To read Supplemental filing of April 19, 2005 to NRC regarding the August 10, 2004 petition on the vulnerability of GE boiling water reactors as confirmed by findings in the National Academy of Sciences April 2005 public version of its classified report to Congress “The Safety and Security of Spent Nuclear Fuel Storage,” visit
http://www.nirs.org/reactorwatch/security/nscnas2206sup08102004.pdf

Safer Storage Solutions

The risk to the public can be greatly reduced by requiring low-density pool storage for 
recently unloaded fuel and secured dry casks for the rest.

Advantages

	Avoids tight packing of thousands of assemblies in the pool, where loss of coolant  water/exposure to air would cause them to ignite within a few hours due to the reaction  between water, air and immense heat. A fire could not be put out – the area would be too  radioactive.
	Because the spent fuel pool is located inside the main reactor building, a spent fuel  pool accident is likely to result in a core accident, too.
	Dry storage minimizes the chance of an accident with thousands of assemblies: There  are generally only 2 dozen assemblies in each dry cask, compared to Pilgrim’s pool that has  2,278 today and will have 3,859 by 2012. An accident would result in the release of 10 times  more high-level radioactivity than released in Chernobyl – contaminating an area (3) times  Massachusetts.
	No risk for dry casks in case of power outage. Waste assemblies cooled by passive  air convection.
	Since there are no moving parts such as fans, pumps or blowers, dry storage has no  risk of mechanical breakdowns – they are cheaper to maintain.
	Dry storage is in use extensively in the US – at decommissioned plants and at over a  dozen operating plants. No others are building new pools.
	The NRC admits dry storage has fewer failure modes. The NRC has approved a range of  dry storage designs.
	Casks can be multi-purpose, suitable for both storage and shipment. Spent fuel rods  will have to be put into casks eventually for transport to a permanent repository. Pilgrim  should be required to place the rods in casks now rather than wait until later, when it could  be too late.
	Low-density pool storage was once a common practice at nuclear plants and poses a  lower level of hazard than high-density pool storage.

Dry Casks Need to Be Secured or Hardened - two proposals

Dry Casks

Typically when industry moves to dry cask storage, they place the casks on a concrete pad – 
like bowling pins waiting for a strike. However, it is not September 10th; therefore it is 
necessary to place them in a less vulnerable position. The schematic below by Dr. Gordon 
Thompson makes sense.

PROPOSAL #1
Dispersed Hardened Cask Storage Proposal

SCHEMATIC VIEW OF PROPOSED DESIGN
FOR HARDENED, DRY STORAGE

ROBUST STORAGE OF SPENT NUCLEAR FUEL: An Interim Report
Gordon Thompson, November 2002 (A report commissioned by Citizens Awareness Network)


Disperse casks so that they are a more difficult target. Pilgrim has plenty of room; it sits 
on 1600 acres.

PROPOSAL #2
Holtec Underground Storage Proposal

Holtec International, a major cask design and manufacturing company, will ask the NRC to approve an underground design for a dry storage cask facility (NuclearFuel, Vol. 29, Number 9, April 26, 2004).

According to Holtec’s President/CEO the design is a low-profile system – all but two feet of which would be below ground – offers “the next level of protection against terrorist attacks.”

The new system uses the same inner canister and ancillary equipment NRC has already approved as part of their Hi-Storm 100 cask system. The new system known as Hi-Storm 100U, uses a large concrete block with metal-lined cavities to hold spent fuel storage canisters. Once the canisters are in place, a lid is secured to each cavity. Canisters are passively cooled and can hold the same heat load as the existing system.

Holtec says that the system can be used at any site, even on a coastal plain or site with a high water table, because the metal canisters are welded and completely sealed off from the surrounding substrate. Preservatives will be applied to protect the concrete from groundwater. A surveillance program would monitor fro groundwater.

Some industry spokespersons commented that the underground design “potentially fuels misperceptions” among the public that spent fuel already in dry storage needs to be made more secure…

Will we again see public safety enhancements go by the board due to pressure from industry to justify business as usual – perpetuating the cheapest way out?

Finances – Who will pay for Safer Dry Storage?

The electricity market has been deregulated and this works against public safety. In a deregulated market there is no longer a pool of captive customers to pay for uneconomic operating costs or expensive capital additions – like secured dry casks. Also the owners of Pilgrim are limited liability companies with little to no cash reserves. Hence there is resistance to move wastes to safer dry storage. Either they have to be forced to do so by regulators or use federal monies.

There is a precedent for using federal monies for public safety especially post 9/11. The federal government promised that a federal repository would be ready by 1998. It wasn’t. Hence it is reasonable to argue that dry casks for waste generated under the current license should be paid for by federal monies, in total or in part.
 

Currently casks cost 1 to 2 million dollars per cask. Pilgrim NPS, for example, has 
approximately 440 tons of fuel which would cost about $71 million dollars to place it all into dry cask storage.
 

Yucca Mountain
Proposed Federal Repository, Won’t Solve Waste Problem –any time soon

Yucca is not a sure thing – legal suits are pending. Yucca would not open until 2010 at the earliest. It will take 30-40 years to transfer waste from around the nation.

We do not know where Pilgrim will be on the federal shipping schedule. Plant owners can sell or trade their place. They do not have to unload the entire inventory either. Pilgrim’s operating license ends 2012. However in 2005, they are likely to start the application process to extend their license – produce more waste.
 
Furthermore, Yucca, if it is ever built, will run out of room before it can take the spent fuel from existing reactors, to say nothing about the waste from re-licensed reactors. 

As of 2002, there were 44,000 metric tons of commercial spent fuel and 12,000 metric tons of defense waste slated for Yucca. The nation’s nuclear reactors generate 2,000 metric tons each year (Nuclear Energy Institute, “Common Objections to the Yucca Mountain Project” What Science Really Says,” 2003). By 2013 the total waste generated by our nation’s nuclear reactors will have exceeded the 77,000 ton limit for Yucca designated by Congress. Therefore, Yucca will not provide storage for any waste generated after 2013. At present 20 nuclear reactors are licensed to operate beyond 2025. This means that now we do not have one repository and we will need two. Plymouth will be a long-term waste site. It must be stored more safely.

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Yucca Mountain Lawsuit; Court Overrules Government's Lax Radiation Standards for Nuclear Waste - July, 2004


July 9, 2004 the U.S. Court of Appeals for the D.C. Circuit ruled that the U.S. Environmental Protection Agency (EPA) illegally set its radiation release standards for groundwater for the proposed high-level radioactive waste site at Yucca Mountain, Nevada.

The EPA set 10,000 years as the period during which radiation in the groundwater cannot exceed drinking water standards at the site's boundary, but this time frame would not protect the health of future generations. As the court ruled, the Energy Policy Act requires that the EPA determine public health and safety standards for Yucca Mountain "based upon and consistent with" the National Academy of Sciences" recommendations. The Academy's recommendation is that the compliance period should extend through the time of the peak risk for radiation doses from the repository - 300,000 years or more.