal testimony are listed below:

1. Carol Reddy, Grand Rapids, Itasca County Nuclear Awareness

2. Bev-Nii Anderson, Leech Lake Reservation, Minnesota Institute of Concern for Public Health

3. Henry Fildseth, Minneapolis, Northern Sun Alliance

4. Brad Knight, Benedict, Citizens for a Sustainable Future

5. Dick Anderson, Walker, Minnesota Institute of Concern for Public Health

6. Joseph Campbell, Sr., Prairie Island, Prairie Island Community Council, elected tribal official

7. Kristin Olson, Minneapolis, private citizen

8. Carl Anderson, McGregor, private citizen

9. Hannah Anderson, Minneapolis, private citizen

10. Leonard Tanner, Duluth, Four State Indian Comnission

11. Walt Handschin, St. Paul, private citizen

12. Kim Keating, Grand Rapids, private citizen

13. Dan Olson, Minneapolis, private citizen In addition to verbal testimony at the hearing the Minnesota Institute of Concern for Public Health received seven additional written testimonies.

All written testimony is enclosed and audio tapes of the hearing are available on request.

All testimony received strongly opposes the proposed fuel rod consolidation pilot project at NSP's Prairie Island nuclear power plant. Concerns were voiced regarding the untried technology of rod consolidation, the unlicensed remote equipment, the unknown and unresolved safety issues, unrealistic evacuation plans, and NSP's " rush" to proceed before DOE data is received, compiled, and analyzed. Many people requested that

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Northern States Power Comprtny spend more time and money on researching alternatives to nuclear power t.o expidite the shutting down of their ,

nuclear power plants, before an accident occurs.

Joseph Campbell, Sr., representing the Prairie Island Indian Community, j said: "Can you tell me these operators of that nuclear power plant l are responsible human beings? ...I think it's time that some government official, or someone, come out and watch them drive when they're off work and see how safety minded they really are." {

j The consensus arrived at by the public hearing participants and those submitting written testimony is that Northern States Power Company should not proceed with the planned rod consolidation project. No one l present spoke in favor of the project. '

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l Respectfully Suhnitted l Minnesota Institute of Concern for Public Health l HCR 84 Box 1397 B Walker, Minnesota 56484 (218) 547-3395 l

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Testimony for Public Hearing on N S P's Proposed Rod Consolidation Pilot Project Presented to the MN Inst.itute of Concern for Public Health On July 13, 1987 State Office Building , St. Paul, Minnesota Bev-Nii Anderson H C R 84 Box 1397 B Walker, Minnesota 56484 1

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My name is Bev-Nii Anderson and I live on the Leech Lake Indian Reservation near Walker, Minnesota. I am a member of the Minnesota Chippewa Tribe and am affiliated with the Minnesota Institute of Concern for Public Health. My testimony is prompted by my concern for the public safety and the public health of all Minnesotans, but especially those living and working in close proximity of the Prairie Island nuclear power plant. That includes all of the people in the metro area of St.

Paul and Minneapolis.

Northern States Power Company has initiated a " pilot project" that will itivolve dismantling (underwater in a tunnel, with remote, unlicenced and unproven equipment) approximately 9,000 extremely radioactive fuel rods form their cladding and placing them in canisters TO SAVE MONEY AND SPACE! I have spent considerable time finding out about this project and the more I know about it, the scarier it gets.

In the first place, it seems that nothing of this scope has been done anywhere in the nation, even by the so-called experts. The Department of Energy, the Federal agency responsible for radioactive waste research and development, is not involved in this " experiment" and are conducting separate projects at National Laboratories to find out IF rod consolidation will be one of the technologies used for increased storage capacity l at comercial nuclear reactors. It seems like NSP is jumping the gun.

I find this entire concept unethical, immoral and unconscionable.

hhere did the so-called " corporate responsibility" of our state's largest electric utility go? Or, as is perhaps more the case, they never had any concern for the public other than getting our money for electric rates. The expense for this nuclear experiment will be charged to the ratepayer, without NSP even answering our questions or coming to this hearing. They have proven to me, and I hope to many others by noi, that they have absolutely no regard for the public or concern for the health and safety of their workers. Why won't they answer our questions?????? Because they don't have the answers!!! That became very clear to me when we talked with officials from DOE and the NRC about rod consolidation.

The questions that still need to be answered are:

1. 'Ihis exr>eriment will consolidate about 50 fuel assemblies, or 9,000 rods, with the idea of consolidating 179,000 more fuel rods weset int /w. Cutro, ynnes(Does the storage pool have sufficient structural strength to withstand the additional weight?

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2. Can you guarantee that rroving the fuel rods from their cladding and placing them in canisters so closely will not prompt a chain reaction and criticality? Do you havt any knowledge of the explosion in Russia during 1957 that was in a fuel storage facility? The entire surrounding area has been contaminated for many years and all the people were evacuated.

3. Will NSP begin monitoring the Mississippi River on an hourly basis,

([the storage pool could run off radioactivity into the fater) and be able to assure the public in the rest of the United Stptes that the river will be safe from your contamination?

4. The Certificate of Need from the State of Minnesota that was granted in 1981 specifically states the following conditions: NSP shall not store more than 1386 spent fuel assemblies in the pools at any given time, to ensure that the spent fuel can be removed from the pools and that the pools do not become a " permanent" storage facility,..

It appears that NSP is p'aving with numbers and nuclear jargon to try and fool the public and ate agencies. Does the current 845 assemblies become 423 after consolidation? Can the spent fuel be retrieved from the pool after consolidation as readily as they can now? /

How do you, NSP, or anyone else at this point in time guarantee that this does not become a permanent storage facility?

5. The NNPA has provisions of Federal Interim storage to assure that commericial nuclear power plants do not run out of storage space and prevent their cantinued operation. Why IS$ht NSP jsut go this route instead of placing this whole area in pctential jeopardy? Chernobyl is still fresh in my mind and that was the result of nuclear power plant operators " experimenting" with' cut government sanctions. The operators are now on trial. An added result is that the United States is receiving cheap food products through Canada that have originated from Yugoslavia Hungary and other "Chernobyl" countries.

We're quietly eating radiatien and I don't like it.

I have NO CONFIDENCE that this is a safe technology and we cannot trust l the so-called " experts" at NSP. We have to assume, by the very fact that they have chosen not to be here to answer questions that they don't have the answers......They p nt the " experiment" to answer Q e questions.

That process is unacceptable. The This rod consolidation experiment MUST NOT PROCEED. All of the citizens,

, all of the nuclear power plant workers, all of the construction workers, and all of this area's natural resources could be in serious trouble I with radiation contamination if this experiment fails. We cannot allow i this to proceed just so NSP can save money. I say no and I will do whatever is necessary to see that it does not proceed.

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1' Testimony for Public Hearing on

\<J N 5 P's Proposed Rod Consolidation Pilot Proj ect is

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Presented to the MN Institute of Concern for Public Health i on July 13, 1987 State Office Building, S t, . Paul, Minnesota l

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Walker, Minnesota 56484

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'MyTname is Dick Anderson and'I'm from Walker, Minnesota.

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'I am going to give some brief background information on rod consolidation as it has occurred and is occuring in the United States. I feel that this is necessary in order to put the proposed fuel rod experiment, that NSP states that they are going-ahead with this summer, in proper perspective.

The U.S. Department of Energy is. charged with:the manage-o ment of high-level nuclear vaste. The information I am presenting l

here is taken directly from their documents. I will be presenting

! these along'with written testimony to the hearing examiner.

D.O.E. has an extensive on-going research and development program. Congress has funded them 10.3 million dollars for )

FY 88 for Interium. fuel rod storage Research & Development.-  !

One project has-been completed. This was a project with the Rochester Gas & Electric Company.in New York. This involved removing.the fuel cells from the Ginna reactor storage pool, shipping them to Battelle Colombus Laboratories, where the fuel rods were removed from the cladding in the laboratory pool. The consolidated rods were then shipped back to the Ginna reactor pool and placed in storage. I will read from DOE's waste management ANNUAL REPORT TO CONGRESS dated April 1987: '(excerpts from Rod Consolidation, pp 23 & 26)

The Department of Energy has a multi-phased Research

& Development project specifically with fuel rod consolidation.

The final phase will be a " hot"-demonstration (with radioactive fuel rods) and will be done at the Idaho Natical Laboratory.

I.will read from the June 23, 1986 OCRWM Bulliten: (p.4-Rod Consolidation Negotiations)

The present Department of Energy Research & Development project with Northeast Utilities Services of Hartford, Connecticut is intended to supply sufficient data for utilities to apply for lit ncing offrod consolidation. I refer to OCRWM Bulletin of-Apr 1987, page 2; which I will leave with the Hearing Examiner:

DOE's OCRWM Mission Plan Amendment, dated June 1987, speaks of risks and costs of rod consolidation at reactor sites. .I will read from page 95:

So what do we know of NSP's announced rod consolidaghon proj ect? Not an awful lot. Had they had a modicum of consideration for the public and governmental agencies they would be here tonight. This is a highly technical issue, and a technology involving risks as you have heard from the Federal agencies.

We have every right to be concerned----yes, even alarmed, that NSP would attempt to sidestep Federal involvement in the project.

To my knowledge NSP has made but two short presentations on their rod consolidation project. The first was on March 23, 1987 to the Pollution Control Agency board and the second was on June 16, 1987 to the Low-Level Radioactive Waste Advisory Ccancil.

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i Thb havesseeryfit;toprovideuswithafivepagequestion and.,.nswer shbet and a diagram of a fuel cell. They were

< questioned at'the June 16th meeting about a report to the Nugtear Regulatory Commission rE.#fhW iPf) un : d " unresolved safLty issues" before the start of'the project. They. responded

'with: "There are no unresolved safety issues."

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NSP met this past winter with NRC officials seeking approval of this rod consolidation project. They were sent back to do some more homework. They are to meet again in August with the NRC so that a determination can be'made to see if the 50-59 Review

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(NSP's self-review) will be adequate to go l' ahead with the" project.

The NRC project director has stated that they cannot say either way as to whether or not they will sanction NSP's rod consolidation project. The NRC official I talked'to said: "We have reason to s believe that NSP will-have a difficult time justifying the project'

• at Prairie ' Island, ' knowing what they know about the situation ,

there." l 4

V So it appears that NSP cannot go willy-nilly ahead with the-rod consolidation " road test" without the approval of the Nuclear Regulatory Commission.

Even without the rod consolidation taking place, we are exper-t iencing a rapidly expanding high level radioactive waste storage site on an isisnd in tha Micciccippi River. This site presently has 151,454 fuel rods stored on site. It is growing at the rate of 14, 320 fuel rods a year. By the year 2000 there will be over 200,000 fuel rods stored in aging facilities that were never designed for this extensive use. Certificates of Need or permits would l

never have been granted had State Agencies realized that Minnesota l

would become a radioactive waste dump. Minnesota government officials unanimously spoke out against the Departreent of Energy when we were targeted as a high level waste dump. Now[e(ary a-1-r+ady, one year later, sitting idlely by and increasing the high level dump that exis's t on a Mississippi River island just south of the Twin Cities? No.

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3 I believe that I am speaking for many Minnesotans when I say: "NSP, hold off for now, let the experiments be conducted at National Laboratories. Let the equipment be licenced and approved before you proceed. Let the technology be tested and licensed by the Department of Energy and the Nuclear Regulatory Commission before you propose ANY rod consolidation in Minnesota.

If you must have a " demonstration", let that demonstration be one of concern for the health and safety of workers and the general public. Let it be a demonstrat:'an of prudent restraint with regards to a project of new and unresolved technical and safety issues.

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spent fuel as' called for by the Act and stated that the greatest lost opportunities of the program to date."

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The DOE is supporting the development of at-reactor dry-storage and in-pool consolidation technologies by means of demonstration programs at utili-ties under cooperative agreements with each utility. These activities were undertaken pursuant to the Act, which directs the DOE to encourage and ex-pedite the effective use of existing storage facilitiesThe extent andtothe addition which utilities of needed new storage capacity at reactor sites.

will pursue dry storage or consolidation will depend on their available stor-age capacity and reactor-specific needs and requirements.

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y Rod consolidation can be performed at A reactor sites, but at addi-The experience to date with I

tional financial and operating costs and (riskss this tech'nolcigy has been to consolidate two' assemblies into one square This " reactor" canister that will fit back into the original storage rack.

canister will be open to permit water cooling (i.e., it will not be sealed);

it will be exposed to water that may be contaminated; androds In contrast, it may from or as may many not as be compatible with repository packaging plans.

12 fuel assemblies f rom pressurized-water reactors (PWRs) or 30 assemblies

' from boiling-water reactors (BWRs) could be consolidated in round canisters at the KRS facility or the repository. The canisters would be sealed, free of f

surface contamination, and specifically designed for the repository reactor sites disposal are package. Thus, consolidation and packaging operations.at h not comparable to the same operations at a large dedicated In addition, the packaging packaging facility func-i like the MRS facility (or the repository).

tions at the MRS facility (or the reoository), in contrast to reactor storage 4 pools, would be designed, built, licensed, and operated specifically for this I Considering that several hundreds of thousands of assemblies will be purpose.

consolidated and packaged, the DDE believes that it is important that'consc h if idation be perf ormed with egpmentEd_f a aci.Qties ded_icated to that objW.

J, N Experience in other countries reinfor os the DOE's belief that there is

-6' Q no need for a more detailed study of alternatives that would further burden

' gf reactor operations. For example, both the Federal Republic of Germany and Sweden are minimizing the role of the operating reactors in spent-fuel manage-ggf: , , .

ment and disposal, in order to allow the reactor managers to conesntrate their v 1 efforts on the safe and efficient operation of the reactor.

J q Expanded dry storage at reactors would not be an alternative to an MRS

&Hg facility because the role proposed for the MRS facility goes well beyond O

g curtailing at-reactor storage problems before the start of Federal acceptance f It is appropriate to note also that the primary objective of of spent fuel. Rather, reducing Q an MRS facility is not reducing utility storage burdens.

_g %g bet secondary, benefit associated with the y g that burden is a very significant,early implementation of the Federal waste-management

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kiftheMRSfacilityisauthorized; it is a benefit that makes the MRS facility 5

4allthemoreattractive. Storage at an MRS facility offers cost savings based

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f j 00 economies of scale that cannot be matched by multiple separate dry-storage p , installations at reactors.

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• Hearing Examiner Third Compaction Scheme For Prairie Island Wastes l State Capitol St. Paul,-Minnesota Walt Handschin 2029 Edgerton St. Paul,IM 55117 July 13, 1987

Dear Hearing Examiner:

i I wish to submit the following as public testimony in the hearing for the Third Compaction Scheme For Prairie. Island Wastes. Through unfortunate experience with previous hearings regarding high level radioactive waste compaction at NSP's Prairie Island plant, I have learned that the public record is more accurate if public testimony is presented in written form. If everyone had the resources of a large corporation, perhaps you would find yourself doing more reading and less hearing.

1. How do we(you and I) get NSP and the State of Minnesota out of the business of trying to make money in what should be a contracting market? l

2. How do we get on with the important work of making life less destructive and more supportive of free, living' creatures?

3. Approval of this Scheme will~ continue to defer investment in decentralized renewable energy sources, especially conservation.

'4.' Money will continue 'o t flow in the wrong magnitudes and directions from poor unemployed people and others to rich _ people working in, controlling, or owning large corporations.

5. What happens with the money also_happens to the political power and freedom

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of the people. They will be flowing in the wrong magnitudes and directions.

6. When we contemplate a scarred earth, who speaks for the fish and birds, the plants and animals?

7. Why are not all parties required to come to the hearings with zero expenditures in the proposed project? I know that you are required to disregard such facts.

Are we both aware that with knowledge comes a loss of innocence, and that such disregarding of facts is a trick that is impossible to achieve? What is the function of such a fiction? When you learn of such expenditure, why are you not empowered to protect the legitimacy of the hearings by requiring divestment?

8. I suggest a prudent course of action that would just say no to the new experiment to disassemble fuel assemblies.

9. Just say no to placing the fuel in new canisters.

10. Just say no to new untested and un11.ensed procedures and remote equipment.

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Walt Handschin Page 2

11. Just say no to premature " disposal" of assembly components in unsafe dumps l or unknown, uncertain future dumps.

12. Wait until NSP, from the chairman of the board down to the smallest stock-holder, is so confident of its business practices, and has amassed such great financial reserves, that it is willing to assume 100% liability for its actions.

Until that time, do not' allow NSP to experiment with the common weal. And do not allow the State to become a co-conspirator.in such activity.

13. The history of nuclear technology is too shameful and terrifying for either industry lor government to adnit. The price of such technology is to put all life at risk. Further, the techtiology's essential secrecy has partially destroyed the elements of democracy in this society. We can learn from _ the suffering at Chernobyl and Three Mlle Island and elsewhere only if we so choose.

14. Act with care, compassion, and wisdom so that we can leave these proceedings with feelings of joy and love, secure in reasonable expectations for a less dangerous future.

Wit a regard for the living,

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L'lCC' k/ A4,s Walt Handschin

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" Prairie Island Community. Council--

5750 Sturgeon Lake Road  !

Welch, MN 55089 S" July 7, 1987 Mr. Tom Bushee Northern States _ Power Company 414 Nicollet Mall

. Minneapolis, MN 55401 t i

Dear Mr. Bushee:

My position as an elected Tribal Official of the Prairie Islano Indian community prompts me to inquire about the proposed fuel. rod. consolidation.

experiment at your. Prairie Island nuclear power. plant. tus have several questions for you to answer:

1. Will you be using Nuclear Regulatory Commission licensed equipment r:

that has been tested and proven safe for this project? .i 2,

Our informatich is that the remote equipment will be used underwater.  ?

What is your anticipated starting date and When do you expect the project to be completed?

3. Has your contractor ever done rod consolidation, using radioactive' rods,-before? ,

If so, when, where and in what amount?  !

Does it come close to the approximately 9,000 fuel rods this project expects to consolidate?

4. Will Northern States Power Company be financially liable for any-damages to health or property to our community?

Will the contractor have any financial liability? l

5. Can tne warning sirens in our community be assured to operate in a  !

timely manner in the event of a disaster? Sometimes they seem to be j set off by weather, how will we know if the sirens are the.real thing?  !

6. Can NSP coordinate-a realistic evacuation of all of our community residents in a timely manner? How will this be accomplished? Both. l bridges leading from here are one lane and not in very good condition. l

7. Th3 understand that the Uni ted States Department of Energy has awarded {

contracts and is conducting research and development to determine if {

commercial rod consolidation is a viable storage option for commercial nuclear reactors. Why is NSP bypassing the Federal system already in place?

" Members of our community will attend the publio hearing regarding the rod  !

consolidation pilot project on Monday July 13th at the Sta te Of f ice Building '

at 7:00 PM in Room 10. Our reservation members have some more questions that will require answers from Northern States Power Company. We sincerely hope i you will be in attendance at the hearing to answer our questions.

'I expect your response on these items in a timely manner. Our community members deserve answers to these questions as we are the most in jeopardy if this 1 technology fails. It's timo for a healthy dose of pessimism. We do not, at

.this time, have the confidence that this can be a completely safe experiment.

SA* O Y q g[g$WV Jose h Campbell, Sr.

Assistant Secretary Treasurer oo: Governor Rudy Perpich Minnesota delegation of U.S. congress President of NSP Minnesota delegation of U.S. Senate Roger Head, Minnesota Indian Affairs Council Members of Minnesota Public Utili ties Comma ssion j

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FACT SHRIT '. .

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Fuel Rod Consolidation .

Fuel rod consolidation involves dismantling (under water, with remote unlicenced equipment) the fuel assemblies and placing them in canisters to take up less space Rod consolidation increases the capacity of spent fuel storage pools WIQ{ HAVE SUFFICIENT ?!RUUNRAL STREN71H TO SAFELY SUPPORT a more compact array of spent fuel rods that have been separated from their hardware

• Remote equipment used for this project of rod consolidation is not licenced.by anyone 2e Glited States Department of Energy has had LIMITED involvement in fuel rod consolidations l . 1981 DOE successfully coupleted a " cold" (nonradioactive) demon-I stration of prototypical rod consolidation equipment

. 1985 Six assemblies were consolidated at the West Valley demonstration project (a Federa; Facility) i

. I'986 Four assemblies were consolidated in Colombus at Batte11e's plant ,

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• 1982 Duke Power Cmpany (Oakoney Plany) consolidated 4 assemblies

• Wis was without Department of Energy involvement

. 1987 Northeastern Utilities of Hartford (Millstone plant) vill start a rod consolidation demonstration protect next sonth for 10-14 fuel rod assemblies **

• • After completion of the cooperative demonstration project, DOE expects to assemble a data base that will enable the "ut'llities to apply for licencing of rod consolidation

• DOE is currently supporting cooperative demonstrations of rod consolidation with several utilities (N7T NSP) DOE is unaware of the specifics of NSP's project

• DOE is conducting spent fuel Research & Development to provide data to the utilities for obtaining licences for these NEW TECHNOLOGIES 2ese DOE activities are intended to establish 1 or more technologies that the NRC MAY APPROVE by rule for use at reactor sites...

Northern States Power Ompany is required to sulxnit a safety analysis report to the Nuclear Regulatory Comission to address UNRESOLVED SAFETY ISSUES (his report vill probalby not be made ytblic)

(MN Institute of Concern for Public Health, June 1%7)

112 West Harvey St.

Ely, MN 55731 July 20, 1987 Northern States Power Comments concerning NSP Nuclear Fuel Rod Consolidation Nuclear f uel rod consolidation has not been established as a safe means of temporary storage. In fact, it is an experiment.

The Department of Energy has had limited involvement in fuel rod consolidation.

There are no regulations no prescribed guidelines for methodology no guidelines for safety no permitting system Equipment used in the process is not licensed A data base has not been established Presently, the largest amount of assemblies to have been consolidated is only six. Northern States Power's proposed pilot project intends to consolidate 9,000 fuel rods.

The DOE has not worked with NSP on rod consolidation and is unaware of the specifics of the NSP project.

It is based on these facts and the non-existant due process for fuel rod consolidation that I oppose the undertaking of the proposed NSP fuel rod consolidation project.

Signed,

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Madonna Ohse Chairperson, MN-North Vermilion Chapter

July 15, 1987 To: Department of E.nergy Nuclear Regulatory Commission USP I am very concerned about the proposed demonstration research at Prarie Island, L the fact that a private industry is wanting to research something as dangerous as nuclear waste and the location of Prarie Island in the mississippi deems the proposal even more absurd. There is lacking evidence that this research can be conducted safely, and while I too am concerned about the nuclear waste that is I

being created and it's future, I believe it is crucial that we avoid risking I potential disasters. Proceeding with research within distance of the Mississippi River, allowing private industry to conduct the research without the close supervision and monitoring of btate Agencies and Public Advocacy Organintions, and proceeding without clear evidence of sefe.ty and the protection of ti e environment are my reasons for opposing research at Prarie Island.

I would also question the safety of a nuclear power facility that does not have a feasible evacuation plan, such as Prarie Island.

hith grave concern,

h. 3v~D B.Bunte, EN, PE1 Box 498 Bigfork, Minnesota 56628

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Dear Person,

In case I'm unable to attend, this is to request that the following aspects of fuel rod consolidation is looked into.

I had a discussion with an operator of a nuclear power plant about maintaining the pool in which the rods are kept. From that, i t's my understanding that:

1) There is more radioactive material in the pool than in the containment itself.

2) If the cooling failed, the pool would boil in a matter of days.

3) If the water evaporated, the rods would melt, flow together, and

" burp" while melting and sinking.

4) If the pool is over-cooled, the solute becomes supersaturated and precipitates out in the plumbing and pumps, clogging them and initiatating the above problems.

I'd like to know if:

1) The above problems ar( real.

2) If the pool has as much attention given to back-up systems and tests as the containment on the reactor.

3) If what's in the pool presents an equal or greater hazard, does plant security give equal weight to protecting it.

1) How long it takes the pool to boil now and af ter consolidation.

5) Whether the above considerations figure into the original design margins of safety, whether they are being now exceeded, and, if so, why don't '

new permits and engineering studies become neccescary?

' Bye for now, e N-- ,

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3 Craig s Copy to Mr. Tom Buchee, NSP

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FACT SHIRT *

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Fuel Rod Consolidation ,

s Fuel rod consolidation involves dismantling (under water, with remote unlicenced equipment) the fuel assemblies and placing them in canisters to take up less space Rod consolidation increases the capacity of spent fuel storage pools WHIQi HAVE SUFFICIDir S!1tDC7)RAL S'11 TEN 7IN 'IO SAFELY SUPPORT a more compact array of spent fuel rods that have been separated from their hardware

• Remote equipment used for this project of rod exmsolidatiot is not licenced.by anyone ___

• 'Ihe United States Department of Energy has had LIMITED involvement in fuel rod consolidation:

. 1981 DOE successfully completed a " cold" (nonradioactive) demon-stration of prototypical rod consolidation equipment

. 1985 Six assemblies were consolidated at the West Valley demonstration project (a Federal Facility)

. I'986 Four assenblies were consolidated in Colombus at Batte11e's plant ,

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• 1982 Duke Power Conpany (Oakoney Plany) consolidated 4 assemblies

• 'Ihis was without Department of Energy involvement

. 1987 Northeastern Utilities of Hartford (Millstone plant) will start a rod consolidation demonstration oroject next month for 10-14 fuel rod assemblies **

• • After completion of the cooperative demonstration project, DOE expects t,o assemble a data base that will enable the u"t311 ties to apply for licencing of rod consolidation

• DOE is currently supporting cooperative demonstrations of rod consolidation with several utilities (NDP NSF) DOE is unaware of the specifics of NSP's project

• DOE is conducting spent fuel Research & Development to provide data to the utilities for obtaining licences for these NEW TECHN010GIES

'lhese DOE activities are intended to establish 1 or more technologies that the NRC MAY APPROVE by rule for use at reactor sites...

Northern States Power Company is required to subnit a safety analysis report to the Nuclear Regulatory Comission to address UNRESOLVED SAFETY ISSUES ('Ihis report will probalby not be made public)

(MN Institute of Concern for Public Health, June 1987)

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,I ggy 01 4G ,k .b l NSF 2/87: j RCD CONSOLIDICION Q&A 1

1 hhat is rod consolidation? .....................'..... I hty is NSP doing the proj ect? . . . . . . . . . . . . . . . . . . . . . . 1 How is rod consolidation done? ..................... 1 khat are the advantages of consolidation? .......... 1 Ecw rany asserblies does NSP plan to consolidate? . . 2 Ecw much will the demonstration project cost? ...... 2 Is criticality (chain reaction) a concern? . . . . . . . . . 2 ,

Won't the consolidation add a lot of weight / heat? . . 3 Why doesn't NSP ship the fuel away? ................ 3 khy doesn't NSP re-rack the pool again? ............ 3 Is NSF considering dry cask storage? ............... 3 How will NSP pay for the project? . . . . . . . . . . . . . . . . . . 4 hty didn't NSP build a bigger pool originally? . . . . . 4 Will NSP continue consolidation demonstrations? .... 4 hhat if the demonstration project doesn't work? .... 5 hhy not just shut down the plant? . . . . . . . . . . . . . . . . . . 5 f///S /C ikt 67dy N' 'W'#'" t Piee </seo 13y susp Q 79, ,%xuu , 7#sy hfm n Arms w f/was.

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RCD CONSOLIDATION Q&A Q. Nhat is rod consolidation?

A. Rod consolidation is a method of increasing the number of spent nuclear fuel assemblies stored at the plant site. By removing the 13-foot-1cng fuel rods frcn their fuel assemblies and placing them in specially designed canisters, plant staff can store the rods frcn two assemblies in the space one assembly formerly occupied.

> Q. Why is NSP doing the denenstration project?

A. The Prairie Island spet fuel pool will be full in the mid-1990s.

Since no off-site storage or disposal is likely to be available by then, NSP must seek ways to increase the number of spent fuel assemblies stored at the plant. Rod consolidation might prove to be the mcst econcaical option for doing so. NSP hopes the demonstration project will show that the technology can be used efficiently on a large scale.

Q. Ecw is consolidation done?

A. Technicians place the Westinghouse-developed . consolidation apparatus on the bottcm of the water-filled, 40-fcot-deep spent fuel transfer canal adjacent to the spent fuel pool. Using rerete handling tools, they remove the 179 fuel reds frcn each assembly and place them in a ecmpact arrangement in canisters. This consolidates two assemblies, one at a time, into a single canister. The canister then is placed in the space formerly occupied by a single fuel assembly in the spent fuel pcol storage racks. . Plant staff will ccupact the remain 1ng ncn-fuel parts of the assemblies and store the material on site for future disposal.

Q. What are the advantages of consolidation?

A. The consolidation process has several advantages.

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• It is the most econcrrical storage expansion option. It can cost frcm 30 to 50 percent less than other methods.

• The process is incremental. 1{SP can consolidate assemblies in stages rather than havino to do a major, all-at-one-time project.

• Consolidation involves many processes already familiar to plant staff and does not require removing the s p t fuel frcn the pool.

Q. How nany assemblies does NSP plan to consolidate?

A. NSP plans to consolidate up to 50 used fuel assemblies during the dercnstration project. If the technolcgy works well in the.

demonstration, NSP will seek pe=its to consolidate at least 1,000 fuel assemblies. The current NSP-Westinghouse contract provides NSP the option of consolidating up to 1,000 assemblics if the demonstration project is successful and NSP gets the required pe mits.

Q.

When will the demonstration project begin? Ecw long will it last?

A. NSP plans to start the six- to-eight-week demonstration project during the su:nter of 1987.

Q. How much will the demonstration project cost?

A. The most the demonstration project could cost is S1.2 million.

However, the cost could be as low as $700,000. The actual cost de p ds on the success of the de:rcnstration and whether NSP decides to continue using the Westinghouse system for future consolidation, if any.

C. Is criticality (a chain reaction) a concern with the fuel reds so close together?

A. No. To have criticality, a moderator is needed to slow dcm the neutrons that split the atcms. At Prairie Island, water is the moderator. By moving the rods closer together, there is less moderator i

between them; therefore the nederator is much less effective and the neutrons cannot cause a chain reaction.

Q. Won't the consolidation add a lot of extra weight / heat to the fuel pool? Can it handle the extra burden?

A. Both the fuel pool and the spent fuel racks were designed with a great deal of reserve strength margin. NSP analysis shcws the pool can hold the extra weight of twice the currently licensed nu-ber of r.ssemblies (1,386 assemblies is the current licensed limit) . The heat generated by spent fuel decreases dramatically cver the first few years the fuel is in storage. NSP will consolidate only older, cooler spent fuel.

If the ccmpany decides to proceed with a full-scale project, it must get state and federal pennits. The pe =dt process will address such issues as increased weight and heat.

Q. hhy dcesn't NbP ship the fuel away frcn the plant as it did at Monticello?

A.

There is no facility to which NSP could ship Prairie Island spent fuel. The Morris, Ill., facility, where NSP has shipped Menticello fuel, soon will be filled under current agreements with its owner, General Electric.

Q. khy doesn't NSP re-rack the fuel pool to hold more asserchlies as it has done before?

A. NSP already has re-racked the Prairie Island spent fuel pool to the fullest extent possible. There is not enough rocn to move whole assemblies any closer together.

Q. Is NSP considering dry cask storage?

A. Dry cask storage involves placing spent fuel in specially designed shielding containers that are drained of water, removed frcm the spent

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fuel pool and stored elsewhere on the plant site. NSP has not eliminated that cption, but believes rod consolidation might be a lcwer-cost alternative.

Q. How will NSP pay for the project?

A. Since 1981, NSP has collected in electric rates funds for the interim storage and ultimate disposal of spent nuclear fuel. The demonstration project and any future fuel consolidation will be paid for using this fund. The project will not result in an increase in custaner rates.

Q. Why didn't NSP build a bigger pool in the first place?

A. At the time NSP built its nuclear plants, the industry planned to reprccess spent nuclear fuel to make new fuel. .Under that plan, spent fuel would have stayed at the plant for only a few months er years I before shipment to a reprocessing center. With the reprocessing 1

assumption, a larger pool was not needed, and spent fuel pcols were si:::ed accordingly. Because of an initial government ban and later poor econanics, large-scale ccnmercial reprocessing never came about. Also, the federal repository siting process has faced repeated delays. NSP and other utilities have had to expand on-site storage. Most utilities, including NSP, chose to install new storage racks that held more fuel assemblies as a first expansion step. Re-racking was an available, relatively low-cost technology. (Rod consolidation technology was not available at that time.)

Q. Will NSP continue to conduct " demonstration projects" as a piecemeal way to expand storage without seeking permission to expand existing space beyond 20 percent?

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~A. No. NSP will conduct just one r5d-consolidation demonstration project. If the demonstration is successful, NSP then will seek required state and federal pennission before consolidating any nere fuel. NSP will use infomation gained frcm the demonstration project in preparing applications to the state and federal agencies. The data should be useful to those agencies in their evaluation of NSP's I applications.

Q. hhat if the demonstration project does not work to NSP's l satisfaction?

1 A. NSP then would evaluate other technologies available for stcrage expansion. Those options include various fo=s of dry storage or the construction of a new pool for storage of older spent fuel.

Q. Scme people say NSP should shut dcwn the nuclear plants. htat would that cost for Prairie Island?

A. Prairie Island consistently produces the cheapest electricity generated in NSP's system. If the ccnpany were forced to shut dcam both units, the cost of replacement power would quickly exceed the. cost of any of the spent fuel storage e.xpansion options.

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