bureaucracy, bureaucrats, California, Diablo Canyon, earthquakes, EIS, GEIS, High Level Nuclear Waste, magwood, major hazard management, NRC, nuclear industry, nuclear lobby, nuclear seismic risk, risk, risk management, Spent Fuel, Spent Fuel Pools, US NRC
The US Nuclear Regulatory Commission Draft Generic Environmental Impact Statement (GEIS), to be voted Tuesday, allows continued at site storage of high level nuclear waste (spent fuel), in already overcrowded spent fuel pools, for up to 140 years before transfer to dry casks is required! This is their timeline:
Tomorrow, August 26th, many will probably breathe a sigh of relief because the concept of finding a deep repository for high level nuclear waste will be dead for 140 years, 240 years, yea even forever and a day, at least in the USA. The US NRC commissioners will vote on a proposal which will allow keeping spent nuclear fuel in spent fuel pools for 140 years before transferring to dry casks. The seismic evaluation seems to have conspicuously failed to consider 4 sites, of which 3 are in western states! California? Diablo! Diablo Canyon?
Diablo Canyon NPP California, NRC photo
The name says it all, unfortunately.
The nuclear industry says that we are all supposed to be dead at age 70, or less, when they are doing their risk calculations, so they are kicking the problem down the road for 2 lifetimes plus. The clear objective of this vote is to allow continued licensing and relicensing of nuclear reactors without addressing the problem of waste. Other countries may decide to follow this solution as a quick easy fix. The nuclear industry will be ecstatic with the work of their NRC lackeys.
“A clean-up crew working to remove radioactive contamination after the Three Mile Island accident“, in 1979. http://en.wikipedia.org/wiki/Nuclear_safety_in_the_United_States
This is what some of the spent fuel looks like, in reality, over time, and lots of time has passed, since nuclear reactors entered operation in the US. On average about 34 years:
“Inventories include SRS fuel assemblies in addition to the thousands of research reactor spent fuel assemblies received from offsite facilities.” http://www.srs.gov/general/programs/spentfuel/ See the rest at the bottom of this post. This is where high level German waste will go: to the Savannah River site.
Visibly Corroding “Spent nuclear fuel stored underwater and uncapped at the Hanford site in Washington, USA, US DOE, Hanford site”
But, before you exhale that sigh of relief, check and see how close you are to a nuclear power plant. And read about these pools in real life:
“Reactor Fuel Pools
► Although designed to hold irradiated fuel for only a few years, US reactor fuel pools still contain at least 75% of all the irradiated fuel generated since 1957, the year of the first US commercial reactor.
► Most fuel pools are so tightly packed with fuel rods that extraordinary precautions must be taken to prevent an inadvertent chain reaction.
► The Nuclear Regulatory Commission does not currently require emergency backup power to run the fuel pool cooling systems, or to supply make-up water, and operate other safety equipment” http://www.beyondnuclear.org/storage/documents/Waste_70YearsHigh_2012.pdf
The 140 years is for any new reactors. On average nuclear reactors will be allowed to keep spent fuel in the fuel pools for only 106 more years, but since they are counting on everyone living to only age 70, or less, no one living today will have to worry with addressing the problem, excepting an accident. The other purpose of the document, of course, is to assure everyone that an accident won’t happen! Is that why they excluded some seismic risks? 140 yrs. max minus 34 yrs. is 106 yrs. As of 2013, “The average age of U.S. commercial reactors is about 33 years. The oldest operating reactors are Oyster Creek in New Jersey, and Nine Mile Point 1 in New York. Both entered commercial service on December 1, 1969. The last newly built reactor to enter service was Watts Bar 1 in Tennessee, in 1996… U.S. commercial nuclear reactors are licensed to operate for 40 years by the U.S. Nuclear Regulatory Commission (NRC). Prior to termination of the original license, companies may apply to the NRC for 20-year license extensions. Last updated: November 7, 2013” http://www.eia.gov/tools/faqs/faq.cfm?id=228&t=21
For the oldest operating US nuclear reactor, the Oyster Creek reactor, spent fuel rods will “only” stay in the spent fuel pool for up to an additional 65 years because it will shut down in 5 years: “The plant first came online on December 1, 1969, and is licensed to operate until April 9, 2029, but Oyster Creek is scheduled to be permanently shut down by December 31, 2019.” http://en.wikipedia.org/wiki/Oyster_Creek_Nuclear_Generating_Station
Recall that in all of the risk calculations of the nuclear industry and its minions, our life span is 70 years or less!
As seen in the diagram on top: “Based on the Atomic Energy Act, the Nuclear Regulatory Commission (NRC) issues licenses for commercial power reactors to operate for up to 40 years and allows these licenses to be renewed for up to another 20 years“. http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/fs-reactor-license-renewal.html So, it is 60 years on top of that. The diagram at the top shows two extensions for a total of 80 years operation! There is a criminal lack of acknowledgement of the aging of materials, of metal and concrete, over time, which is even accelerated by neutron bombardment in nuclear power plants! People should be very worried about the US nuclear reactor, which was partially completed in the 1980s, being completed now. How can it be sound? Concrete ages.
[August 27th update: On August 26th the NRC notes that:”The continued storage rule adopts the findings of the GEIS regarding the environmental impacts of storing spent fuel at any reactor site after the reactor’s licensed period of operations. As a result, those generic impacts do not need to be re-analyzed in the environmental reviews for individual licenses.” Do they or don’t they? It sounds like they will re-license and then require retrofit if there is a problem.]
Here is an excerpt of the NRC nonsense being voted on. RECALL THAT SHORT-TERM TIME FRAME IS UP TO 60 YEARS POST OPERATION! NOTE THAT THEY EXCLUDED THE EARTHQUAKE RISK OF 3 WESTERN SITES – PRESUMABLY INCLUDING EARTHQUAKE PRONE CALIFORNIA – IN THEIR SEISMIC HAZARD ASSESSMENT! [Additional info-attempts at clarifying added on August 27th]
“the NRC determined in NUREG–1738 that based on the generic spent fuel pool fragility analysis, the seismic risk at all but four sites—which included three western plants for which updated seismic hazard information was not available—was below the value consistent with the large early release frequency criterion for managing reactor risk”
[August 27th update: The above was based on a 2001 document. So, they turn around and then say: “Further, the NRC is requiring all operating reactor licensees to perform an updated seismic hazard evaluation for each site, which will include an evaluation of spent fuel pool seismic risk (NRC 2012b). Should new information indicate spent fuel pool risk is significantly greater than
previously considered, the NRC would take the appropriate regulation action to ensure protection to public health and safety“. (pp. F-10-F-11)
BUT THEN THEY SAY:
“Also, after publication of the draft GEIS, the NRC issued COMSECY–13–0030, an NRC study on the potential for requiring expedited transfer of spent fuel from reactor spent fuel pools to dry cask storage (NRC 2013m). In the regulatory analysis in COMSECY–13–0030, the NRC stated that it:
used the U.S. Geological Survey (USGS) 2008 model to evaluate seismic hazards at Central and Eastern U.S. (CEUS) nuclear power plant sites in this analysis. Although the USGS model considers sites in the western United States (including Columbia, Diablo Canyon, Palo Verde, and San Onofre), the staff has not performed the necessary analyses for these sites to include them in this analysis. Considering the robust designs of spent fuel pools, especially in more seismically active areas in the western United States, the staff concludes that public health and safety are adequately protected. Upon completion of the Near-Term Task Force Recommendation 2.1 seismic reevaluation, the staff will confirm that the seismic risk for spent fuel pools is consistent with the risk assumed in this analysis.
Appendix F of the GEIS has been updated to include the more recent information from COMSECY–13–0030 (NRC 2013m). Further, the consequences of a severe earthquake, with resulting spent fuel pool drainage and an uncontrolled zirconium fire, are encompassed by the pool drainage and zirconium fire analysis in Appendix F of the GEIS, including the risk analysis in Table F-1. No changes were made to the Rule as a result of these comments“. (p. D-348) We didn’t find anything of use searching for COMSECY. Since Diablo Canyon is among those up form relicensing we can only surmise that this is bureaucratic double-speak so that they can do as they please in the end. This looks like a huge loophole.
“….The NRC acknowledges that the pools were not intended for long-term or indefinite storage of spent fuel, which is one of the reasons why the NRC assumes that the spent fuel will be removed from the pools by the end of the short-term timeframe. In accordance with the license-termination requirements for power reactors in 10 CFR 50.82(a)(3) and 52.110(c), decommissioning of the power plant, including the spent fuel pool, will be completed within 60 years of permanent cessation of operations. This requirement applies equally to the spent fuel pools at power reactors. Although the regulations at 10 CFR 50.82(a)(3) allow the Commission to extend the time allowed to complete decommissioning and the ‘…unavailability of waste disposal capacity’ is one of the factors to be considered, the Commission will only approve the request when necessary to protect public health and safety. Thus, the GEIS assumes that all spent fuel will be removed from the pool within 60 years, and therefore, the pools would not be used in the long-term or indefinite storage timeframes. Additional information on this assumption and the basis for it can be found in Section D.2.16.10 of this appendix.
Concerning the amount of spent fuel stored in pools, the pool density at each reactor has been subject to site-specific reviews. For example, the NRC assesses the environmental impacts of storage of spent fuel in the pools during operations as part of the initial licensing review. Re-racking to achieve higher density requires the NRC to approve a license amendment. This
review includes an environmental review and as assessment of the possible accidents due to the increased spent fuel density in the pool.
For information on loss of offsite power see Section D.2.35.25 of this appendix. As discussed in Section 18.104.22.168 of the GEIS, in response to the earthquake and subsequent tsunami that damaged the Fukushima Dai-ichi nuclear power facility in Japan, the NRC has placed additional requirements on nuclear power operators to ensure the continued safety of U.S. plants. These include measures applicable to pools, including developing mitigation strategies for severe events and ensuring the reliability of pool instrumentation. The NRC is not aware of any additional studies that would cause it to question the low risk of spent fuel pool accidents. However, the NRC is continuing its work in response to the accident in Japan and will use information it collects to determine whether to update other aspects of power plant design, construction, and operation, including aspects of construction and operation of spent fuel pools.
As explained in Section 22.214.171.124 of the GEIS, the GEIS does not propose or impose safety requirements for the storage of spent fuel, such as expediting the transfer of spent fuel from pools to casks. The GEIS assesses the reasonably foreseeable environmental impacts of continued storage in accordance with current NRC requirements. The impacts of expedited transfer are not within the scope of the GEIS because the NRC does not currently require these actions. The Commission evaluated a staff assessment of expedited transfer in a separate process and issued its decision on May 23, 2014 (NRC 2014b) not to pursue further evaluation of the expedited transfer of spent fuel from pools to dry storage, see Section D.2.50.1 for more information.
For the issue of high-density loading of spent fuel in a pool, the Commission has evaluated the risks of high-density loading in the context of expediting the transfer of spent fuel from a pool to an ISFSI as part of evaluating the lessons learned from the accident at Fukushima. For further discussion on this issue, refer to Section D.2.50.1 of this appendix. No changes were made to the GEIS or Rule as a result of these comments.
D.2.50 Out-of-Scope Comments – HOSS and Expedited Transfer
D.2.50.1 – COMMENT: Commenters expressed concern about the vulnerabilities of spent fuel pools and the density of storage in the pools and stated the NRC should require that spent fuel cool enough to be in dry storage be moved as soon as possible from pools to dry storage. Many commenters favored moving the fuel into HOSS. Commenters described specific aspects of dry cask and spent fuel pool storage, stating that dry cask storage is inherently safer than pool storage because it does not depend on an electricity supply. One commenter noted that cracks have been found in some pools. Commenters cited the risk of a variety of accidents or other events and referred to the effects of the tsunami on the spent fuel pools and dry casks at the Fukushima Dai-ichi nuclear power plant in Japan. Commenters also stated that the GEIS should have included a consideration of expediting the transfer of spent fuel to dry storage and that the NRC’s basis for excluding this from consideration in the GEIS is insufficient. A commenter asserted that the NRC is making a mistake in assuming that an unlikely event will never happen and that this assumption is irresponsible and counter to the NRC’s mission of protecting public safety. Other commenters added that the nuclear power industry should bear the costs of transfer and that hardened dry storage should be employed even if it is more expensive for utilities. In providing their views on pool storage, commenters referred to specific plants, including Calvert Cliffs (Maryland), Peach Bottom (Pennsylvania), San Onofre and Diablo Canyon (California), and Browns Ferry (Alabama) and described their concerns with pools at those sites (e.g., the risk posed by sudden dam failure, lack of hardened structures housing the pools, proximity to facilities such as a natural gas terminal, potential for being used as weapons of mass destruction, climate change concerns, and the potential for pool fires resulting from a loss of water).
Several commenters stated that expedited transfer should be implemented at California plants before California’s next big earthquake occurs. One commenter stated that the California Energy Commission has directed the two plants in California to accelerate the transfer of spent fuel to dry storage and asked if the NRC would ‘stand in California’s way.’
RESPONSE: The NRC expresses no view on these comments. As explained in Section 126.96.36.199 of the GEIS, the GEIS does not propose or impose safety requirements for the storage of spent fuel (e.g., expediting the transfer of spent fuel from pools to casks or into hardened dry storage). The GEIS assesses the reasonably foreseeable environmental impacts of the continued storage of spent fuel in accordance with current NRC requirements. The impacts of expedited transfer and the use of hardened dry storage are not within the scope of the GEIS because the NRC does not currently require these actions.
The NRC acknowledges the concerns about spent fuel storage in pools and agrees that this topic requires careful consideration. The Commission evaluated a staff assessment of this issue in a separate process and issued its decision on May 23, 2014 (NRC 2014b), not to pursue further evaluation of the expedited transfer of spent fuel from pools to dry storage. The Commission also directed the staff to evaluate or provide more information on other aspects of spent fuel pool regulation and operation. Regarding expedited transfer, the Commission stated, ‘The Commission has approved the staff’s recommendation that…no further generic assessments be pursued related to possible regulatory actions to require the expedited transfer of spent fuel to dry cask storage.’ The NRC staff’s conclusion, which was provided to the Commission in COMSECY–13–0030 (NRC 2013m), is that the ‘expedited transfer of spent fuel to dry cask storage would provide only a minor or limited safety benefit…and that its expected implementation costs would not be warranted.’ In the COMSECY, the NRC staff did not assume, as noted in one comment, that an unlikely event will never happen, but instead systematically assessed the probability of unlikely events and weighed that information against the costs and benefits of implementing measures such as expedited transfer. The COMSECY responded to Commission direction (NRC 2011l) to evaluate whether the issue of expedited transfer should be included with the NRC’s Japan lessons-learned activities and whether any regulatory action is recommended or necessary. The NRC staff’s assessment relies on another NRC technical study (NRC 2014a).
The issue of whether states or utilities (e.g., the California Energy Commission) may direct plants to implement the expedited transfer of spent fuel to dry storage is beyond the scope of the GEIS and Rule.
D.2.50.3 – COMMENT: In expressing support for expediting the transfer of spent fuel from pools to dry cask storage, commenters also stated that the NRC should conduct further analysis of dry storage issues. One commenter stated that the NRC should be looking into developing a ‘reliable extreme long-term storage modality,’ and stated that any method that relies upon an uninterrupted electric supply is bound to fail.
RESPONSE: The NRC agrees that further study of long-term storage issues, including dry cask storage, would help the NRC plan for the continued safe storage of spent fuel. In accordance with Commission direction, the NRC staff is separately examining the regulatory framework and potential technical issues related to the extended storage and subsequent transportation of spent fuel. This ongoing research is part of the NRC’s effort to continuously evaluate and update its safety regulations. The NRC is not aware of any deficiencies in its current regulations that would challenge the continued safe storage of spent fuel in spent fuel pools or dry cask systems. If, at some time in the future, the NRC were to identify a concern with the safe storage of spent fuel, the NRC would evaluate the issue and take whatever action or make whatever change in its regulatory program that is necessary to protect public health and safety. The NRC will continue to monitor the ongoing research into spent fuel storage.
As part of its Station Blackout Mitigation rulemaking, the NRC is considering the need to implement additional requirements to address potential issues relating to the extended loss of offsite power. One of the requirements being considered as part of this rulemaking is the need for additional, diverse backup power supplies for the spent fuel pool. Section 188.8.131.52 of the GEIS has been updated to account for this rulemaking, and additional information on the rulemaking can be found on http://www.regulations.gov by searching for docket NRC-2011-0299. No changes were made to the Rule as a result of these comments.
D.2.50.5 – COMMENT: Commenters stated that the NRC should require HOSS and that it should be a top national security priority as an interim measure before the final disposition of spent fuel. The commenters referred to or repeated the specific elements of HOSS contained in the statement of ‘Principles for Safeguarding Nuclear Waste at Reactors’. Some commenters provided additional suggestions for hardening onsite storage (e.g., bolting casks to the pad or using concrete ramps in front of casks to deflect aircraft impacts). Commenters stated the NRC should not continue licensing reactors until HOSS is implemented nationwide. Some commenters expressed concern about water supplies and emphasized that HOSS cannot be a permanent measure near water sources (e.g., noting that there are 33 reactors on the Great Lakes basin). Most commenters favored HOSS and were opposed to transporting spent fuel offsite, but some commenters expressed disagreement with HOSS or support for moving spent fuel to hardened facilities at remote locations.
RESPONSE: As stated in Appendix B of the GEIS, current NRC licensing requirements for storage facilities ensure their robust design, and spent fuel has been stored safely in pools and in dry casks for several decades. See Sections D.2.38.4, D.2.28.5, D.2.38.6, D.2.28.8, and D.2.38.10, and of this appendix for further discussion regarding the safety of dry cask and pool storage. Also as explained in Section 184.108.40.206 of the GEIS, the GEIS does not impose new regulatory standards for spent fuel storage (e.g., requirements to harden onsite or offsite storage in pools and dry casks). The GEIS assumes that technology remains the same throughout the timeframes analyzed and considers the impacts of continued storage in accordance with current NRC requirements. Likewise, technical judgment as to how hardened storage would be implemented (e.g., whether to use concrete ramps, bolt casks in place, locate hardened storage near waterbodies, or hardened storage at or away from reactor sites) and the associated costs, benefits, and environmental impacts are not within the scope of the GEIS, because NRC regulations do not require hardened storage.
As a matter separate from this rulemaking, the NRC is considering, in its update of the ISFSI security requirements, a request that the NRC require HOSS at all power plants and away-from-reactor storage sites (see ‘Petition for Rulemaking Submitted by C–10 Research and Education Foundation, Inc.,’ 77 FR 63254). The proposed Rule, scheduled to be published for comment in 2017, will formally address the petition. The NRC had offered the draft technical basis for this proposed Rule for public comment and has published responses to the comments that were submitted (78 FR 77606). Further information on the rulemaking is provided in comment responses dated November 21, 2013 (NRC 2013u). Consistent with its NEPA responsibilities, the NRC would determine based on that or any related rulemaking whether an update to the GEIS is necessary. No changes were made to the GEIS or Rule as a result of these comments…” (Emphasis our own) http://pbadupws.nrc.gov/docs/ML1418/ML14188B749.pdf
From: “Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel Manuscript Completed: August 2014 Date Published: August 2014, Waste Confidence Directorate Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C.”
WHY ARE THEY WAITING SO MANY YEARS TO ADDRESS HOSS SAFE STORAGE? IS IT SO THAT THEY CAN GRANDFATHER IN ANY LICENSES GIVEN PRIOR TO FINALIZING THE RULE?SHOULDN’T THEY HAVE ADDRESSED HOSS INSTEAD OF WRITING THIS B.S. pseudo EIS?
A LIST OF THE 40 BULLSHIT ARTIST, OVERPAID, BUREAUCRATS WHO WROTE THIS THING AND NEED TO BE FIRED, IS FOUND AT THE END OF THE ABOVE DOCUMENT. The B.S., beside the names of many, apparently does NOT stand for Bachelor of Science. While they may only earn enough for a middle class life-style, most educated, hard-working, people haven’t earned that for decades. Plus they get good retirement. Those who want to save US taxpayers money? One worker could have done a better job than the nonsense that it took 40 US bureaucrats to produce. Organize to fire these 40 bullshit artists! No one should expect better than this from the pro-nuclear NRC anyway, so why bother to give them jobs? Just hire people to monitor the power plants and waste. Probably the same bullshit artists wrote the Generic Dewey Burdock EIS for In Situ Leach uranium mining. Lest anyone be impressed that they included comments – they had something like 13 public meetings and 30,000 comments, so they had to include some. (This number is based on memory and may be inexact, but there were many).
Since the NRC bureaucrats failed to address this question, our understanding is that the radiation regulations can be more strict in states than on the federal level, but not less strict.
From the Real World of the Savannah River Site:
“Spent Fuel Management
The Savannah River Site provides for the safe receipt and interim storage of irradiated spent nuclear fuel (SNF) assemblies from domestic and foreign test and research reactors. The fuel is stored in underwater facilities until it is stabilized for final disposition.
SRS’s spent nuclear fuel is managed under various National Environmental Policy Act documents, including the SNF Programmatic Environmental Impact Statement, the Foreign Research Reactor Environmental Impact Statement, the Interim Management of Nuclear Materials Environmental Impact Statement, and the SRS SNF Environmental Impact Statement.
Underwater storage facilities, called disassembly basins, are located in all five of SRS’s reactor areas. These facilities were designed to store spent nuclear fuel and target assemblies discharged from the reactor cores. This storage allowed the nuclear material to cool after being irradiated in the reactors. The basins were also used to prepare the nuclear materials for transport to the F and H Areas processing facilities.
Only L Basin still contains and receives fuel material. The basins have concrete walls 3 feet thick and hold 3.5 million gallons of water with pool depths of 17 to 30 feet. Although all assemblies are now ‘cold’ enough to no longer require water cooling, water provides shielding to protect workers from radiation.
Each basin has four main sections used to receive, prepare, and store the fuel. The fuel assemblies are transferred through these sections via narrow vertical gateways used to isolate the sections.
In 1996, the L Basin equipment was reconfigured to safely handle and store spent nuclear fuel (SNF) from off-site (foreign and domestic) research reactors. The first off-site fuel was received and stored in February 1997.
Inventories include SRS fuel assemblies in addition to the thousands of research reactor spent fuel assemblies received from offsite facilities. Additionally, the basins contain other miscellaneous nuclear materials, some of which will require special handling and disposal. Thousands more assemblies are projected to be received and stored in L Basin in the next decade.” http://www.srs.gov/general/programs/spentfuel/ (Emphasis added).
August 27, 2014 postscript:
The NRC document, “Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel, August 2014, Waste Confidence Directorate Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C.” is available online. We recommend that you download your own copy to arrive at your own conclusions. It is 1,310 pages long. We could spend months just picking this or other long-winded NRC documents apart, but there are too many important things going on. If nothing else it is an example of the adage that too many cooks spoil the soup as there were 40 individuals who participated in writing it. We have not read it in its entirety, but rather skimmed through many times and searched for key words. (We have recently read through a similarly idiotic, long-winded, GEIS for ISL uranium mining by the NRC so our patience is thread-bare with their foolishness). Beware that it seems misleading, deceptive and contradictory. For instance they define “short-term” storage as 60 years. For nuclear it is very short-term but when most people see “short-term” they are not thinking 60 years, but in days or months. The 40 individuals who wrote it should be fired, but are probably kept on because of their apparent doublespeak incompetence. One good worker could have written a coherent document in a short time.