Targets – Danger and Vulnerability
Spent Fuel – the danger
Estimates of Costs and Latent Cancers Following Releases of Cesium-137 from Pilgrim’s Spent-Fuel Pool
It is important to note that the curve from a 10% to 100% release is not a straight line. A smaller per-cent release of Cs-137 would be proportionately less but still very significant. And, most important, the consequence analysis by Dr. Jan Beyea focused solely on Cs-137 and only on cancer. We know that other dangerous isotopes would be released in a severe accident and other health effects expected.
[Source: The Massachusetts Attorney General’s Request for a Hearing and Petition for Leave to Intervene With respect to Entergy Nuclear Operations Inc.’s Application for Renewal of the Pilgrim Nuclear Power Plants Operating License and Petition for Backfit Order Requiring New Design features to Protect Against Spent Fuel Pool Accidents, Docket No. 50-293, May 26, 2006 includes a Report to The Massachusetts Attorney General On The Potential Consequences Of A Spent Fuel Pool Fire At The Pilgrim Or Vermont Yankee Nuclear Plant, Jan Beyea, PhD., May 25, 2006. NRC Document library at: http://www.nrc.gov/reading-rm/adams/web-based.html. Adams Accession Number ML061630088]
Reactor Core – the danger
Support Systems –the danger
7. Nuclear Power Plant Security: Voices from Inside the Fences, September 12, 2003 Project on Government Oversight (POGO), p.9
8. Mark Golden, “POWER POINTS: Airplane Attack Exposes Nuclear Plant Myth,” Dow Jones Newswires 14-09-01, Dow Jones Newswires; 201-938-4604
Independent Spent Fuel Storage Installations (ISFSI) - the danger
An ISFSI poses a radiological risk that is lower than the risk posed by a spent-fuel pool packed at high density. Nevertheless, options are available for reducing the risk associated with malice-induced accidents at an ISFSI. NRC refuses to consider these options in an EIS. Also, NRC attempts to hide the vulnerabilities of existing ISFSIs under a veil of secrecy.
Option to reduce risk ISFI
Options for designing an ISFSI to resist attack have been identified by Dr. Gordon Thompson as follows: "re-design of the ISFSI to use thick-walled metal casks, dispersal of the casks, and protection of the casks by berms or bunkers in a configuration such that pooling of aircraft fuel would not occur in the event of an aircraft impact".
Holtec has developed a design for a new ISFSI storage module that is said to be more robust against attack than present modules. The new module is the HI-STORM 100U module, which would employ the same MPC as is used in the present Holtec modules. For most of its height, the 100U module would be underground. Holtec has described the robustness of the 100U module as follows, "Release of radioactivity from the HI-STORM 100U by any mechanical means (crashing aircraft, missile, etc.) is virtually impossible. The only access path into the cavity for a missile is vertically downward, which is guarded by an arched, concrete-fortified steel lid weighing in excess of 10 tons. The lid design, at present configured to easily thwart a crashing aircraft, can be further buttressed to withstand more severe battlefield weapons, if required in the future for homeland security considerations. The lid is engineered to be conveniently replaceable by a later model, if the potency of threat is deemed to escalate to levels that are considered non-credible today."
[Holtec International,"The HI-STORM 100 Storage System", accessed at <http://www.holtecinternational.com/hstorm100.html> on June 17, 2007. (Holtec FSAR) Holtec International, Final Safety Analysis Report for the Holtec International Storage and Transfer Operation Reinforced Module Cask System (HI-STORM 100 Cask System),NRC Docket No. 72-1014, Holtec Report HI-2002444 (Holtec, undated). ]
C-10 Research and Education Foundation Petition for NRC Rulemaking to Upgrade Interim Dry Cask Storage Code Requirements -Submit Comments by May 18, 2009
The C-10 Research and Education Foundation Inc. Petition for NRC Rulemaking to Upgrade Interim Dry Cask Storage Code Requirements
[Federal Register: March 3, 2009 (Volume 74, Number 40)]
SUMMARY: The Nuclear Regulatory Commission (NRC) has received and requests public comment on a petition for rulemaking dated November 24, 2008, filed by the C-10 Research and Education Foundation, Inc. (petitioner). The petition was docketed by the NRC and has been assigned Docket No. PRM-72-6. The petitioner is requesting that the NRC amend the regulations that govern licensing requirements for the independent storage of spent nuclear fuel, high-level radioactive waste, and reactor-related greater than class C waste. The petitioner believes that the current regulations do not provide sufficient requirements for safe storage of spent nuclear fuel in dry cask storage or in independent spent fuel storage installations (ISFSIs). The petitioner states that the NRC does not adequately enforce the current regulations that govern dry cask storage by allowing manufacturers, vendors, and licensees to use alternatives to the American Society of Mechanical Engineers (ASME) Code. The petitioner also states that the NRC has not specified license requirements for multiple cask designs under different expiration dates at the same ISFSI, has not adequately
considered age-related degradation of dry cask systems, and has no requirements in place to address sabotage and adverse environmental effects on ISFSIs and current and future dry cask storage systems.
DATES: Submit comments by May 18, 2009. Comments received after this date will be considered if it is practical to do so, but assurance of consideration cannot be given except as to comments received on or before this date.