ML032590717

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G20030547/LTR-03-0588 - Rep. Robert E. Andrews Ltr Opposition of the Proposed Storage Methods of Spent Fuel at Hope Creek (Norm Cohen)
ML032590717
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 09/04/2003
From: Andrews R
US HR (House of Representatives)
To: Rathbun D
Office of Congressional Affairs
References
G20030547, LTR-03-0588
Download: ML032590717 (13)


Text

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EDO Principal Correspondence Control FROM: DUE: 10/06/03 EDO CONTROL: G20030547 DOC DT: 09/04/03 FINAL REPLY:

Representative Robert Andrews TO:

Rathbun, OCA FOR SIGNATURE OF : ** GRN ** CRC NO: 03-0588 Travers, EDO DESC: ROUTING:

Hope Creek - Storage Methods of Spent Fuel Travers (Norm Cohen) Norry Paperiello Kane Collins Dean DATE: 09/12/03 Burns/Cyr Miller, RI ASSIGNED TO: CONTACT:

NMSS Virgilio SPECIAL INSTRUCTIONS OR REMARKS:

Thr.( Io~t~& I'.o "oI i & Its i SE01,0 I

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OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET DatePrinted:Sep 11, 2003 17.04 PAPER NUMBER: LTR-03-0588 LOGGING DATE: 09/111/2003 ACTION OFFICE: EDO AUTHOR: Robert Andrews AFFILIATION: REP ADDRESSEE: Dennis Rathbun

SUBJECT:

Hope Creek reactor ACTION: Signature of EDO DISTRIBUTION: OCA to Ack LETTER DATE: 09/04/2003 ACKNOWLEDGED No SPECIAL HANDLING:

NOTES:

FILE LOCATION: ADAMS DATE DUE: 10/0612003 DATE SIGNED:

EDO -- G20030547

ROBERT E. ANDREWS PLEASE REPLY TO:

FIRST DISTRICT, NEW JERSEY o 2439 RAYBURN HOUSE OFFICEBUILDING COuMwrIES: WASHINGTON, DC 20515 EDUCATION AND THE WORKFORCE (202) 225-4501 SoNion IAm Na DaEmocA SUsCOMMmmEON EMrOYER-EMPwSnE RELATrONS MEMISS SUSCOMMmESON 21STCENTURY (Conarre of thie UJntiteb otateg; O 606-A WHITE HORSE PIKE HADDON HEIGHTS,NJ 08035 COMipETIVrNESs SELECT COMMrI1TE ON jbouae of 3atpreaentafibtf; be

}0 (856) 5465100 63 NORTHBROAD STEET WOODBURY, NJ 08096 HOMELAND SECURITY KEwan, SUsCOMMmiEEON CYBERSEMcUTY, SCENCE, WJha~ijngton, -DQ 20515-3001 (856) 848-3900 ANo RESEARCH&DEVLOPMENT E4WAIL MEMWS SUDCOMMSEA ON INMTELUENCE AND COUNTERTERRORISM rob.andreBws mail.house.gov September 4, 2003 Mr. Dennis Rathbun, Director Nuclear Regulatory Commission Office Of Congressional Affairs 11555 Rockville Pike Mail Stop 017A1 Rockville, MD 20852 Director Rathbun:

I write to you on behalf of Mr. Norm Cohen who has contacted my office for assistance regarding the Hope Creek reactor in Southern New Jersey.

Mr. Cohen opposes the proposed storage methods of spent fuel, specifically the use of above ground "dry cask" storage units. I would appreciate any effort taken to review and address Mr. Cohen's concerns.

Please respond directly to Mr. Cohen at 321 Barr -Ave. in Linwood, NJ 08221 and kindly provide a copy of your reply for my Woodbury District Office. Thank you in advance for your attention to this matter.

,@cerel 4/67 -00 Robert Andrews Member of Congre REA:fd Enclosures THIS STATIONERY PRINTED ON PAPER MADE OF RECYCLED FIBERS

'ROBERT E. ANDREWS PLEASE REPLY TO:

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UD -L kA 6- " 6rq H -O X C. -P C 0 oe-d tJ f -% t 7-Please describe exactly how Congressman Andrews can assist you. Attach copies of any accompanying documentation.

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THIS STATIONERY PRINTED ON PAPER MADE OF RECYCLED FIBERS

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CLOSE THE SALEM NUKES NOW The UNPLUG SALEM Campaign 321 Barr Ave., Linwood NJ 08221 609-601485831601-8537; ncohen12@comcast.net http:lAwiw.unptugsafem.orgl Date: 06123/03

Dear Congressman Andrews,

At a sparsely attend and poorly advertised "public meeting" at the NRC regional headquarters In King of Prussia last week, PSEG outlined their plans for building above ground "dry cask" storage for their spent nuclear fuel. The Hope Creek reactor will run out of room Intheir spent fuel pool by 2007, and the two Salem units Inthe early 2010s.

On behalf of the 109 organizations of the UNPLUG Salem Campaign, we of course would prefer that PSEG decommission their nuclear plants when they run out of room Intheir spent fuel pool, rather than add on aboveground dry cask storage, which merely becomes one more terrorist target and begins the process whereby Artificial Island will become a permanent repository of high level nuclear waste.

Inthe very least, IfPSEG Is permitted by the NRC to construct dry cask storage, the storage should be as robust as possible to resist any tertorist attack Enclosed is a copy of the summary report of a recent study discussing exactly how that could be achieved.

Thus, we ask ifyou would do the following to help make sure that IfPSEG builds dry cask storage, that this storage Is as safe as possible:-

(1) Please write letters to the NRC, PSEG, Lower Alloways Creek Township Committee, and the Salem County Freeholder Board, requesting a public meeting on PSEG's plans for dry cask storage to be held at an accessible location In Salem County, as opposed to King of Prussia, so that concerned South Jersey cItizens can be briefed on PSEG's plans. Please ask that any additional meetings on the dry cask storage be held InSalem County, not King of Prussia.

(2) Please write letters to the NRC, PSEG, Lower Alloways Creek Township, and the Salem County Freeholder Board to require that the dry cask system Installed at Artificial Island be of the robust system as described in the enclosed report

CLOSE THE SALEM NUKES NOW - The UNPLUG SALEM Campaign 321 Barr Ave., Unwood N3 08221 609-601-8583/601-8537; ncohenl2@comcastnet http://www.unplugsalem.org/

tHo wE mE: The UNPLUG Salem Campaign - Close the Salem Nukes Now Is a network of (as of 61102) 108 organizations: national, regional, local, environmental, religious, student, political and civic, who work on Issues concerning the two Salem Nuclear Plants, and the effects these nuclear plants have on the citkens of Delaware and Southern New Jersey.

W1EAT ARE OUR GOALS:

(1) To shut down the aging and dangerous Salem Nudear Rants. These two plants have a history of problems. Salem Unit 2's steam generator is defective; Both plants have defective fire barriers; Both plants continue to age and degrade; Both plants are not hardened against a 91 1-type attack and are terrorist targets.

(2) To Stop the Salem Nuke Fish Slaughter. PSEG needs to obey the aean Water Act and Install cooling towers. This wHll end 95% of the slaughter of billions of fish, other marine life, and endangered species caused by Salem's obsolete once-through cooling system.

(3) To act as a safety and public health watchdog. Cancer rates in Salem County, NJ, and In New Castle County, Del., are higher than the national average. Salem 1 and 2 emit continuous streams of low-level radiation, which weakens the immune systems of those most at risk - fetuses, infants, and the elderly.

(4) To promote alternative forms of energy. We support the 20-20 plan. 20% of our nation's electricity could be produced by alternatives by 2020, thus allowing the safe phase-out of nuclear power, starting with the oldest and most dangerous nukes first We need to Invest in wind, solar, wave, thermal, and other ugreeni alternatives.

WHEA WE DO: We work to educate the public about the safety and health issues concerning the Salem Nukes. We lobby Congress and our State politicians. We intervene with the Nuclear. Regulatory Commission and the New Jersey and Delaware Departments of Environmental Protectiol. We testify at official hearings. We hold protests and educate. We'll keep at it until these nukes are closed.

JOIN CLOSE THE SALEM NUKES NOW - THE UNPLUG SALEM CAMPAIGN Name Address Phone Email/Fax__

Individual Member (25.00) Family Membership (35.00)

Sustainer (100.00) Senior/Student/Fixed Income (10.00)

Visa/MasterCard available. Please write down your card number and expiration date. For a tax deduction, please make your check payable to "PAEF". Please mail to UNPLUG Salem Campaign, 321 Barr Ave, Linwood 08221.

ORGANIZATIONS - PLEASE JOIN THE UNPLUG Salem Campaign Organization Name Contact Person_

Address Phone Email/Fax - Number of Members

INSTITUTE FOR RESOURCE AND SECURITY STUDIES 27 Ellsworth Avenue, Cambridge, Massachusetts 02139, USA Phone: 617-491-5177 Fax: 617491-6904 Email: irss@igcorg ROBUST STORAGE OF SPENT NUCLEAR FUEL:

A Neglected Issue of Homeland Security by Gordon Thompson January 2003 (A report commissioned by Citizens Awareness Network)

EXECUTIVE

SUMMARY

The 103 nuclear power plants operating in the USA contain massive amounts of radioactive material in their reactor cores. In addition, the reactors have discharged more than 43,000 tonnes of irradiated fuel, containing an amount of long-lived radioactive material that substantially exceeds the amount in the reactor cores. This irradiated fuel is commonly described as 'spent fuel",

because it is no longer suitable for generating fission power. Cumulative national production of spent fuel is likely to exceed 80,000 tonnes over the currently-licensed lifetimes of existing nuclear power plants.

Most of the nation's spent fuel is now stored in high-density spent-fuel pools adjacent to the reactors, and the plant owners intend to continue using these pools at high density. As the pools become full, plant owners are building independent spent fuel storage installations (ISFSIs) to accommodate the growing inventory of spent fuel. Present and proposed ISFSIs are generally at reactor sites, but away-from-reactor ISFSIs may be established at Skull Valley, Utah, and elsewhere. In the USA, ISFSIs store spent fuel under dry conditions inside storage modules that are arrayed on concrete pads in the open air.

This situation poses a very high risk to people and the environment, because the loss of water from a high-density pool will cause spent fuel in the pool to heat up, self-ignite, burn and release a huge amount of long-lived radioactive material -- including tens of millions of Curies of the isotope cesium-137 -- to the atmosphere. Water could be lost from a pool by evaporation, displacement, siphoning, pumping, a breach in the pool floor or wall, or overturning of the pool. These mechanisms could be exploited in various ways by knowledgeable and determined attackers, who could thereby create a pool fire that contaminates large areas of US territory with radioactive material. Nuclear reactors are also vulnerable to attack. A successful attack

Robust Storage of Spent Nuclear Fuel A Report by IRSS, January 2003 Executive Summary Page ES-2 on an operating reactor would release large amounts of short- and long-lived radioactive material to the atmosphere. Knowledgeable and determined attackers could achieve this result in a variety of ways. Table 1 shows some potential modes of attack.

The safe operation of a reactor or a spent-fuel pool depends upon the continuing availability of cooling water, electrical power and operator attention. By contrast, ISFSI modules are passively cooled by natural circulation of air. Nevertheless, these modules are not designed to resist a determined attack. Moreover, ISFSI modules are comparatively easy to attack, because they are stored in the open air in a closely-spaced array.

Thus, nuclear power plants and their spent fuel can be regarded as pre-deployed radiological weapons that await activation by an enemy. The US government acts as if it were unaware of this threat. Responsibility for overseeing the security of civilian nuclear facilities has been delegated to the US Nuclear Regulatory Commission (NRC). This agency has a longstanding policy of not requiring its licensees to protect their facilities against enemy attack, and has continued this policy with little change since the terrorist attacks of September 2001. As a result, US nuclear facilities are lightly defended and are not robust against attack. This situation is symptomatic of an unbalanced US strategy for national security, in which offensive capabilities are assigned a higher priority than homeland defense. The lack of balance is a potentially destabilizing factor in the current international environment, because It could promote an escalating spiral of violence.

Moreover, a weak defense of the homeland exposes US citizens to a variety of threats. In the case of nuclear facilities, the lack of defense exposes US citizens to the risk that an enemy will create widespread radioactive contamination.

This report offers a way forward in an important area of national defense.

Specifically, the report articulates a strategy for providing robust storage of US spent fuel, where the word robust' means that a facility for storing spent fuel is designed so as to be resistant to attack. Implementation of robust storage will be needed whether or not a repository is opened at Yucca Mountain, Nevada. The proposed robust-storage strategy should be implemented as a major element of a four-component strategy for the security of each US civilian nuclear facility. The four components are: site security; facility robustness; damage control; and offsite emergency response. Together, these components could provide a defense in depth for each nuclear facility, within the context of a national-security strategy that provides solid protection of our homeland. Figure 1 shows how robust storage of spent fuel would contribute to the national security of the USA.

Robust Storage of Spent Nuclear Fuel A Report by IRSS, January 2003 Executive Summary Page ES-3 A strategy for nuclear-facility security will have as its objective the reduction of the risk of a release of radioactive material. In the case of a reactor, the risk can be almost completely eliminated by shutting down the reactor and removing its fuel. In the case of spent fuel, the risk can be reduced but can never be eliminated. A strategy for robust storage of spent fuel must be judged by the extent to which it reduces risk. The strategy should assign the highest priority to reducing the highest risk.

The highest priority of a robust-storage strategy would be to re-equip spent-fuel pools with low-density, open-frame racks, as was the case when the present generation of nuclear plants began operating. This step would prevent fuel from igniting and burning if water were lost from a pool. Fuel that can no longer be accommodated in the pools would be stored in ISFSIs.

Each pool would continue to operate at low density while its associated reactor remained operational, to provide storage space for fuel discharged from the reactor. After storage in the pool for several years, to allow its level of radioactive-decay heat to decline, fuel would be transferred to an ISFSI.

As a further measure of risk reduction, ISFSIs should be designed to incorporate hardening and dispersal. 'Hardening' means that each fuel-storage module would be shielded from attack by layers of concrete, steel, gravel or other materials. Dispersal' means that fuel-storage modules would not be concentrated at one location, but would be spread more uniformly across a site.

Hardening and dispersal of ISFSIs should not be conducted in a manner that encourages society to extend the life of an ISFSI until it becomes, by default, a repository. Therefore, a hardened ISFSI should not, unless absolutely necessary, be built underground. Also, the cost of implementing hardening and dispersal should be minimized, consistent with meeting performance objectives, and the timeframe for implementation should be similarly minimized. These considerations argue for the use, if possible, of dry-storage modules that are already approved by the NRC and are in common use.

The design of a hardened, dispersed ISFSI would be governed by a design-basis threat (DBT). This report articulates a two-tiered DBT. The first tier requires high confidence that no more than a small release of radioactive material would occur in the event of a direct attack on the ISFSI by a TOW (anti-tank) missile, a manually-placed charge, a vehicle bomb, an explosive-laden general-aviation aircraft or a fuel-laden commercial aircraft. The second tier requires reasonable confidence that no more than a specified release of radioactive material would occur in the event of a ground burst of a 10-kilotonne nuclear weapon at the ISFSI.

Robust Storage of Spent Nuclear Fuel A Report by IRSS, January 2003 Executive Summary Page ES-4 An ISFSI design approach that offers a prospect of meeting this DBT involves an array of vertical-axis dry-storage modules at a center-to-center spacing of perhaps 25 meters. Each module would be on a concrete pad slightly above ground level, and would be surrounded by a concentric tube surmounted by a cap, both being made of steel and concrete. This tube would be backed up by a conical mound made of earth, gravel and rocks. Channels for air cooling would be inclined, to prevent pooling of jet fuel, and would be configured to preclude line-of-sight access to the dry-storage module. Figure 2 provides a schematic view of the proposed design.

An alternative design approach might be used at a few reactor sites where space is insufficient to allow wide dispersal. In this approach, a number of dry-storage modules would be co-located in an underground, reinforced-concrete bunker. Similar bunkers would be dispersed across the site to the extent allowed by the site's geography. At especially-constricted sites, it could be necessary to ship some spent fuel from the site to an ISFSI at another location.

Any ISFSI, whether at a reactor site or an away-from-reactor site, should employ hardened, dispersed, dry storage. The design of an away-from-reactor ISFSI could, because the facility is entirely new, provide a degree of dispersal and a level of site security that may be difficult to achieve at some reactor sites. However, there are factors that argue against developing an away-from-reactor ISFSI: (I) overall transport risk would be increased, because fuel would be shipped twice before arriving at a repository; (ii) the massive amount of radioactive material concentrated at this ISFSI could provide an attractive target for an enemy; (ill) this ISFSI would not eliminate the need for at-reactor ISFSIs; (iv) this ISFSI could become, by default, an unsafe repository; and (v) storage in this ISFSI could be more expensive than storage at reactor sites.

Three major requirements must be met if a robust-storage strategy for spent fuel is to be implemented nationwide. First, full-scale experiments are needed to determine the ability of various dry-storage design approaches to accommodate various DBTs. Second, performance-based specifications for robust storage, addressing both short- and long-term risks, must be developed with stakeholder input. Third, robust storage of spent fuel must be seen as an important component of national security, to ensure that sufficient funding is available and robust storage is implemented quickly.

Robust Storage of Spent Nuclear Fuel A Report by IRSS, January 2003 Executive Summary Page ES-5 MODE OF ATTACK CHARACTERISTICS PRESENT DEFENSE Commando-style attack

  • Could involve heavy Alarms, fences and weapons and lightly-armed guards, sophisticated tactics with offsite backup
  • Successful attack would require substantial planning and resources Land-vehicle bomb
  • Readily obtainable Vehicle barriers at entry
  • Highly destructive if points to Protected Area detonated at target Anti-tank missile
  • Readily obtainable None if missile
  • Highly destructive at launched from offsite point of impact Commercial aircraft
  • More difficult to None obtain than pre-9/11
  • Can destroy larger, softer targets Explosive-laden smaller
  • Readily obtainable None aircraft
  • Can destroy smaller, harder targets 10-kilotonne nuclear
  • Difficult to obtain None weapon
  • Assured destruction if detonated at target TABLE 1 SOME POTENTIAL MODES OF ATTACK ON CIVILIAN NUCLEAR FACILITIES

Robust Storage of Spent Nuclear Fuel A Report by IRSS, January 2003 Executive Summary Page ES-6 FIGURE 1 ROBUST STORAGE OF SPENT FUEL IN THE CONTEXT OF NATIONAL SECURITY

Robust Storage of Spent Nuclear Fuel A Report by IRSS, January 2003 Executive Summary Page ES-7 Ground FIGURE 2 SCHEMATIC VIEW OF PROPOSED DESIGN FOR HARDENED, DRY STORAGE Notes

1. Cooling channels would be inclined, to prevent pooling of jet fuel, and would be configured to preclude line-of-sight access to the dry-storage module.
2. The tube, cap and pad surrounding the dry-storage module would be tied together with steel rods, and spacer blocks would prevent the module from moving inside the tube.
3. The steel/concrete tube could be buttressed by several triangular panels connecting the tube and the base pad.