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Reducing Risks
from Storage of High-level Waste
at Progress Energy’s Nuclear Power Facilities
A Position Paper: September 4, 2003
Summary
NC WARN welcomed the April announcement that the Progress Energy corporation
intends to cease overland shipments of “spent” nuclear fuel assemblies from
the Brunswick (Southport, NC) and H. R. Robinson (Hartsville, SC) power
plants to the Shearon Harris plant (Wake County, NC).
This is an essential first step towards reducing the potential for large
radiological releases associated with storing irradiated nuclear fuel rods –
the most concentrated form of high-level nuclear waste. Progress now has
the opportunity to set the industry standard for minimizing these risks.
The nuclear industry does not bear sole responsibility for public safety,
however. Federal, state and local officials also have important roles in
this domestic security issue.
Progress Energy plans to increase storage capacity at Robinson and Brunswick
by instituting dry storage, possibly beginning in 2004, but apparently only
for the overflow from the waste cooling pools currently in use. Dry storage
methods presently used by U.S. utilities do not protect against sabotage or
attack. The Raleigh-based company will continue storing large volumes of
waste fuel in the high-density pools at each plant inside buildings designed
to withstand only weather-related impacts.
Nuclear power
facilities are vulnerable to a variety of malicious acts, but are required
to protect against only the most minimal attack scenarios. The regulatory
criteria for security do not define the threat level of certain attacks;
they merely define the limits of industry responsibility in preparing for
and responding to attacks.
Twenty-seven state attorneys general recently joined top experts in
warning Congress that densely packed spent fuel pools at each U.S. plant are
of more concern as targets than are reactors. Federal studies confirm that
loss of pool water would lead to an uncontrollable fire, with radiation
released into the atmosphere causing thousands of fatalities and costing
hundreds of billions of dollars in offsite economic damage. Such pools are
among the largest risks to U.S. security, what Dr. Gordon Thompson referred
to as “pre-deployed radiological weapons waiting for activation by an
enemy.” These pools are also subject to accidental loss of water and
subsequent fire.
The
current provocative international climate has elevated the risks of
unconventional warfare by forces unable to compete with a powerful
conventional military on the battlefield. Rand Beers, a national
security advisor for four presidents, points out that while foreign policy
has escalated tension and hostility, real security enhancements inside the
U.S. have languished. He warns that oversight agencies like the U.S.
Nuclear Regulatory Commission (NRC) are suffering from “policy constipation”
and complacency, and that high-impact targets like chemical and nuclear
industries “cry out for protection.”
All Progress plants will store large amounts of spent fuel as long as they
operate, with a strong likelihood of permanent storage. None will ship
waste to a proposed but uncertain national dump in Nevada prior to 2015;
under current plans, Harris will not ship any waste before 2040.
NC
WARN has reviewed current dry storage practices, held discussions with
numerous leading independent experts and conducted an inspection of an
established facility that manufactures both thin and thick walled
containers. We have conveyed to Progress Energy the following simple,
affordable, and effective strategy to minimize the risks associated with
either accident or attack against spent nuclear fuel stored at each plant:
- For recently
discharged waste fuel that must remain in water, return to low-density,
open-rack storage as originally designed and licensed at all plants.
- Move all other spent
fuel into the highest quality, thick walled dry storage casks available.
- Store these
containers, dispersed to the maximum degree possible, at each generating
plant.
- Protect each cask
with a ventilated concrete vault, reinforced within an earthen berm.
- Halt overland
shipments of spent fuel rod assemblies immediately.
- Open a public
hearing process on all safety and security measures for communities within
a 10-mile radius of each plant.
This strategy reduces
the maximum single target at any plant to a few dozen assemblies (bundles)
of fuel rods, versus the thousands now stored in pools. It largely prevents
the most damaging type of nuclear release: a waste pool fire. Because these
measures create powerful deterrence to attack, they were adopted by several
European nations years ago. This plan would not add substantial time to the
approval process for the dry storage systems Progress is planning.
“Taking steps for safer storage today doesn’t mean the industry was wrong in
the past, but any new storage facilities must reflect the reality of the
post 9-11 world.”
-David Lochbaum, Union of Concerned Scientists.
Progress
Energy believes it could protect its plants from malicious acts; many
independent experts disagree. In light of a dispute involving such severe
consequences, and given the availability of a feasible means to minimize
risks, NC WARN asserts that conservatism must prevail. We urge citizens,
public officials, and civic leaders to call for immediate action by Progress
Energy, as well as state and federal government, to correct the present –
and possibly permanent – high-risk situation.
Overview
of Risks at Progress Plants
The vulnerability of nuclear
power facilities to accident or malicious acts, along with threats against
them, have been evident to informed observers for decades. However, in the
early 1980s and again in 2003, the NRC declared that it would be cost
prohibitive to require nuclear power licensees to incorporate design or
administrative features to protect against any but the most minimal attack
scenarios. Even after the September 11 tragedy, the NRC claims the risk is
“too speculative” and that the U.S. military, not plant owners, are
responsible for their ultimate protection.
Detailed information is widely available in the public domain showing that
various vital components of nuclear plants are vulnerable to assault from
the ground, water or air. This includes jets or small, explosives-laden
planes. NC WARN has published a report demonstrating the desirability of
plants as targets for “asymmetric” attack, and showing that many
organizations have mastered the basic skills required to conduct a
successful attack.
High-level nuclear waste is dangerous no matter how it is managed, and will
be for 10,000 years. After removal from a reactor, fuel rods are
highly radioactive, and high decay heat must be removed by circulating water
for five years. Because of a lack of disposal options, plants use large,
indoor cooling pools that were intended for short-term storage but are now
crowded with far more waste than they were originally designed to contain or
keep cool. For excess capacity, plant owners have added dry storage systems
– incorporating passive air cooling – for older waste assemblies. No U.S.
utilities are building new pools to increase storage capacity.
Progress Energy
plans to continue storing large volumes of waste in high-density pools at
each plant. There is one pool
at Robinson, containing an estimated 380 assemblies; two at Brunswick – one
in each building housing the I and II reactor units, each with approximately
1,200 waste assemblies. At Harris, there are four interconnected pools in
one building; two are filled, one is partially filled, totaling an estimated
4,400 assemblies. This is already among the largest concentrations of
high-level waste in the U.S.. Harris’s total capacity is more than 8,100
bundles. All Progress pools are in buildings designed only against
weather-related impacts; equipment rooms lie beneath each pool.
The pools
at Robinson and Brunswick I and II are filled to capacity, and the
corporation says it will soon begin to place the oldest waste fuel in dry
storage at those plants instead of shipping it to Harris. Each reactor is
refueled on an 18-month schedule, and as “hotter” waste is moved from the
core into the pools, older assemblies would be cycled out of the water and
into dry storage. No dry storage is apparently planned for Harris, so the
waste pool inventory will continue to increase each time the plant refuels.
Although a successful attack on a dry storage container could release a
large amount of radio-activity, the potential scope of damage from a pool
fire is worse by orders of magnitude, and according to federal studies,
could create irreversible physical, economic, and social damage across
thousands of square miles. This material constitutes a custodial
responsibility for society over a period far longer than most human
institutions survive. We must develop a system for managing this waste that
– even if world-changing events occur – will minimize the chance of
widespread radioactive contamination.
Return all cooling pools to original design: low-density,
open racks
A comprehensive risk reduction plan
must address the most dangerous concentration of radioactive material:
high-density fuel pools. In October 2002, 27 state attorneys general,
including North Carolina’s Roy Cooper, wrote to Congress:
The consequences of a catastrophic attack against a nuclear power plant are
simply incalculable. It is evident that urgent steps must be taken to
bolster the efforts of private nuclear power plant operators and the [NRC]
to minimize the potential threat and expand emergency response capability
should such an attack occur… An interagency Task Force—chaired by the
NRC and working in concert with the Director of Homeland Security, should be
created and tasked to … enhance protections for one of the most
vulnerable components of a nuclear power plant—its spent fuel pools.
Congress and the NRC have thus far ignored those recommendations.
U.S. nuclear plants will store large amounts of high-level waste fuel for
many years, regardless of whether they remain operational, and even if a
proposed national repository is opened. Based on estimates by the U.S.
General Accounting Office, a dump at Yucca Mountain, Nevada could not open
prior to 2015. The U.S. Department of Energy has not even filed an
application to license construction of the project, and industry officials
admit that many more years of regulatory and court challenges – and an
estimated $55 billion – are needed to open the dump. Also, security
concerns regarding thousands of waste fuel transports passing through U.S.
communities over a 25 year period have yet to be addressed.
Therefore, waste inventories at Robinson and Brunswick will continue to grow
until at least 2015. License renewals are being sought for all Progress
Energy’s plants, which would extend the generation of waste fuel for many
years. Because Shearon Harris was among the last U.S. plants to become
operational, a dump at Yucca Mountain would be legally filled before Harris
would be eligible to send its waste.
Only waste discharged from the
reactor within the last five years should remain in pools:
The cooling pools at all nuclear plants were originally designed and
licensed for open-framed racks. Assemblies were spaced over a foot apart in
order to allow water flow to remove decay heat. In the event of water loss,
air convection should be sufficient to prevent self-ignition of the fuel
cladding.
Over the years, with a
permanent disposal solution unavailable, U.S. utilities installed storage
racks that allowed more waste assemblies to be crowded into pools. Now
plants use a dense storage configuration, with assemblies approximately one
inch apart and separated by neutron-absorption shields to prevent fissioning
between assemblies. These shields effectively create a thermos around each
waste assembly. With even partial loss of circulating water, assemblies
will overheat in a matter of hours and the zirconium rods containing fuel
pellets will self-ignite.
In the words of Dr. Gordon Thompson,
this makes the pools “pre-deployed radiological weapons waiting for
activation by an enemy.” Any one of countless attack options that causes
loss of water or its
circulation would lead to an unquenchable fire releasing a quantity of
readily volatilized cesium-137 into the atmosphere. At most plants, the
release could far exceed the amount causing widespread contamination from
the Chernobyl accident in Ukraine in 1986. This critical vulnerability to
either accident or attack would be decisively eliminated by a return to
low-density, open rack pool storage, as originally used throughout the
industry.
Shearon Harris is presently storing approximately 4,400 assemblies in its
pools. The reactor holds 157 assemblies that undergo a 100% exchange every
4.5 years. All imported waste from other Progress plants is over five years
old, thus it is safe to assume that over 4,000 waste fuel assemblies are
eligible for dry cask storage, leaving no more than one core size, or 157
assemblies, requiring pool cooling. This constitutes a dramatic potential
reduction of density on an order of almost nine times, or more than enough
to remove the boron-impregnated separators and prevent pool fires if water
were lost. The Brunswick and Robinson plants could both be similarly
maintained at less than half their current densities, also enough to revert
to open rack systems as originally designed.
Hardened, dispersed dry storage
It was
only after their pools were filled that U.S. utilities began using dry
storage for older waste assemblies. Nuclear power facilities around the
world, the U.S. Department of Energy and the Navy use dry storage for spent
fuel rods. Most U.S. facilities, however, have not protected dry storage
against potential attackers. Lowest-risk storage for an indefinite period
at power plants involves a system of basic measures that minimize the
potential for large releases of radioactivity.
Because the NRC has been careless in regulating dry cask manufacturing and
usage, and given the likelihood that Progress is committing to long-term dry
storage, the company must select the highest quality containers available.
The NRC has approved dry cask designs and quality levels by a wide range of
manufacturers. There are dramatic differences in the quality of available
containers, and none are designed to withstand numerous weapons such as
anti-armor ordnance. NC WARN will not endorse any company or its
containers, but herein suggests assessment and selection criteria.
Cask quality is crucial
Some designs use horizontal
orientation, others vertical. The NRC licenses casks for 20 years;
re-licensing or repackaging will be necessary at most plants due to the lack
of disposal options. Some higher quality casks will maintain physical
integrity for much longer.
Many dry storage systems are comprised of thin-walled (one-half inch) metal
canisters surrounded by a concrete container, or overpack. Waste assemblies
rest on an inner framing, or basket. Passive air movement via vents in the
inner cask dissipates high heat levels. Although up to 27 inches thick,
the concrete is designed to shield workers from most of the radiation
emitted, not protect against assault, or against storm-driven missiles such
as telephone poles. Other problems include the fact that the lid must be
welded onto the inner container, and that a means to safely unload the
assemblies has not yet been determined.
The NRC has also approved the use casks with thick (ten-inch) steel walls.
These are not placed in overpacks, and cooling occurs by radiant transfer
through the cask wall. Often, a thin outer polymer shield is used to reduce
radiation exposure to workers. Many utilities favor the heavy-walled units
because they have bolted lids, instead of welds, and are readily
transportable (in anticipation of a future repository) without removing an
inner container from an overpack. A number of U.S. companies manufacture
these casks, which were the industry standard until recent years when the
DOE, after losing a lawsuit against utilities for failing to license a
national dump, began favoring thin-walled containers as part of an interim
cost-cutting scheme by the industry.
Neither thin, nor thick-walled containers, on their own, are designed to
withstand attacks from anti-tank munitions or special explosives. However,
thick-walled casks are preferable if incorporated into a comprehensive dry
storage system that is resistant to acts of malice.
There have been problems within the U.S. dry cask industry, and one
manufacturer and its utility client are under investigation for quality
control falsification. Governmental oversight must be improved, as should
current standards regarding cask engineering to prevent criticality, and
impact load and heat transfer to spent fuel in the event of accident or
fire. Each cask should undergo extensive physical testing, including
explosive attacks, not just the present computer modeling.
Key additional factors for Progress Energy plants include:
Store casks on
site, dispersed to the maximum degree possible
At most nuclear power facilities, dry storage
casks are simply lined up in the open atop concrete pads, and therefore are
vulnerable to attack by air, or series engagements from direct fire weapons
capable of damaging multiple casks in seconds. Dispersing the casks turns
a single high yield target at one geographic point into separate low-yield
targets at multiple points. Each Progress plant has hundreds of acres,
sufficient site space to accommodate this plan. The casks should not be
buried, but positioned above ground to allow for monitoring over the short
and long term.
Harden each canister with a ventilated concrete vault,
reinforced within an earthen berm.
A simple method
for reducing the remaining vulnerability of casks is to “harden” the casks
by surrounding them with an additional robust structure (preferably an
accessible concrete vault surrounded by an earthen berm). Advantages
include:
- Dissipates the energy
of high explosive anti-tank ammunition or TOW missiles, which require
“stand-off” from the target surface to optimize results and protect the
shooter
- Prevents line-of-sight
targeting of the cask by direct fire weapons from plant boundary
- Deflects and absorbs
kinetic energy of an aircraft attempting to crash into the structure
- Can be configured to
prevent insertion by an intruder of an explosive device into the outer
container.
Dr. Gordon
Thompson’s recent report from the Institute for Resource and Security
Studies, Robust Storage of Spent Nuclear Fuel: A Neglected Issue of
Homeland Security (December, 2002), describes a sound process for
hardened, on-site storage that could be implemented promptly:
SCHEMATIC OF HARDENED ON-SITE STORAGE
 
These measures would not nullify the need for
strict security, but would increase the difficulty of attack as well as
lower potential regional contamination, thereby removing a plant from many
target lists.
Halt shipments of waste fuel immediately
NC WARN supports Progress Energy’s intent to
stop transports of waste fuel, but reiterates that these monthly shipments
should cease immediately. Additional trainloads of this hazardous material
– with international hostility to the U.S. at unprecedented levels – is
unacceptable. No other utility in the nation is currently shipping any
waste fuel off-site.
Ten or more times each year, Progress Energy transports the waste by slow
rail over 200 miles of largely unprotectable terrain, from either the
Robinson or Brunswick plant, for storage at Harris, with the easily
recognizable waste fuel transport cask in clear view aboard a modified flat
rail car.
The spent fuel assemblies are contained in an IF-300 shipping cask, cooled
by a water-ethylene glycol mixture. This cask has been minimally tested for
drops and impacts, and fitted with stainless steel impact fins to provide
protection from rupture due to accident. It has not been tested for
vulnerability to attack, and construction diagrams indicate that it is
easily penetrable by standard shoulder-fired anti-armor munitions, or by
manually emplaced, man-portable explosive breaching charges. It also has
weak points on critical external structures that interface with the
containment Cavity to include the upper cavity, and lower cavity valve
boxes, the neutron valve boxes, and the neutron shield expansion tanks. The
cargo generally contains approximately one million curies of dangerous
radioactive isotopes, including cesium-137, a gamma-emitter.
The cask itself is partially composed of depleted uranium (DU) to increase
superstructural density. DU is an alpha radiation emitter (extremely
carcinogenic) when volatilized. DU is also a heavy metal, and as such is
highly toxic.
There is no reasonable means to secure these transports against even a small
group of skilled and determined attackers. Destruction of the cask would
make both security and clean-up a potentially lethal activity for local
emergency responders who may not understand the nature of this material, and
who lack the resources and training for radiological emergencies.
Volatilization of even a portion of the waste fuel and/or the DU, depending
on unpredictable climactic conditions at the time of attack, could be
severe. Federal and independent studies confirm that dangerous exposures to
the public could occur over dozens of square miles, which could require
evacuation, along with long-term contamination leading to billions of
dollars in economic damages. Moreover, it cannot be ruled out that the
intent to attack a transport cask might also be incorporated into a plan
that makes emergency responders themselves secondary targets.
Conclusion
Former
Department of Energy Senior Advisor Robert Alvarez said at a public hearing
on nuclear safety in Apex, NC: "In
the United States, both the nuclear industry and its regulatory agency are
in total denial. Several events could cause a loss of pool water ...
Industry officials maintain that personnel would have sufficient time to
provide an alternative cooling system before the spent fuel caught fire.
But if the water level dropped to just a few feet above the spent fuel, the
radiation doses in the pool building would be lethal. The NRC and the
industry are not facing this with appropriate gravity, but using public
relations in lieu of addressing problems."
Based on a study
by Alvarez and others published in Princeton University’s journal Science
and Global Security this spring, converting each Progress plant’s
waste storage back to low-density pools, in conjunction with hardened,
dispersed dry storage for older waste, would cost between four to seven
million dollars per year. Compared to the corporation’s annual revenue of
$8 billion, and a public relations budget in the tens of millions, this is a
realistic investment to accomplish a critical domestic security measure.
The entity that can resolve this issue immediately for central and coastal
North Carolina is Progress Energy itself. The corporation believes it could
protect its plants against determined attack; the available data support the
case of many independent experts who disagree. Due to the extreme
consequences that could result if Progress is wrong, and the availability of
a feasible, affordable alternative to current high-risk practices, the
uncertainty should be resolved in favor of conservatism.
Progress has the opportunity to make history by establishing a new industry
standard – and becoming a model of corporate responsibility in the process.
At a minimum, high-level nuclear waste will be stored in North Carolina for
decades, possibly for centuries. We cannot afford to retain it in
high-density pools. All available measures must be employed at this time to
minimize the historically unique risk of large releases of radioactivity
from waste fuel storage. If Progress fails to act, or takes half-measures
that leave the public at unnecessary risk for the indefinite future, it is
incumbent on the People of the State of North Carolina, through our attorney
general and his authority under the state constitution, to mandate the
safest possible management of high-level waste. |
