Nuclear Waste: 

Is There A Need For 

Federal Interim Storage? 

Report of the Monitored Retrievable Storage Review Commission 

November 1, 1989 

For sale by the Superintendent of Documents, U.S. Government Printing Office 

Washington, D.C. 20402 

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MONITORED RETRIEVABLE STORAGE REVIEW COMMISSION 

1825 K Street, NW Alex Radin 

Suite 318 Chairman 

Washington, DC 20006 

Dale E. Klein 

202-653-5361 Commissioner 

Frank L. Parker 

Commissioner 

Jane A. Axelrad 

Executive Director and 

General Counsel 

November 1, 1989 

The Honorable Thomas S. Foley 

Speaker of the House 

United States House of Representatives 

H-204 Capitol 

Washington, D.C. 20515-6501 

The Honorable Robert C. Byrd 

President Pro Tempore 

United States Senate 

Hart Office Building, Suite 311 

Washington, D.C. 20510-1902 

Dear Speaker Foley and Senator Byrd: 

The Monitored Retrievable Storage Review Commission herewith submits its 

final report as required by the Nuclear Waste Policy Amendments Act of 1987, 

Public Law 100-203, as amended by Public Law 100-507. 

The Congress created the Commission to provide a report on the need for a 

Federal monitored retrievable storage facility (MRS) as part of the Nation's 

nuclear waste management system. In essence, Congress asked the Commission to 

review the U.S. Secretary of Energy's proposal to create an MRS, evaluate the 

technical need for an MRS, obtain data and comments from affected parties, and 

recommend whether such a facility should be included in the nuclear waste 

management system. 

The Commission concludes that the MRS as presently described in the law, 

which links the capacity and schedule of operation of the MRS to a permanent 

geologic repository, cannot be justified. The Commission finds, however, that 

while no single factor would favor an MRS over the No-MRS option, cumulatively 

the advantages of an MRS would justify the building of an MRS if: (1) there 

were no linkages between the MRS and the repository; (2) the MRS could be 

constructed at an early date; and (3) the opening of the repository were 

delayed considerably beyond its presently scheduled date of operation. 

The Commission notes that the Congress, for many years, has expressed 

concern that an unlinked MRS might be regarded as a de facto repository and 

could reduce the impetus for proceeding with permanent geologic disposal. The 

Commission recognizes this expression of Congressional will, as well as 

similar sentiments voiced during the course of its hearings. Although the 

Commission does not believe that there is a technical basis for the linkages, 

the Commission concludes that some linkages are justified. 
Based on our studies, and the conclusions noted above, the Commission has 

decided that some limited interim storage facilities would be in the national 

interest to provide for emergencies and other contingencies. The Commission 

feels that such facilities would be especially desirable in light of delays 

which have already been experienced as well as additional delays that might be 

encountered in building a permanent geologic repository. The Commission 

therefore recommends that the Congress take the following actions: 

1. Authorize construction of a Federal Emergency Storage (FES) facility 

with a capacity limit of 2,000 metric tons of uranium. 

2. Authorize construction of a User-Funded Interim Storage (UFIS) 

facility with a capacity limit of 5,000 metric tons of uranium. Such a 

facility would provide only storage, and would be in addition to the FES. 

3. Reconsider the subject of interim storage by the year 2000 to: (a) 

take into account uncertainties that exist today and that might be resolved or 

clarified within ten years; (b) consider developments that cannot be 

anticipated today; and (c) evaluate the experience with the two facilities 

recommended above. 

The Commission believes that these recommendations, together with the 

analyses contained in the report, carry out the mandate given the Commission 

by the Congress. 

We thank you for the opportunity to serve the Congress. It is our hope 

that the report will assist the Congress as it continues to deliberate on the 

management and disposal of the Nation's spent nuclear fuel. We stand ready to 

assist Congress in any way possible to accomplish this goal. 

Sincerely, 

Alex Radin 

Chairman 

Dale E. Klein 

Commissioner 

Ztgu&t.L. 

Frank L. Parker 

Commissioner 

0 0 2 0 
Table of Contents 

Commissioners and Commission Staff xi 

Commission Activities xiii 

Executive Summary xv 

Chapter One: Introduction 1 

Section One: The Commission's Mandate 1 

Section Two: The Legal and Historical Context 4 

Section Three: The Problem 5 

Section Four: The Commission's Process 5 

Chapter Two: Key Issues 9 

Section One: Public Policy Context 10 

Section Two: Summary of the Key Issues 10 

Section Three: Key Questions 14 

Chapter Three: Analytical Methodology 17 

Section One: No-MRS and MRS Alternatives 17 

Section Two: The Models 19 

Section Three: Assumptions of MRS and No-MRS Strategies 21 

Section Four: Sensitivity Analyses 26 

Chapter Four: Health, Safety, and Environmental Effects 29 

Section One: General Effects on Health and Safety 29 

Section Two: Special Issues 35 

Section Three: Environmental and Socioeconomic Effects 43 

Section Four: Findings 45 

Chapter Five: Health and Safety Effects of Transporting Spent Fuel 49 

Section One: Radiological Effects 49 

Section Two: Non-radiological Risks—Traffic Accidents 52 

Section Three: Sensitivity Analyses of Radiological and Non-radiological Factors 54 

Section Four: Findings 57 

r, a 
Chapter Six: Spent Fuel Management Costs 59 

Section One: Background 59 

Section Two: Cost Estimate Data Sources and Differences 62 

Section Three: Cost Analysis 67 

Section Four: The Effects of Discounting 71 

Section Five: Findings 74 

Chapter Seven: Distributional Considerations and Equity 77 

Section One: Compensating State and Local Governments 77 

Section Two: Stigma Effects 78 

Section Three: Equity Considerations of MRS Alternatives 79 

Section Four: Economic Efficiency and Equity in MRS Financing 80 

Section Five: Findings 82 

Chapter Eight: Policy Issues 85 

Section One: Public Policy Views on the Need for an MRS Facility 86 

Section Two: MRS Review Commission's Summary of Advantages and Disadvantages of an MRS 96 

Chapter Nine: Conclusions and Recommendations 99 

Section One: Conclusions 99 

Section Two: Recommendations 101 

Appendix A A-1 

Public Hearings—People Appearing Before the Commission A-1 

Appendix B B-1 

Statements for the Record B-1 

Appendix C C-1 

Public Briefings—People Appearing Before the Commission C-1 

Appendix D D-1 

Spent Fuel Management Policies in Eight Countries D-1 

Appendix E E-1 

Contractor Assistance E-1 

Appendix F F-1 

Chronology of the Monitored Retrievable Storage Concept F-1 

vi 

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Appendix G G-1 

Description of the Models G-1 

Appendix H H-1 

Sensitivity Analyses H-1 

Appendix I I-I 

The Commission's Recommendations: Cost, Capacity, and Financing I-1 

Appendix J J-1 

Managing Spent Fuel Transportation Risks J-1 

Appendix K K-1 

Glossary, Acronyms, and Abbreviations K-1 

Bibliography BIB-1 

vii 
Tables and Figures 

Chapter One: Introduction 

Figure 1.1—U.S. Commercial Nuclear Power Reactor Sites 2 

Figure 1.2—The Commission's Charge 3 

Figure 1.3—Nuclear Waste Policy Amendments Act Linkages 5 

Chapter Two: Key Issues 

Figure 2.1—The Nuclear Fuel Cycle 9 

Table 2.1—Major Arguments Presented to the Commission For and Against an MRS Facility 11 

Chapter Three: Analytical Methodology 

Figure 3.1—Interim Storage Concepts 18 

Figure 3.2—Illustration of a Network Model 20 

Figure 3.3—No-MRS and MRS Modeling Assumptions 22 

Figure 3.4—An Example of a Dry Storage Cask 24 

Figure 3.5—Generic Horizontal Modular Storage System (NUHOMS) 25 

Chapter Four: Health Safety, and Environmental Effects 

Table 4.1—Total Spent Fuel Management Life-cycle Public Doses 30 

Table 4.2—Total Spent Fuel Management Life-cycle Occupational Public Doses 30 

Table 4.3—Comparison of Total Life-cycle Radiological Effects of MRS and No-MRS Systems 31 

Figure 4.1—A Comparison of Calculated Cancer Fatalities from Natural Background Radiation, Medical X-rays, and 

Spent Fuel Management Activities 32 

Table 4.4—Total Life-cycle Doses in Person-rem for No-MRS and Linked MRS Systems 33 

Table 4.5—Sensitivity Analyses of Total Life-cycle Doses 34 

Table 4.6—Total Life-cycle Non-radiological Occupational Risk for MRS and No-MRS Systems 35 

Figure 4.2—An Example of a Spent Fuel Pool 36 

Figure 4.3—Shutdown Commercial Light Water Power Reactors (LWR) 38 

Figure 4.4—Spent Fuel Accumulation at Shutdown Commercial Light Water Power Reactors (LWR) 39 

Table 4.7—Spent Fuel Accumulation at Shutdown Commercial Light Water Power Reactors (LWR) 39 

Figure 4.5–Fuel Assembly and Fuel Rod 40 

Table 4.8—Comparison of Total Spent Fuel Management Life-cycle Doses for Systems with and 

without Consolidation 41 

Figure 4.6—A Dual-purpose Cask 43 

viii 

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Chapter Five: Health and Safety Effects of Transporting Spent Fuel 

Table 5.1—Total Life-cycle Transportation Radiological Risk 50 

Table 5.2—Surrogate Life-cycle Transportation Risk Measures 51 

Table 5.3—Life-cycle Non-radiological Risk 53 

Table 5.4—Effects of Linkages on Life-cycle Transportation Risk 54 

Table 5.5—Effects of Transshipment on Life-cycle Transportation Risk 55 

Table 5.6—Effects of MRS Location on Life-cycle Transportation Risk 56 

Table 5.7—Effects of At-reactor Rod Consolidation on Life-cycle Transportation Risk 57 

Chapter Six: Spent Fuel Management Costs 

Figure 6.1—Location of Spent Fuel, MRS in 2000, Repository in 2003 60 

Table 6.1—Location of Spent Fuel, MRS in 2000, Repository in 2003 60 

Figure 6.2—Location of Spent Fuel, No-MRS, Repository in 2013 61 

Table 6.2—Location of Spent Fuel, No-MRS, Repository in 2013 61 

Table 6.3—Comparison of Historical Total-system Life-cycle Cost Estimates 63 

Table 6.4—Comparison of WACUM and DOE Total-system Life-cycle Cost Estimates 65 

Table 6.5—Comparison of 10% and 90% Probability Levels for Total-system Life-cycle Cost Selected Cases 68 

Table 6.6—Comparison of Total-system Life-cycle Costs for Selected Repository Start Dates 69 

Table 6.7—Comparison of Total-system Life-cycle Costs for Selected Repository Start Dates: Present Value and 

Nominal Value 72 

Table 6.8—Comparison of Total-system Life-cycle Costs: Nominal Value and Present Value for Selected Cases 73 

Figure 6.3—Cost Per Year of Delayed Removal of Spent Fuel from Shutdown Reactors 74 

Chapter Eight: Policy Issues 

Table 8.1—Reduction in Dry At-reactor Storage Needs with an MRS 88 

Figure 8.1—Spent Fuel in Dry Storage and at Shutdown Sites, without MRS or Repository 91 

'Appendix D 

Table D.1—Spent Fuel and HLW Storage in Eight Countries D-18 

Table D.2—Spent Fuel Storage in the United States D-19 

Appendix G 

Figure G.1—Schematic Representation of the Spatial Network in MARC G-2 

Figure G.2—Schematic Representation of the Space-time Network in MARC G-3 

Figure 0.3—Reactor Sub-network G-4 

Figure G.4—MRS Sub-network G-5 

Figure G.5—Repository Sub-network G-6 

ix 
Figure G.6—Sample Output Summary Cost Table for WACUM Simulation of Linked MRS In 2010 and 

Repository in 2013 Case G-13 

Appendix H 

Table H.1—Variations on the No-MRS Strategy H-1 

Table H.2—Variations on the MRS Strategies H-2 

Appendix J 

Figure J.1-100 Ton Combined Transport Cask J-2 

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MONITORED RETRIEVABLE STORAGE 

REVIEW COMMISSION 

COMMISSIONERS 

Alex Radin, Chairman 

Dale E. Klein, Ph.D. 

Frank L. Parker, Ph.D. 

COMMISSION STAFF 

EXECUTIVE DIRECTOR AND GENERAL COUNSEL 

Jane A. Axelrad 

TECHNICAL STAFF 

Sherwood C. Chu, Ph.D. 

Remi B. Langum 

James C. Malaro 

Allan G. Pulsipher, Ph.D. 

EXTERNAL AFFAIRS 

Paula N. Alford 

RESEARCH AND EDITORIAL SERVICES 

Sauci S. Churchill 

J. D. Brown, D.P.A. 

Anne M. Donovan 

ADMINISTRATIVE STAFF 

Nancy L. Creason, Administrative Officer 

Barbara M. Cames 

Margaret K. Geiger 

Dezebee Tyrone Miles 

Or? 
Commission Activities 

After being sworn into office on June 14, 1988, the 

Monitored Retrievable Storage (MRS) Review Commission members assembled and organized a small staff. The 

Commission operated as a collegial body, with commissioners intimately involved in directing the research and establishing the report writing methodology. From June 14, 

1988, until November 1, 1989, the Commission met formally almost every other week. In addition, commissioners 

traveled individually to gather pertinent information. 

All Commission meetings with outside persons or organizations were open to the public. Transcripts of public 

meetings and routine correspondence were available for review in a Public Document Room at the Commission's offices in Washington, D.C. 

The Commission solicited the views of a broad spectrum of people and organizations by holding public hearings in Washington, D.C.; Denver, Colorado; San 

Francisco, California; and Atlanta, Georgia. (See Appendix 

A.) The hearings were well attended and produced a wealth 

of information and insights used during the Commission's 

deliberations. A total of 173 private citizens, nuclear waste 

experts, nuclear utility officials, State and local government 

representatives, Members of Congress, and representatives 

of citizen and environmental action groups testified, expressing a wide variety of views and, in many instances, 

submitting statements for the record. Commissioners listened to and questioned each witness concerning the 

rationale and long-term consequences of his or her recommendations. The Commission also received statements for 

the record from people unable to attend the hearings. (See 

Appendix B.) 

Throughout its study, the Commission conducted public briefings to gather relevant information. (See Appendix 

C.) In July 1988, the U.S. Department of Energy (DOE), 

the Nuclear Regulatory Commission (NRC), Members of 

Congress and their staffs, the General Accounting Office 

(GAO), the nuclear industry, the State of Tennessee, and 

environmental action groups briefed the Commission on 

monitored retrievable storage work done before the Commission was created. 

In September 1988, the Commission requested a series of briefings on specific topics by DOE and NRC representatives. DOE presented information on its ongoing 

studies on the need for an MRS facility, rod consolidation, 

its dry cask storage study, and the status of the repository 

program. NRC briefed the Commission on its procedures 

for licensing independent spent fuel storage installations 

and certifying casks for transportation of spent nuclear fuel. 

Soon after its formation, the Commission determined 

it needed to examine first-hand how utilities and others 

handle and store spent fuel. In October 1988, the Commissioners and the Commission's Executive Director visited 

Carolina Power and Light Company's H.B. Robinson Nuclear Project in Hartsville, South Carolina, and Virginia 

Power Company's Surry Nuclear Power Station in Surry, 

Virginia. Although these are the only U.S. commercial nuclear power plants currently using at-reactor dry storage facilities for spent fuel, other utilities are exploring the 

possibility. The facilities' handling and storage of spent 

fuel were examined, and the utilities' reasons for adopting 

this type of storage and their plans for the future were 

discussed. 

In addition to those site visits, the Commissioners and 

Executive Director visited facilities in Sweden, the Federal 

Republic of Germany, France, and Switzerland to learn 

about the European experience with spent fuel storage and 

to examine possible components of an interim storage system. They observed many approaches to spent fuel management ranging from wet centralized storage of spent fuel 

at CLAB in Sweden to the dry centralized storage of vitrified high-level wastes from reprocessing at La Hague in 

France. (See Appendix D.) 

Following this trip, the Commission held a public 

briefing in Washington, D.C., in November 1988, to obtain 

additional information from officials of COGEMA, a 

French nuclear fuel cycle company. Another briefing followed in December 1988 to obtain information from DOE 

on its program to construct a permanent repository for the 

disposal of nuclear waste. Department officials briefed the 

Commission on efforts to characterize the Yucca Mountain 

site in Nevada and the schedule for providing a permanent 

repository for high-level radioactive waste. 

In March 1989, DOE provided the Commission with 

the preliminary results of its system studies on the need for 

an MRS facility. In May 1989, DOE supplied the final results of those studies and stated the department's current 
position on the need for an MRS facility. At the same meeting, NRC officials briefed the Commission on safeguards 

issues associated with a potential MRS facility. 

The Commission's evaluation focused on a series of 

alternative waste management strategies. Acting on an 

early decision to contract for assistance to augment its staff 

efforts in performing needed complex analyses, initial contracts totaling $827,836 were awarded in February 1989 to 

perform five technical tasks and to provide data and analytical tools for the Commission to use in performing its evaluation. The same month, the Commission sent Congress 

and other interested parties a status report detailing Commission activities to date. 

In March 1989, the Commission invited a group of experts to review a draft outline of the report. They represented a wide range of views pertaining to the nuclear 

waste issues the Commission was examining and provided 

their expert perspectives on the scope of the report. 

Throughout the summer, the Commission received results of the contractors' work. Contractors' work, which included development of two computer models, augmented 

technical and public policy work already underway. (See 

Appendix E.) The Commission also received, in July 1989, 

the State of Tennessee's final study on the need for an MRS 

facility. In August, Edison Electric Institute submitted a 

study on the role of an MRS prepared by Energy Resources 

International at the request of the Edison Electric Institute/ 

Utility Nuclear Waste and Transportation Program. The 

Commission held a retreat in August to determine its conclusions and recommendations. 

This report, completed during the remaining months 

of the Commission's existence, reflects the Commission's 

extensive technical work and public policy deliberations. 

xiv 

20 e:$ 
Executive Summary 

About 20,000 metric tons of spent, or used, nuclear 

fuel have accumulated since the beginning of commercial 

nuclear power prbduction in the United States. At the end 

of the currently licensed period of all existing nuclear power plants and those under construction, the amount of spent 

nuclear fuel is expected to total 87,000 metric tons. 

Thus far, practically all of the spent nuclear fuel is 

stored in water-filled pools at reactor sites. However, space 

does not exist in the pools to store all the spent fuel expected to accumulate over the lifetime of the reactors. 

Therefore, other storage must be made available. 

U.S. policy is to dispose of spent fuel from nuclear 

power plants in a permanent underground geologic repository. The objective of permanent disposal is to limit to safe 

quantities the amount of nuclear waste that might reach the 

biosphere during the next 10,000 years and beyond. 

To achieve that objective, Congress, in the Nuclear 

Waste Policy Amendments Act of 1987 (NWPAA), designated Yucca Mountain, Nevada, as the candidate site for a 

repository. Final selection of the Yucca Mountain site was 

made subject to extensive studies of the suitability of this 

site and other conditions. 

The objective of Congress in adopting the NWPAA 

was to have a repository available for accepting spent fuel 

in 1998. However, the U.S. Department of Energy (DOE), 

which has responsibility for characterizing the Yucca 

Mountain site, has announced that the opening of the repository will be delayed until 2003, and it is likely that 

there will be additional delays. 

To store spent fuel until the permanent repository is 

available, a monitored retrievable storage (MRS) facility 

has been proposed by DOE. The MRS would serve as a 

means of collecting spent fuel, in excess of that in reactor 

pools, in a central location, where it would be stored until 

the fuel can be accepted at the repository. It has also been 

proposed that the MRS could serve other purposes, such as 

consolidating the fuel and packaging it for ultimate disposal in the repository. 

Facilities similar to an MRS have been proposed since 

1972 and have always been the subject of considerable 

controversy. As recently as 1987, DOE proposed to build 

an MRS at the Clinch River site near Oak Ridge, Tennessee. In adopting the NWPAA later that year, however, Congress "annulled and revoked" the DOE proposal to locate 

an MRS in Tennessee. 

In the same law, Congress authorized the construction 

of an MRS but created the Monitored Retrievable Storage 

Review Commission to study and report to Congress on 

whether an MRS should be a part of the Nation's nuclear 

waste disposal system. Essentially, Congress directed the 

MRS Review Commission to compare the options of a 

waste disposal system that included an MRS with one that 

did not include an MRS. The latter, which is known as the 

No-MRS alternative, would require continued storage of 

spent nuclear fuel at the more than 70 existing sites of nuclear power plants until the repository is operational. 

In the NWPAA, DOE was directed to begin site surveys for an MRS only after the MRS Review Commission 

had submitted its report to Congress. The NWPAA also 

limited the capacity of the MRS and linked its construction 

and operation to the repository schedule. 

This report represents the results of almost 18 months 

of study and deliberations by the MRS Review Commission in response to its mandate from Congress. In addition 

to its own studies and evaluations, the Commission contracted a number of studies by independent consultants; 

held extensive public hearings in four locations in the 

United States; reviewed detailed studies by DOE, the State 

of Tennessee, and others; received numerous written statements; and visited nuclear waste storage sites in the United 

States and in four European countries. 

As a result of its extensive studies and deliberations, 

the Commission reached the following conclusions: 

Conclusion No. 1. From a technical perspective, both 

the No-MRS and MRS options are safe. 

Although neither option is completely without risk, 

the Commission determined that the risks are expected to 

be small and within regulatory limits, and the degree of difference in risks is so small that the magnitude of difference 

should not affect the decision as to whether there should be 

an MRS. 

Conclusion No. 2. The net cost of a waste management system that includes an MRS would be lower than 

previously estimated because of delays that have already 

occurred in the expected date of repository operation, and 

the likelihood of further slippages of that date. 

xv 

Ay 
The economics of an MRS would become more favorable if the repository were delayed and if the MRS were to 

accept spent fuel as early as possible. These effects would 

become especially significant if the repository operation 

were to be delayed beyond 2013, when there will be a 

sharp increase in the number of nuclear power plants 

whose current licenses will expire. If a repository were not 

in operation by that time, utilities would incur major additional costs that would result from the inability to remove 

spent fuel from plants being decommissioned. However, a 

system with an MRS would still be somewhat more costly 

on a discounted basis than one without an MRS. 

Conclusion No. 3. There are no single discriminating 

factors that would cause the MRS alternative to be chosen 

in preference to the No-MRS alternative. 

Although the Commission does not find any single 

factor that would cause it to favor one alternative, it believes that, cumulatively, there are a number of advantages 

that would justify a central storage facility not limited in 

capacity nor linked to the repository schedule and operation. These advantages include storage for emergency purposes; storage for utilities which do not have sufficient 

space in their spent fuel pools or on-site or which cannot 

obtain a license for additional at-reactor storage and, hence, 

might be required to shut down an otherwise satisfactorily 

operating nuclear power plant; storage for spent fuel from 

shutdown reactors; economies in the waste management 

system if an MRS could be completed substantially before 

the repository; greater redundancy in the system in the 

event of unforeseen circumstances; more surge capacity to 

facilitate the flow of spent fuel to the repository; more flexibility in storage options and future waste preparation functions; assistance in standardization; and initiating Federal 

responsibility for taking possession of spent fuel. 

Conclusion No. 4. An MRS linked as provided in current law would not be justified, especially in light of uncertainties in the completion time for the repository. 

Consequently, the Commission does not recommend a 

linked MRS as required by current law and as proposed by 

DOE. 

The Commission notes that Members of Congress, 

other public officials, environmental groups, and many private citizens for many years have expressed concern that an 

unlinked MRS might be regarded as a de facto repository, 

and thereby would reduce the impetus for building the repository as expeditiously as possible. Although the Commission does not believe that there is a technical basis for 

the linkages, the Commission agrees that, in light of congressional and other concerns about a de facto repository, 

some linkages are justified. 

However, the schedule linkage presently in the 

NWPAA (MRS construction may not begin until the Nuclear Regulatory Commission issues a license for the construction of a repository) would make it impossible for an 

MRS to be operational more than three years before the repository. Because of delays already experienced in the repository schedule and continued uncertainty surrounding 

the repository's location and date of operation, the value of 

the MRS would be greatly diminished if its construction 

were tied to the schedule of the repository. Most of the 

need for an MRS would have disappeared, in that utilities 

would have had to make other arrangements for storage. 

Conclusion No. 5. Some interim storage facilities, 

substantially more limited in capacity and built under different conditions than the DOE-proposed MRS, are in the 

national interest to provide for emergencies and other contingencies. 

The Commission recognizes the need to provide certain services that would be in the national interest, but 

which could not be provided by an MRS restricted by the 

schedule linkages currently in the law. The Commission 

concludes that spent fuel storage for emergency and other 

purposes would be in the national interest. Facilities to fulfill this national interest could be more limited in scope and 

could be built under different conditions than the DOE-proposed MRS. 

In view of the conclusions noted above, and in light of 

its extensive studies and deliberations, the Commission 

recommends the following: 

Recommendation No. 1. Congress should authorize 

construction of a Federal Emergency Storage (FES) 

facility with a capacity limit of 2,000 metric tons of 

uranium (MTU). 

In light of the continuing delay in the building of a repository, the Commission believes it would be in the national interest to have available a safety net of storage 

capacity for emergency purposes, such as an accident at a 

nuclear power plant, which would make it advantageous to 

have the plant's spent fuel pool available for decontamination of affected parts of reactors and for storage of debris. 

If the facility proposed in Recommendation No. 2 

were not available, the FES also could be used to store 

spent fuel from otherwise satisfactorily operating nuclear 

power plants that would have to be shut down because of 

insufficient on-site storage. 

Because the FES would be designed primarily for 

emergency use and, hence, would serve as "insurance" for 

the entire industry, the Commission recommends that the 

cost of this facility should be paid from the Nuclear Waste 

Fund, to which all of the utilities which generate power 

from nuclear energy contribute. 

Recommendation No. 2. Congress should authorize 

construction of a User-Funded Interim Storage (UFIS) facility with a capacity limit of 5,000 MTU. Such a facility 

xvi 

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would provide storage only, and would be used in addition 

to the Federal Emergency Storage facility proposed in Recommendation No. 1. 

Although spent fuel can be stored safely at reactor 

sites for as long as 100 years, some utilities may not have 

space on-site for life-of-plant storage or may not be able to 

obtain a license for additional storage. 

In view of the uncertainties regarding the availability 

of a repository, the Commission believes it would not be in 

the national interest to force utilities to shut down operation 

of otherwise satisfactorily operating nuclear power plants 

because of lack of storage capacity for spent fuel. Congress 

recognized this problem by authorizing, in Section 135 of 

the Nuclear Waste Policy Act of 1982, a Federal Interim 

Storage facility (FIS). It is the Commission's intention that 

the 5,000 metric ton storage facility that it recommends 

likewise should be available in such contingencies. 

This facility also should provide storage for: (a) shutdown reactors at sites where a utility no longer operates nuclear power facilities, and (b) utilities which would prefer 

to ship spent fuel to this facility rather than retain it onsite. 

In view of the uncertainties which have existed as to 

the time of operation of the MRS and the repository, many 

utilities with newer reactors have already taken steps to 

provide needed life-of-plant storage, while others have expressed a preference for providing such storage themselves 

rather than relying on an MRS. For these reasons, the Commission believes it would be more equitable for the storage 

facility (UFIS) to be user funded, so that only those utilities that chose to use the facility would pay for it. 

Recommendation No. 3. Congress should reconsider 

the subject of interim storage by the year 2000 to: 

(a)take into account uncertainties that exist today and 

which might be resolved or clarified within 10 years, 

(b) consider developments which cannot be anticipated 

today, and (c) evaluate the experience with the two 

facilities recommended above. 

Many uncertainties make it extremely difficult to plan 

for long-term interim storage of spent fuel. Although the 

opening of the repository is the most notable uncertainty, 

many other questions also must be resolved. 

The Commission believes that the actions recommended above should be adequate to take care of the needs 

of interim storage at least until the year 2006. However, by 

the year 2000, Congress should reconsider the question of 

interim storage of spent fuel. At that time, Congress should 

take into account, among other things, such factors as: status of the repository; status of nuclear power plants; availability of at-reactor storage; utilization and adequacy of the 

2,000 metric ton Federal Emergency Storage facility and 

the 5,000 metric ton User-Funded Interim Storage facility; 

status of technological developments in the storage of spent 

fuel; nuclear waste system optimization; and the fee schedule established for the UFIS. 

• • • 

The Monitored Retrievable Storage Review Commission believes that these recommendations would provide 

safe interim storage of spent nuclear fuel, would be consistent with the goals of the national nuclear waste management system, and would provide for flexibility and 

unforeseen contingencies. 

xvii 
Chapter One 

Introduction 

Nuclear power plants generated about 19.5 percent of 

all electricity produced in the United States in 1988. 1These 

plants generate electricity through the fission (splitting of 

atoms) of uranium-235 fuel, which is contained inside a 

zirconium alloy rod. As the fuel fissions and generates heat 

to produce power, fissile uranium-235 is depleted, and the 

efficiency of the chain reaction decreases. After three or 

four years of use, the spent (that is, partially depleted) fuel 

rods have to be removed from the reactor and replaced with 

new ones. The spent fuel rods are highly radioactive and 

must be isolated from people and the environment. The 

United States regulates and treats spent fuel as high-level 

radioactive waste (HLW). 2 

About 20,000 metric tons of commercial spent nuclear 

fuel is now stored at more than 70 nuclear power plant sites 

around the country. (See Figure 1.1.) Most of the spent fuel 

is now stored in pools. It is expected that existing nuclear 

power plants will produce approximately 87,000 metric 

tons of spent fuel during their lifetimes. 3 

The spent fuel is small in volume compared to other 

hazardous materials but is highly radioactive. It produces 

heat and remains hazardous for more than 10,000 years. 

Therefore, the spent fuel must be handled carefully. It can 

be reprocessed, stored, or disposed of permanently by isolating it from the environment for thousands of years. U.S. 

policy is to dispose of spent fuel by isolating it from the environment in an underground, geologic repository. Other 

nations also plan to construct geologic repositories, but 

most nations plan to store spent fuel or waste from reprocessing for many years before eventual disposal . 4 

Under the Nuclear Waste Policy Act of 1982 

(NWPA), 5the Congress required electric utilities generating power at nuclear plants to pay into a Nuclear Waste 

Fund to cover the costs of storage and disposal of spent nuclear fuel. Thus far, more than $4 billion has accumulated 

in this fund, which is administered by the Department of 

Energy (DOE). Contributions to this fund, which are ultimately paid by electric consumers, are now based on a 

charge of 1 mill (one-tenth of a cent) for each net kilowatthour of electricity produced by nuclear power plants. 

Under current law, DOE was expected to begin to take 

possession of the spent fuel in 1998 and, ultimately, to dispose of the waste in an underground repository. However, 

the program to develop a repository to receive the spent 

fuel for safe disposal is technically, institutionally, and politically complex. Consequently, according to DOE's estimates as of May 1989, it is unlikely a repository will be 

available before the year 2003. 6Other experts believe a repository may not be ready to accept spent fuel until considerably later. 

Thus, the question facing the country is: What should 

be done with the spent fuel accumulating at more than 70 

nuclear reactor sites around the country until it can be disposed of in a permanent repository? 

The Congress has grappled with this issue for some 

time. Some Members of Congress believe the waste should 

be left at the reactors until a permanent repository is built. 

Other Members, and the Department of Energy, believe 

DOE should collect spent fuel from the nuclear power 

plants and store it in a central, Federal facility before disposal. The term now used for such a facility is "monitored 

retrievable storage facility" (MRS). 

In 1985, DOE proposed to construct an MRS at one of 

three sites in Tennessee and recommended the Clinch River 

site. The proposed facility would perform the functions of 

storage, rod consolidation, packaging, and gathering spent 

fuel for shipment to the repository. In the ensuing debate 

over DOE's proposal, Congress created the MRS Review 

Commission to evaluate the department's proposal and to 

make a recommendation on the Nation's need for a monitored retrievable storage facility as part of its nuclear 

waste management system. 

1 
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SO U R C E: N R C 1 31 89 
Figure 1.2—The Commission's Charge 

Section One: The Commission's Mandate 

Congress created the MRS Review Commission in the 

Nuclear Waste Policy Amendments Act of 1987 

(NWPAA),7 directing the Commission to prepare a report 

on the need for an MRS as a part of a national nuclear waste 

management system. The need for an MRS also must be 

considered in the broader context of the Nation's need to 

develop "safe and environmentally acceptable methods of 

disposal." 8Congress specifically directed the Commission 

to compare storing spent fuel at an MRS to storing spent 

fuel at reactor sites before permanent disposal in a repository.9(See Figure 1.2.) 

In May 1988, the Department of Energy initiated nine 

system studies to help the MRS Review Commission in its 

evaluation. The studies were presented to the Commission 

in May 1989, along with DOE's latest position on the need 

for a monitored retrievable storage facility. In contrast to its 

1985 proposal, DOE's current proposal includes neither rod 

consolidation nor packaging functions, although DOE contemplated that the MRS might ultimately perform some of 

these functions. It is this current DOE position on which 

the Commission focused in response to its charge to "review the status and adequacy of the [Energy] Secretary's 

evaluation of the system's advantages and disadvantages of 

bringing such a facility into the national nuclear waste disposal system." 1 ° 

The MRS Commission shall: 

•(i) review the status and adequacy of the [Energy] Secretary's evaluation of the system's advantages and disadvantages of bringing such a facility into the national nuclear waste disposal•system; . , 

ii) obtain commehlandiavailable data on monitored retrievable storage frOrti affected parties, including States 

' containing potentially acceptable Sites; 

(iii) evaluate the utility of a monitored retrievable storage facility from a. technical perspective and 

 iv) make a recommendation to CongresS as to whether such a fkility should be included in the national nuclear 

Waste.management.systernirr order to .achieve the purposes of this chapter, including meeting needs.for pack= 

,aging and handling of spent nuclear fuel, improving the flexibility of the repository development schedule, and 

•proViding temporary storage of spent nuclear fuel accepted for disposal. • 

, . 

..The•CoMmission shall compare such a [monitored retrievable storage] facility to the alternative of at-reactor 

storage of spent nuclear fuel prior to disposal of such fuel in .a respoitory under this chapter. Such comparison 

shall take into consideration.the impact on— . 

(A) repositOry design and construction; 

' (B) waste package design, fabrication and standardization; 

(C) waste preparation; 

(D) waste transportation systems; 

–(E) the reliability of the national system for the disposal of radioactivewaste; 

(F) the ability of the Secretary to fulfill contractual commitments of the Department [of Energy] under this Act to 

. accept spent nuclear fuel kir disposal; and • • . 

.(G) economic factors, including the impact on the costs likely to be imposed on ratepayers of the Nation's electric. • 

utilities for temporary at-reactor storage of spent nuclear fuel prior to final disposal in a repository,•as well as 

the costs likely tb be imposed on ratepayers of the Nation's electric utilities. in building and operating such a 

facility. 

42 U.S.C. §10163 

3 

(3) 
Section Two: The Legal and Historical Context 

The concept of Federal monitored retrievable storage 

of spent fuel is not new. Appendix F gives a detailed chronology of the evolution of the concept. Monitored retrievable storage first surfaced in 1972 after the Atomic Energy 

Commission (AEC) abandoned plans for a repository near 

Lyons, Kansas. To fill the void this abandonment created, 

the AEC proposed aboveground structures called Retrievable Surface Storage Facilities (RSSFs) for long-term interim storage until a permanent repository was available. The 

Environmental Protection Agency (EPA) and others severely criticized a 1974 AEC draft environmental impact 

statement on RSSFs because of concern that the facilities 

could become low-budget, permanent repository sites." 

The RSSF proposal was withdrawn in 1975. 

In 1977, the need for interim storage became more 

pressing because of President Carter's decision to defer 

commercial reprocessing of spent fuel as part of his nonproliferation of nuclear weapons policy. 12With U.S. reprocessing indefinitely suspended, the President proposed 

that the Federal government take title to spent fuel, which 

would be transported at utilities' expense to a Federal 

away-from-reactor (AFR) facility for storage until a repository became available. 13In his nuclear waste policy announced in February 1980, the President included an AFR 

with more limited capacity than was originally proposed. 

Such an AFR was intended to provide interim storage for 

utility spent fue1. 14 

In 1981, the Reagan administration lifted the reprocessing deferral and withdrew the away-from-reactor 

storage proposa1. 15However, the MRS concept played an 

important role in the comprehensive nuclear waste legislation then pending before Congress. 

In the Nuclear Waste Policy Act of 1982, Congress attempted to create a stable institutional framework for managing the waste generated by the Nation's civilian nuclear 

power reactors. The act gave geologic disposal highest priority and set forth elaborate procedures and an ambitious 

schedule for siting, constructing, and operating two permanent geologic repositories. 

The statute directed DOE to submit to Congress a detailed study of the need for and feasibility of a monitored 

retrievable storage facility in the national nuclear waste 

management system, as well as a proposal for constructing 

one or more MRS facilities. 16The act envisioned an MRS 

that would: provide back-up storage of spent fuel and highlevel waste from civilian nuclear activities; allow for continuous monitoring, management, and maintenance of spent 

fuel for the foreseeable future; permit ready retrieval of the 

spent fuel for reprocessing or disposal; and safely store the 

spent fuel for as long as necessary (a time limit was not 

specified).'? 

In 1985, DOE completed its study of the need for and 

feasibility of an MRS facility in the national program and 

greatly modified the concept of what an MRS facility 

should be. 1 8Rather than a backup to the repository, the 

MRS was conceived as an integral part of an "improved 

performance" waste management system. 19The MRS 

would be used for consolidating, repackaging, and storing 

the waste until the repository was ready. 

In a companion study to the need and feasibility study, 

DOE proposed three MRS sites, all in Tennessee. 20The 

State of Tennessee sued DOE in Federal court to block submission to Congress of DOE's proposal to site the facility 

in Tennessee. Tennessee argued that the NWPA required 

the department to consult with the State before choosing 

specific MRS sites. The court agreed with the State and issued an injunction preventing DOE from submitting its 

proposal to Congress. 21However, the United States Court 

of Appeals reversed the lower court's decision, the Supreme Court refused to hear the case, 22and DOE submitted 

its proposal to Congress on March 31, 1987. 23 

In December 1987, Congress passed the Nuclear 

Waste Policy Amendments Act of 1987, reaffirming the repository program as the primary focus of the Federal waste 

management effort. The act directed DOE to terminate all 

site-specific activities (other than reclamation) at all candidate repository sites other than the Yucca Mountain site in 

Nevada (that is, at sites in Washington and Texas) and all 

initial site investigations for a possible second repository. 

The NWPAA also "annulled and revoked" DOE's proposal to locate an MRS at any of the three proposed sites in 

Tennessee.24The legislation authorized an MRS, but directed DOE to begin site surveys only after the MRS Review Commission submitted its report to the Congress. 

Furthermore, the statute included certain conditions, to be 

incorporated in any MRS license issued by the NRC, that 

limit the capacity of the MRS and closely link its construction and operation to the repository schedule. 25(See Figure 

1.3.) Thus, under current law, the prospects for successfully 

siting and constructing an MRS are closely linked to the repository project's progress. This linkage is a significant 

consideration in evaluating the need for and usefulness of 

an MRS. 

4 

7 0 2 CE 0 2 0 3 0 
Figufe 1.3—Nuclear Waste Policy Amendments Act-Linkage,_ 

.> 4: • k •2. 

(1) constructiorrof such facilitylMFISimay not begin until the Commission [NRC] has issued a license for the'tbn-- 

StiliCtion:a aleboSit*bridei section 10135(d); 

(2) construction of such Jacility,or acceptance of, spent nuclear Juel or high :level radioactive. waste shall be Orbhibi4 

.tea during such time as the repository license is revoked by' the COmmistion'or construction of the 

ceases;: 

(3) jtio,iintitct:61,SPentinU,olear fuel or high-level r',adioactive waste at the site of such faCilitjtiet;any One tinielenay 

':ritifk eeet[1010007Mettie:tOrld of heavy: etal until a!repository under this chapter first aOCeptS Spent nUcl earfueV,t' 

ot:Solidifie&hibh=f6ieliridibaaiVe waste; 

 

(4)athe:OciantitSttc?fSpent ptiClearfiJel bitiOnlevel radioact lye waste at the site of such ,facilify at any one; irna ma 

not exceed Metric tons Of ti eatj't'rnetal. 

„ 

 10i-6a(d) 

Section Three: The Problem 

The question before the Commission is: Given that it 

is national policy to dispose of spent fuel from civilian reactors in a permanent geologic repository, what is the most 

appropriate way to store that fuel as it accumulates before 

repository operations start? While there are many options, 

there are two basic alternatives: (1) continue storing all 

spent fuel at the reactors where the spent fuel is generated; 

that is, the No-MRS alternative, and (2) store some spent 

fuel at a central location or locations as well as at some reactors; that is, the MRS alternative. The Commission examined each alternative's merits to determine an interim 

storage strategy which, to the extent practicable, maximizes 

the safety and effectiveness of the overall waste management system and increases the probability of attaining the 

national goal of permanent disposal. 

Section Four: The Commission's Process 

The question of the need for monitored retrievable 

storage is complex, controversial, and subjective, involving 

assumptions and expectations about future events, technical 

and political. There are deeply felt views on all sides of the 

issue. 

Chapter Two describes the public policy context in 

which the issue has been examined, the major arguments 

for and against an MRS, and the issues which the Commission decided were most important in choosing between 

having and not having an MRS. 

Chapter Three explains the Commission's analytical 

methods and assumptions. It describes the three base cases 

the Commission evaluated: (1) having no MRS; (2) having 

an MRS linked to a repository schedule as specified in the 

NWPAA; and (3) having an MRS unlinked to a repository 

schedule and not limited in capacity. Chapter Three also 

describes (1) the two computer modeling tools the Commission used to analyze the base cases; (2) a set of detailed 

assumptions about how spent fuel will be handled and 

transported that are needed to define the base cases; and (3) 

the variations or "sensitivity analyses" on the base cases 

that were examined. 

Chapter Four compares the base cases by analyzing 

the relative effects on health, safety, and the environment. 

5 
It estimates the radiological dose to workers and the general public from each alternative. It considers the likelihood 

of a series of risks to public safety and the environmental 

and socioeconomic effects of each alternative. 

Chapter Five compares the base cases by analyzing 

how safely spent fuel could be transported and handled. It 

compares the radiological effects and non-radiological 

(traffic accident) risks posed by spent fuel transportation as 

it would be conducted if there were an MRS and if there 

were not. It examines the risks of various spent fuel handling and packaging methods (such as dual-purpose casks, 

rod consolidation, and transshipment). 

Chapter Six analyzes how the total system costs of the 

base cases would vary under the assumptions as to when 

the repository would begin to operate. The costs for each 

case and its principal cost components are estimated and 

the uncertainty inherent in the estimates discussed. The 

costs are analyzed in both nominal (undiscounted) value 

and present (discounted) value terms. 

Chapter Seven discusses the distribution of costs and 

benefits among ratepayers, taxpayers, and stockholders as 

well as among governmental jurisdictions and geographic 

regions. It describes the types of costs imposed and some 

of the mechanisms available to adjust or compensate for 

those costs, should that be desirable. This chapter also includes a discussion of the appropriateness of user funding 

of various components of the spent fuel management and 

disposal system as opposed to paying for all costs from the 

Nuclear Waste Fund. 

Chapter Eight describes the major policy advantages 

and disadvantages of an MRS, while concentrating on 

DOE's and the State of Tennessee's positions. The chapter 

concludes with a summary of the Commission's findings 

on the major advantages and disadvantages of an MRS. 

Chapter Nine contains the Commission's conclusions 

and recommendations. 

6 

7 0 2 0 2 0 
Chapter One Notes 

1.Department of Energy, Energy Information Administration, "Commercial Nuclear Power 1989," DOE/EIA-0438(89) 

(Hereafter cited as DOE/EIA-0438(89)), p. ix. 

2. In this report, the terms "spent fuel" and "waste" are 

used interchangeably. High-level waste is the highly radioactive 

material resulting from the reprocessing of spent nuclear fuel, including liquid waste produced directly in reprocessing and any 

solid material derived from such liquid waste, that contains fission 

products in sufficient concentrations; and other highly radioactive 

material that the Nuclear Regulatory Commission, consistent with 

existing law, determines by rule requires permanent isolation. 

3. Department of Energy, MRS System Study Summary Report, DOE/RW-0235, June 1989 (Hereafter cited as Task J), Appendix B, p. 6. 

4. See Appendix D for a detailed discussion of how other nations are handling spent fuel. The experience of these countries 

provides useful insights, but does not have any single clear 

message for U.S. spent fuel storage policy. The United States 

must make its decisions in a situation that is very different in a 

number of important aspects: in the absolute size (much larger) 

and relative importance (generally smaller) of its nuclear power 

program; in the regulatory, institutional, and political environment 

for nuclear power and waste management; in the pressures to develop a permanent repository and the related concerns that central 

storage facilities would delay that goal; and in the geographic 

characteristics (e.g., transportation distances, population densities, 

and the range of options available for siting storage and disposal 

facilities) that must be taken into account in waste management 

policy. 

5. 42 U.S.C. § 10101 et. seq. (January 7, 1983). 

6. Isaacs, Thomas H., Associate Director, External Relations 

and Policy, Office of Civilian Radioactive Waste Management, 

Department of Energy, "DOE Position on the Monitored Retrievable Storage (MRS) Facility," Prepared Remarks before the Monitored Retrievable Storage Review Commission, May 25, 1989, 

p. 4; Task J, p. 69. 

7. Pub. L. No. 100-203, 101 Stat. 1330-232 (December 22, 

1987)(codified as amended in scattered sections of 42 U.S.C.). 

8. 42 U.S.C. § 10131(a)(1). 

9. Storage, as defined in the Nuclear Waste Policy Act, is 

the retention of high-level radioactive waste, spent nuclear 

fuel, or transuranic waste with the intent to recover such waste or 

fuel for subsequent use, processing, or disposal. 42 U.S.C. § 

10101(2)(25). Disposal, as defined in the Nuclear Waste Policy 

Act, is the emplacement in a repository of high-level radioactive 

waste, spent nuclear fuel, or other highly radioactive material with 

no foreseeable intent of recovery, whether or not such emplacement permits the recovery of such waste. 42 U.S.C. § 10101(2)(9). 

10.42 U.S.C. § 10163(a)(1)(C)(i). 

11.Office of Technology Assessment, U.S. Congress, Managing the Nation's Commercial High-Level Radioactive Waste, 

New York: UNIPUB, 1985 (OTA, 1985), p. 85. 

12.Public Papers of the Presidents, Jimmy Carter, April 17, 

1977, Book 1, pp. 582-583. Spent fuel contains usable fissile material (U-235 and Pu-239) which can be recovered by chemically 

reprocessing the fuel and used in recycled fuel. Reprocessing to 

recycle the fuel is now being done in countries such as France, the 

Federal Republic of Germany (FRG), the United Kingdom, and 

Japan. In 1977, President Carter announced the indefinite deferral 

of reprocessing of commercial spent fuel because of concerns regarding nuclear weapons proliferation. Although President Reagan 

lifted the suspension of commercial reprocessing in 1981, it is not 

currently viewed as economical in the United States and is not being done here. 

Spent fuel from weapons reactors in the United States is reprocessed to recover plutonium for nuclear weapons. The waste 

from this reprocessing, now being stored as a liquid, will be solidified and disposed of in the same geologic repository as commercial spent fuel. Present projections of the medium potential for the 

production of defense high-level waste are between 9,500 and 

33,900 canisters or 4,750-16,950 MTU. Oak Ridge National Laboratory, "Integrated Data Base for 1988; Spent Fuel and Radioactive Waste Inventories, Projections, and Characteristics," DOE/ 

RW-0006, Rev. 4, September 1988, p. 54. (This is based on an estimate of 0.5 MTU of defense high-level waste per canister.) 

Kerrisk, J. F., "An Assessment of the Important Radionuclides in 

Nuclear Waste," October 1985, pp. 3-4. 

13.OTA, 1985, p. 87. 

14.Public Papers of the Presidents, Jimmy Carter, February 

12, 1980, Book 1, pp. 296-301. 

15.OTA, 1985, p. 88. 

16.42 U.S.C. § 10161. 

17.42 U.S.C. § 10161(b). 

18.Department of Energy, "The Need For and Feasibility of 

Monitored Retrievable Storage—A Preliminary Analysis," DOE/ 

RW-0022, April 1985. 

19.Department of Energy, "Mission Plan for the Civilian 

Radioactive Waste Management Program," Vol. 1, DOE/ 

RW-0005, June 1985, pp. 122-126. 

20. Department of Energy, "Screening and Identification of 

Sites for a Proposed Monitored Retrievable Storage Facility," 

DOE/RW-0023, April 1985. 

21. Tennessee v. Herrington, 626 F. Supp. 1345 (M.D. Tenn. 

1986). 

22. Tennessee v. Herrington, 806 F. 2d 642 (6th Cir. 1986), 

cert. denied, 480 U.S. 946 (March 30, 1987). 

23. Department of Energy, "Monitored Retrievable Storage 

Submission to Congress," DOE/RW-0035/1-Rev. 1, March 1987. 

24. 42 U.S.C. § 10162. 

25. These statutory provisions refer to both spent fuel and 

high-level radioactive waste. However, the Commission has interpreted its mandate to be limited to wastes from the civilian reactor 

program. Defense wastes will not be addressed in this report. Storage facilities for vitrified defense wastes are being constructed at 

the sites of the vitrification plants. 

7 
Interim storage 

Figure 2.1—The Nuclear 

Fuel Cycle 

Geologic disposal 

Milling 

Exploration Mining 

FRONT END BACK END 

SOURCE: U.S. Office of Technology Assessment 

(Adapted from chart In Managing the Nation's Commercial High-active Radioactive Waste) 

Fuel fabrication 

Enrichment 

UF6 conversion 

High-level waste 

or spent fuel 

Chapter Two 

Key Issues 

How to manage and dispose of spent nuclear fuel pmdently and safely has proven to be a difficult, contentious 

public policy issue. It involves many technical and scientific uncertainties as well as public policy judgments about 

which fair and informed people have legitimate differences 

of opinion. 

During its deliberations, the Commission held public 

meetings to hear the views of the public and government 

officials on the need for Federal monitored retrievable storage.' Wide-ranging views were expressed by Members of 

Congress, private citizens, representatives of citizen and 

environmental action groups, nuclear waste experts, managers of nuclear utilities, and governmental representatives 

at the Federal, State, and local levels. The Department of 

Energy (DOE) testified three times that an MRS is needed 

as an integral part of the Nation's nuclear waste management system. 2With few exceptions, persons expressing 

views to the Commission supported construction of a permanent repository regardless of whether an MRS is built. 3 

The MRS, if built, could be a part of the nuclear fuel cycle 

as shown in Figure 2.1. 

The Commission studied all of the testimony presented during its public meetings and all of the statements 

submitted for the record. It became apparent that the Commission would be unable to address all topics that might in 

some way relate to the need for an MRS. Some, like storage of defense wastes, were beyond the Commission's 

mandate. Others, like the suggestion that spent fuel could 

be shipped to Europe for storage and reprocessing, were 

too speculative to merit serious consideration at this time. 

Therefore, the Commission decided to organize the most 

important issues into five categories for study: (a) health, 

safety, and environmental effects, (b) transportation safety, 

(c) economic costs and benefits, (d) distributional and equity concerns, and (e) policy considerations. 

Section One of this chapter describes the public policy 

context of the MRS debate. Section Two categorizes and 

summarizes the primary arguments presented to the Commission for and against an MRS in each of the five study 

categories. Section Three lists the key questions that 

needed to be answered before the Commission could make 

an informed recommendation. 

9 

k: e 
Section One: Public Policy Context 

Few, if any, public policy issues have as long a planning horizon as nuclear waste disposal. The objective of 

permanent disposal is to limit to safe quantities the amount 

of nuclear waste that will reach the biosphere during the 

next 10,000 years and beyond. To put this objective in perspective, a planning horizon of 10,000 years dwarfs the 

lifespan of the world's recorded civilizations and political 

entities. Moreover, the United States' goal is to achieve 

permanent disposal within a single generation. 

A time horizon of this length means that geologic stability and dynamics must be understood more completely 

than for any previously built facility. Choosing a location 

for a nuclear waste facility requires extensive site characterization and complex technical evaluation; these studies 

themselves take years and they may be complicated and delayed by political and policy issues, such as a community's 

response to siting plans. Despite the considerable time and 

money already expended to site a repository, none has been 

sited yet, and the date by which a permanent repository 

will be available is uncertain. 

The purpose of building an MRS would be to store 

spent fuel from the time it is produced at reactors until it 

can be emplaced in a repository. The date when a permanent repository is likely to become operable and the debates surrounding that date are very important considerations in determining the need for an MRS. 

The nuclear waste disposal debate has served as a 

proxy for the more fundamental debate about the merits of 

nuclear power technology. Critics argue that nuclear power 

should not be pursued unless a solution to the nuclear 

waste disposal problem is found. 4Many environmental activists and other concerned citizens view effective nuclear 

waste disposal as a major moral imperative facing this generation. The risks of nuclear waste loom large in the environmental activists' view because some of the harmful 

materials have an extremely long life, and the costs of isolating them from the biosphere are high. Environmental activists assert that this generation has an ethical responsibility to guarantee that today's radioactive waste will not 

harm succeeding generations. 5 

For nuclear proponents, demonstrating the ability to 

manage and dispose of nuclear waste safely will validate 

the use of nuclear power. Supporters of nuclear power, and 

many members of the scientific community, believe nuclear waste can be managed and disposed of safely, but they 

are frustrated because large amounts of money, time, and 

resources have been dedicated to solving the problem with 

little apparent progress. 6 

Regardless of one's views on the merits of nuclear 

power, about 20,000 metric tons of spent fuel already exist 

at the reactor sites and must be stored somewhere. The 

Commission's charge is to evaluate objectively and systematically the alternatives for interim storage of spent fuel as 

part of the Nation's nuclear waste disposal system. Thus, 

this evaluation is structured around the specific arguments 

which have been made for and against an MRS. 

Section Two: Summary of the Key Issues 

This section summarizes the testimony presented to 

the Commission in each of the five study categories. Table 

2.1 lists the main arguments in each category for and 

against building an MRS facility. The remainder of the section explains these arguments more fully. 

A. Health, Safety, and Environmental Effects 

Public health and safety and environmental protection 

are serious concerns of the American people and are of 

highest priority to the Commission. 

1. Arguments for an MRS 

Supporters emphasize that the technology is safe: the 

MRS poses no significant hazards to public health and 

safety, or the environment; and the risks associated with 

the MRS are similar to those of at-reactor storage.? Proponents assert that an MRS facility will reduce the interference that at-reactor storage poses for reactor operations, 

allowing utilities to focus attention on their primary responsibility: safe and reliable generation of electricity. 8 

DOE and the utilities also argue that early and adequate 

10 
Fuel is already stored safely at reactors, so unnecessary 

Means additional handling and subsequent increase in risk 

Early decision needed to plan for emergencies 

a long routes 

Economic Costs If more expensive overall, benefits outweigh costs 

'and Benefits . , . 

May not be:more expensive overall if repository 

delayed and the cost to reactors of delaying , 

decommissioning is considered 

Reduces at-reactor storage costs 

Generates economies of scale for packaging and 

handling 

Distributional and Generates regional equity because only disposal 

Equity Concerns site is currently in West 

Risks, costs, stigma of being a high-level waste 

site would be shared 

Unfair to ratepayers to pay for an MRS which is 

more expensive than No-MRS. 

Provides valuable experience for siting repository 

More beneficial if NWPAA linkages are removed 

Provides system flexibility to adapt to an uncertain 

future 

Timely siting and construction needed to maximize 

.MRS usefulness 

Will become a de facto repository; linkages with repository should be strengthened 

Will divert critical resources from repository 

Uncertainties in siting and developing an MRS 

System bottlenecks less likely to occur with at-reactor for storage 

Policy Enables DOE to meet its contractual commitment 

COnsiderations for early acceptance 

Utilities will end up paying more for at-reactor storage unless DOE fulfills its contract 

Federal government is not obligated to begin accepting spent fuel in 1998 if there are compelling 

reasons to delay or cancel an MRS facility 

Congress can change commitment 

• 

Category 

Health, Safety, 

and Environment 

RedOces interference with reactor operation's • 

Prevents delay in decommissioning 

, . 

Transportation Consolidates routes to permanent site, limiting 

Impacts • – ' states/localities affected 

Too expensive 

Benefits do not outweigh costs 

At-reactor storage cheaper 

No reductions in at-reactor costs because MRS 

cannot be built in time 

Enhanced transportation strategies are less expensive than an MRS 

Makes western utilities pay for an MRS they may 

not use 

Makes utilities with extensive at-reactor storage 

pay twice—for at-reactor storage and an MRS 

Will be more of a terrorist target 

Major Arguments Presented to the Commission 

For and Against an MRS Facility 

Against MRS 

Table 2. 

For MRS 

Technology is safe 

11 

7 C)) '7!‘ .) 41. 
waste acceptance will ensure that spent fuel is removed 

from reactors without delaying planned decontamination 

and decommissioning. 9 

2. Arguments against an MRS 

Several witnesses asserted that an MRS will increase 

risks to public health and safety, and impacts on the environment. They believe that spent fuel is being stored safely 

at reactors and can continue to be safely stored there until a 

repository becomes available. Some feel an MRS increases 

the risk of terrorist attacks because an MRS may require 

more shipments. They fear that collecting a large volume 

of spent fuel in a central location will provide a tempting 

target for terrorism. 19 

B. Transportation Impacts 

Most State and local government representatives, 

while taking no position on an MRS, raise concerns about 

the transportation of spent fuel through their regions and 

inadequate emergency response capabilities along the 

routes. They stress the need for an early decision on an 

MRS to allow sufficient time for planning and emergency 

response training along proposed routes. 

1. Arguments for an MRS 

Some proponents suggest that consolidating spent fuel 

and using dedicated trains from the MRS to the permanent 

disposal site will reduce transportation impacts. DOE subscribed to this view in 1987 but has since concluded that 

transportation impacts are not a discriminator between 

MRS and No-MRS options, because actual transportation 

risks are extremely low." DOE currently believes that an 

MRS will offer transportation advantages because the MRS 

would consolidate routes to the permanent disposal site, 

thus limiting the number of States and localities affected, 

as well as their need to be prepared for an emergency. 

2. Arguments against an MRS 

Substantial public apprehension exists over potential 

radioactive transportation accidents. Many argue that an 

MRS means additional handling and transportation of spent 

fuel, thereby significantly increasing the risk of radioactive 

contamination to people and property.' 2The State of Tennessee asserts that using dual-purpose casks and transporting spent fuel directly from the reactors to the repository 

would reduce handling and transportation impacts. 13 

C. Economic Costs and Benefits 

The costs and benefits of an MRS would accrue to 

utilities and their ratepayers. 

1. Arguments for an MRS 

Proponents suggest that an MRS facility would provide benefits by generating economies of scale for spent 

fuel storage and packaging. Also, early acceptance of waste 

at an MRS will limit utility expenses for storing additional 

waste in and outside reactor pools. 14Utility representatives 

assert that an MRS facility will reduce the costs and complexities of on-site storage of spent fuel, yielding significant savings to ratepayers. 15Utilities are frustrated because 

the Federal government's waste management program has 

consumed large amounts of money but has shown little 

progress. 

DOE indicates that an MRS facility will add between 

$1.3 billion and just over $2 billion to the cost of the national spent fuel management and disposal system. The 

costs cited are "net," meaning savings at reactors are taken 

into account. DOE points out that the earlier the MRS becomes operational, the greater the reduction in utility at-reactor storage costs, and the lower the net cost to the 

system. 16 

DOE argues that additional costs are justified by the 

advantages of building an MRS facility. DOE notes that the 

department's cost estimates do not take into consideration 

the potentially significant cost to reactors of delaying decommissioning if the opening of the repository is delayed." 

2. Arguments against an MRS 

Opponents of an MRS assert that it is too expensive 

and that the potential benefits of incorporating the facility 

into the nuclear waste management system do not justify 

the costs. The State of Tennessee asserts that an optimized 

No-MRS strategy, using dual-purpose casks, would be $1 

billion to $5 billion cheaper than a system with an MRS. 18 

Some MRS opponents believe that the costs of an MRS 

will escalate well beyond DOE's current estimates, as has 

been the case with the costs of other nuclear facilities. 

Some nuclear industry representatives do not favor an 

MRS. They point out that on-site storage would be cheaper 

than having an MRS in the system. 19They conclude that 

continual slippage in DOE's schedule for opening the repository makes it highly unlikely an MRS will be sited and 

constructed within a reasonable time, especially in view of 

the linkages between the repository and an MRS. These nuclear industry representatives assert many utilities will not 

experience the reductions in on-site storage costs claimed 

by MRS proponents. They say it will be more cost effective 

in the long run to store the wastes at reactor sites while 

moving as expeditiously as possible to construct a permanent repository. 

12 

7 0 2 2 0 7 
D. Distributional and Equity Concerns 

Siting an MRS in the East would affect the geographic 

distribution of the costs and benefits of the Nation's waste 

management system. 

1. Arguments for an MRS 

The NWPAA directs DOE to limit its characterization 

of repository sites to Nevada's Yucca Mountain. Some contend that the process for making this determination was biased and unfair, and that Congress singled out Nevada for 

the repository because Nevada, with only two representatives in the House of Representatives, did not have enough 

influence in Congress. Consequently, Nevadans have to 

bear the burden of perceived risks, costs, and stigma associated with the nuclear repository. Some believe, therefore, 

that the burdens associated with hosting a nuclear waste 

site should be shared by placing an MRS facility in the 

Eastern United States where most nuclear reactors are 

located. 

2. Arguments against an MRS 

Some utilities say that financing the cost of an MRS 

facility from the Nuclear Waste Fund would create financial inequities in the nuclear waste system because a utility's share of the cost would be proportionate to the amount 

of electricity it generated from nuclear reactors rather than 

proportionate to the extent to which it used an MRS facility. Therefore, utilities which need additional storage would 

derive substantially more benefit from an MRS facility 

than would utilities that do not need the storage. 20Utilities 

that have planned for life-of-plant storage claim that it is 

unfair for them to have to pay both for on-site storage and 

for an MRS. Some oppose the MRS because they contend 

that the utilities can provide less expensive storage on-site 

than could be provided at an MRS. Therefore, the overall 

system costs would be greater with an MRS. 

Others oppose the MRS if a plan for a western repository location and an eastern MRS site prevented western 

utilities from using the MRS. This "western strategy" 

would require the utilities to continue storing spent fuel onsite until the repository is available, at which time they 

would then ship the spent fuel directly to the repository. In 

this case, western utility ratepayers would pay proportionately the same share to build an MRS facility as ratepayers of nuclear utilities in other sections of the country. 

Western ratepayers, however, would not benefit directly 

from the facility. 21 

E. Policy Considerations 

The objectives of U.S. nuclear waste policy are important considerations in evaluating the need for an MRS 

facility. 

1. Arguments for an MRS 

DOE and most utilities favor building an MRS to allow the Federal government to begin accepting utilities' 

spent fuel at the earliest possible time. Early acceptance of 

the waste, utilities argue, will allow DOE to meet its contractual obligation to begin accepting spent fuel by January 

1, 1998.22The Nuclear Waste Policy Act of 1982 authorized the Secretary of Energy to enter into contracts with 

nuclear utilities for acceptance of title, subsequent transportation, and ultimate disposal of spent fuel beginning not later than January 31, 1998. DOE is to provide these services 

in exchange for utilities' paying fees into the Nuclear 

Waste Fund. Since utilities must pay into the Nuclear 

Waste Fund whether an MRS is built or not, utilities have 

strong economic reasons to insist that DOE fulfill what 

they claim are its contractual obligations. In addition, utility representatives express concern that nuclear power opponents would oppose on-site storage expansion. 23These 

utilities believe DOE's early acceptance of spent fuel is of 

the utmost importance if they are to keep operating their 

plants. 

DOE and other MRS proponents conclude that an 

MRS facility will positively affect the repository program 

by providing valuable experience in siting, licensing, and 

operating a large-scale waste management facility; by 

using proven technology earlier than the repository; and by 

generating the momentum needed for repository development and to boost public confidence in DOE. 24The department has never participated in a Nuclear Regulatory 

Commission (NRC) licensing proceeding for any waste 

management facility. If an MRS facility could be licensed 

before a repository, DOE believes that the repository program would benefit from the MRS licensing experience. 

DOE and some utility representatives also state that an 

MRS facility would add substantially to the waste management system's reliability and flexibility. 25They assert that 

an MRS facility will provide the infrastructure needed to 

face an uncertain future and to respond to unforeseen emergencies. 26Without an MRS, DOE stresses, the Nation's 

ability to provide for the continuous, orderly transfer of 

spent fuel from reactors will depend totally on achieving 

uninterrupted operation at a first-of-a-kind geologic repository. 27Proponents assert an MRS would insulate reactors 

from slippages in the repository schedule and provide buffer capacity if disruptions occur in repository operations. 

DOE asserts that an MRS facility would provide flexibility in making decisions about waste aging and the preferred location of waste packaging functions. For example, 

13 
if DOE decides that aging spent fuel before emplacing it in 

the repository is advantageous, an MRS, DOE believes, 

will allow that policy to be carried out without additionally 

burdening utilities. DOE suggests packaging functions 

could be added at an MRS to minimize the repository's surface operations, thus simplifying the licensing of the 

repository. 

Utility industry advocates of an MRS argue that 

timeliness in siting and constructing the facility is critical, 

since an MRS facility's usefulness would be diminished if 

it were made operational on the same schedule as a permanent repository. Advocates recommend removing or changing the linkages between the MRS facility and the permanent repository. 28According to DOE, the advantages 

of having an MRS facility will be reduced significantly under current statutory provisions that link the MRS to the repository schedule. 29In the department's opinion, achieving 

full benefits depends on early licensing and operation of an 

MRS, which can only be achieved by siting the MRS 

through the Nuclear Waste Negotiator with a Congressionally approved agreement that does not link an MRS's 

schedule to the repository schedule. 3° However, DOE 

stresses that the MRS will offer significant advantages even 

if the linkages are not revised. 31 

2. Arguments against an MRS 

The most frequently heard argument against an MRS 

is that if an MRS is constructed, it will become a de facto 

repository. Opponents of an MRS assert that utility pressure on the Federal government to accept the waste will decline significantly once waste is moved to an MRS facility. 

Although current MRS capacity limits ensure the majority 

of the spent fuel will remain at the reactors, critics fear 

these capacity limits could be easily lifted once the facility 

is built and operating. Critics are concerned that the national interest in permanent disposal will erode once an interim 

storage facility is available to store the spent fuel safely for 

the foreseeable future. These opponents of an MRS believe 

strongly in the NWPAA linkages between an MRS facility 

and the repository schedule because the linkages ensure 

that the focus will remain on deep geologic disposal. Some 

opponents want the linkages strengthened. 32 

Opponents assert that an MRS will divert critical resources from the repository program. Many state that they 

have little confidence in DOE's ability to manage two programs successfully and simultaneously. These critics are 

concerned that an MRS will decrease the likelihood that 

geologic disposal will be developed in a timely manner. 

Opponents also question system reliability and flexibility improvements. Many see an MRS as a potential bottleneck. Should a problem occur at the MRS facility, the 

flow of spent fuel to the repository could stop. They also 

claim reliability and flexibility cannot be guaranteed because siting an MRS facility will be a difficult task. 33 

Many opponents regard prolonged at-reactor storage as the 

most flexible and reliable alternative because at-reactor 

storage can be added safely and incrementally in a timely 

manner, 34while preventing system bottlenecks and avoiding significant siting and development uncertainties. 35 

Some believe that an MRS is not needed because the 

Federal government is not obligated to begin accepting 

commercial spent fuel in 1998. 36In general, these opponents assert, nuclear waste management schedules established by law have not been met. 

Section Three: Key Questions 

Section Two recapitulated the main arguments presented to the Commission in the five study categories. This 

section lists the key questions to be addressed in Chapters 

Four through Eight. 

1.Are the effects on health, safety, and the environment significantly different if some spent fuel is 

stored at an MRS facility instead of all being stored 

at reactors? 

2. Are the transportation risks associated with using 

different routes and different modes of transport 

significantly different if spent fuel is stored at an 

MRS facility instead of at reactors? 

3.What are the economic costs and benefits associated with storing spent fuel at an MRS facility as 

compared to at-reactor storage, and does a comparison of the costs and benefits make one option more 

desirable than another? 

4. Are there economic and social equity issues that 

should be taken into consideration in determining 

the need for an MRS facility? If so, what are the equity issues and do they favor choosing an MRS facility over at-reactor storage? 

5. Which policy issues should be taken into consideration in evaluating the need for an MRS facility, and 

do they make a significant difference in the 

evaluation? 

These questions are discussed in the following 

chapters. 

14 

7 0 2 3 
Chapter Two Notes 

1. See Appendix A for a list of people who testified before 

the Commission and Appendix B for a list of people who submitted written statements for the record. 

2. An integral MRS facility is one which would receive and 

eventually ship to the repository all spent fuel requiring permanent disposal, and thus integrate the MRS into the Federal waste 

management system. In the integral MRS, there may be a "western strategy" in which the spent fuel from western reactors would 

go directly to the repository. 

3. Hamilton, William, Manager, Nuclear Waste Department, 

Westinghouse Electric Corporation, Transcript of Monitored Retrievable Storage Review Commission Public Hearings (Hereafter cited as Hearings Transcript), December 1, 1988, p. 41; 

Smith, Ben L., Executive Administrative Assistant III, Tennessee 

State Planning Office, Hearings Transcript, December 1, 1988, p. 

60; Mazur, Donald W., Managing Director, Washington Public 

Power System, Hearings Transcript, January 9, 1989, pp. 71-74; 

Anderson, Robert, Executive Director of Engineering, Chem-Nuclear Systems, Inc., Hearings Transcript, January 18, 1989, pp. 

483-484; Parker, Mike, U.S. House of Representatives, 4th District, Mississippi, Hearings Transcript, January 18, 1989, p. 451; 

Keyserling, Harriet, State Representative, South Carolina Nuclear 

Waste Consultation Committee, Hearings Transcript, January 17, 

1989, p. 234. 

4. Johnsrud, Judith, Ph.D., Director, Environmental Coalition 

on Nuclear Power, and Research Director, Food and Water, Inc., 

Hearings Transcript, December 1, 1988, p. 145; Ferguson, Richard, Ph.D., Regional Vice President for Southern California/Nevada, Sierra Club, Hearings Transcript, January 9, 1989, p. 161; 

Eichelberger, Don, Staff Person, Abalone Alliance, Hearings 

Transcript, January 9, 1989, pp. 337-338; Johnson, Tim, Co-Director, Campaign for a Prosperous Georgia, Hearings Transcript, 

January 18, 1989, pp. 392-393. 

5. Schmitz, Margaret, Pastor, Maybeury-Elkhorn United 

Methodist Charge, Hearings Transcript, December 2, 1988, pp. 

307-308; Colonna, Andy, Private Citizen, Hearings Transcript, 

January 9, 1989, p. 332; Gorenflo, Louise, Rural Cumberland Resources, Hearings Transcript, January 17, 1989, pp. 284-286; 

Drey, Laura, News Editor, Coalition for Alternatives to Shearon 

Harris, Hearings Transcript, February 16, 1989, pp. 175-176. 

6. Childress, Paul, Babcock and Wilcox, Nuclear Power Division, Project Manager, and American Society of Mechanical Engineers, High-level Radioactive Waste Committee, Hearings 

Transcript, December 2, 1988, pp. 360-361; Stephens, J.D., President, Oil, Chemical and Atomic Workers International Union 

3-288, Hearings Transcript, January 18, 1989, pp. 340-342; Shifter, James D., Vice President of Nuclear Power Generation, Pacific Gas and Electric Company, Prepared Remarks, January 9, 

1989, pp. 6-7. 

7. Childress, Hearings Transcript, December 2, 1988, pp. 

360-361, 363; Behnke, Wallace, Vice Chairman, Commonwealth 

Edison Company, Hearings Transcript, January 9, 1989, pp. 22-

23; McMeekin, T.C., Vice President, Design Engineering, Duke 

Power Company, Hearings Transcript, January 17, 1989, p. 131. 

8. Isaacs, Thomas H., Associate Director, External Relations 

and Policy, Office of Civilian Radioactive Waste Management, 

Department of Energy, Transcript of Briefing before the Monitored Retrievable Storage Review Commission, July 25, 1988 

(Hereafter cited as Briefing Transcript, July 25, 1988), p. 66; 

Hamilton, Hearings Transcript, December 1, 1988, pp. 44-45; 

Counsil, W.G., Vice Chairman, Texas Utilities Electric Company, 

Hearings Transcript, January 17, 1989, pp. 19-22; Beedle, Ralph, 

Vice President, Nuclear Support Services, New York Power Authority, Hearings Transcript, February 17, 1989, p. 235. 

9. Isaacs, Thomas H., Associate Director, External Relations 

and Policy, Office of Civilian Radioactive Waste Management, 

Department of Energy, "DOE Position on the Monitored Retrievable Storage (MRS) Facility," Prepared Remarks before the Monitored Retrievable, Storage Review Commission, May 25, 1989 

(Hereafter cited as Isaacs, Prepared Remarks, May 25, 1989), 

p. 9; Snipes, Gregory, Engineering Supervisor II, Design Engineering, Duke Power Company, Hearings Transcript, January 17, 

1989, p. 136. 

10.Jackson, Carol, MRS Coordinator, West Virginia Citizens 

For a Clean Environment, Hearings Transcript, January 17, 1989, 

p. 254; Johnson, Tim, Hearings Transcript, January 18, 1989, p. 

391; Riley, Jessie L., Chairman of the North Carolina Nuclear 

Subcommittee, Sierra Club National Energy Committee, Hearings 

Transcript, February 17, 1989, p. 275. 

11.Isaacs, Prepared Remarks, May 25, 1989, pp. 20-21. 

12.Lowery, Leon, Legislative Representative, Environmental Action, Hearings Transcript, December 2, 1988, pp. 318-320; 

Sanford, Terry, U.S. Senate, North Carolina, as presented by John 

Blackburn, Legislative Assistant, Hearings Transcript, February 

17, 1989, p. 309; Hoyle, Janet, President, Blue Ridge Environmental Defense League, Hearings Transcript, February 16, 1989, 

pp. 68-70; Hefner, W.G. (Bill), U.S. House of Representatives, 

8th District, North Carolina, as presented by Bill McEwen, Administrative Assistant, Hearings Transcript, February 16, 1989, 

p. 140. 

13.Smith, Hearings Transcript, December 1, 1988, pp. 67-

68; Colglazier, Dr. E. William Jr., Director, Energy, Environment 

and Resources Center, University of Tennessee, Hearings Transcript, February 16, 1989, pp. 99-100. 

14.Isaacs, Thomas H., Associate Director, External Relations and Policy, Office of Civilian Radioactive Waste Management, Department of Energy, Transcript of Briefing before the 

Monitored Retrievable Storage Review Commission, May 25, 

1989 (Hereafter cited as Briefing Transcript, May 25, 1989), 

pp. 22-23. 

15.Counsil, Hearings Transcript, January 17, 1989, pp. 13-

14; Beedle, Hearings Transcript, February 17, 1989, p. 235. 

16.Isaacs, Prepared Remarks, May 25, 1989, pp. 17-18. 

17.Letter dated August 15, 1989, to the Monitored Retrievable Storage Review Commission from Thomas H. Isaacs, Associate Director for External Relations and Policy, Office of Civilian 

Radioactive Waste Management, Department of Energy. 

18.McWherter, Ned, Governor, State of Tennessee, "Tennessee's Position on the MRS: Final Comments to the Monitored 

Retrievable Storage Review Commission," July 20, 1989, p. 10. 

19.Fuirerer, Anton, Director, Special Projects, Rochester 

Gas and Electric Company, Hearings Transcript, December 1, 

1988, pp. 101, 111-112; Willis, William F., Executive Vice President and Chief Operating Officer, Tennessee Valley Authority, 

Hearings Transcript, January 17, 1989, pp. 175-177, 183. 

15 
20. Smith, Hearings Transcript, January 18, 1989, pp. 425-

426; Gordon, Bart, U.S. House of Representatives, 6th District, 

Tennessee, as presented by Harrison M. Wadsworth, III, Staff 

Member, Hearings Transcript, February 16, 1989, p. 133. 

21. Shiffer, James D., Vice-President of Nuclear Power Generation, Pacific Gas and Electric Company, Hearings Transcript, 

January 9, 1989, pp. 202-203. 

22. Berry, William W., Chairman of the Board, Virginia 

Power Company, Hearings Transcript, December 2, 1988, 

pp.228-229; Behnke, Hearings Transcript, January 9, 1989, pp. 

12-13; Shiffer, Hearings Transcript, January 9, 1989, pp. 196-

197; Counsil, Hearings Transcript, January 17, 1989, pp. 12-13. 

23. Behnke, Hearings Transcript, January 9, 1989, pp. 19; 

Shiffer, Hearings Transcript, January 9, 1989, p. 204; Beedle, 

Hearings Transcript, February 17, 1989, pp. 239, 242-243. 

24. Shiffer, Hearings Transcript, January 9, 1989, pp. 199-

201; Peelle, Elizabeth, Consultant, Socio Economic Study Group, 

MRS Task Force, Hearings Transcript, February 16, 1989, p. 62; 

Counsil, Hearings Transcript, January 17, 1989, pp. 13-14; Isaacs, 

Briefing Transcript, May 25, 1989, pp. 16-17, 26. 

25. Isaacs, Briefing Transcript, July 25, 1988, pp. 52, 84; 

Hamilton, Hearings Transcript, December 1, 1988, pp. 39, 42. 

26. Counsil, Hearings Transcript, January 17, 1989, p. 13; 

McMeekin, Prepared Remarks, January 17, 1989, p. 5; Willis, 

Hearings Transcript, January 17, 1989, p. 198. 

27. Isaacs, Briefing Transcript, May 25, 1989, p. 25. 

28. Hamilton, Hearings Transcript, December 1, 1988, p. 39; 

Mazur, Hearings Transcript, January 9, 1989, pp. 80-81. 

29. Isaacs, Briefing Transcript, May 25, 1989, pp. 14-15. 

30. The NWPAA provides for the creation of an Office of the 

Nuclear Waste Negotiator to "attempt to find a State or Indian 

tribe willing to host a repository or monitored retrievable storage 

facility at a technically qualified site on reasonable terms" and to 

"negotiate with any State or Indian tribe which expresses an interest in hosting a repository or monitored retrievable storage facility." 42 U.S.C. § 10242(b)(2). If a negotiator finds a willing 

"volunteer" state to host a repository or MRS, the proposed 

agreement must be submitted to Congress to be enacted into law. 

42 U.S.C. § 10243(d)(3)(A). 

31. Isaacs, Prepared Remarks, May 25, 1989, pp. 17-18. 

32. Broughton, Jeffrey J., City Manager, City of Oak Ridge, 

Tennessee, Hearings Transcript, January 17, 1989, pp. 216-217; 

Eddleman, Wells, Staff Scientist, North Carolina Citizens Research Group, Hearings Transcript, January 18, 1989, p. 532; 

Clarke, James McClure, U.S. House of Representatives, 11th District, North Carolina, as presented by Claudine Cremer, District 

Assistant, Hearings Transcript, February 17, 1989, pp. 266-267. 

33.Johnson, Hearings Transcript, January 18, 1989, pp. 391, 

394-395; Sharp, Jane, Board Member, Conservation Council of 

North Carolina, Prepared Remarks, February 16, 1989, p. 1; Colglazier, Hearings Transcript, February 16, 1989, pp. 98-99. 

34. Fuierer, Hearings Transcript, December 1, 1988, pp. 101-

102, 122-125; Lowery, Hearings Transcript, December 2, 1988, 

pp. 321-323; Mazur, Hearings Transcript, January 9, 1989, pp. 

71-72, 74; Willis, Hearings Transcript, January 17, 1989, pp. 

182-203. 

35. Kassen, Melinda, Senior Attorney, Environmental Defense Fund, Hearings Transcript, January 5, 1989, pp. 137-138; 

Willis, Hearings Transcript, January 17, 1989, p. 176; Sanford, 

Hearings Transcript, February 17, 1989, pp. 310-311. 

36.Johnsrud, Prepared Remarks, December 1, 1988, p. 6; 

Colglazier, Hearings Transcript, February 16, 1989, pp. 115-116. 

16 

7 0 2 0 9 ,4 
Chapter Three 

Analytical Methodology 

Chapter One defined the problem: the Commission is 

to compare the alternatives of having and not having an 

MRS in the national spent fuel management system. Chapter Two defined the issues to be considered when comparing the alternatives. Chapter Three explains the analytical 

methods the Commission used to compare the alternatives 

quantitatively. 

To define the MRS and No-MRS alternatives, the 

Commission had to select among hundreds of variables, 

such as where storage, rod consolidation, and waste packaging would be performed; schedules for MRS and repository development; spent fuel discharge projections; cost 

assumptions; transportation schemes and modes; MRS and 

repository locations; and cask types and capacities. The 

Commission selected the most significant variables and 

used them to define the alternatives on which it focused its 

evaluation. 

The Commission defined two basic categories of spent 

fuel management systems (MRS and No-MRS alternatives), identified the variables most likely to affect its decision on the need for an MRS, and developed analytical 

models to enable it to compare quantifiable aspects of the 

alternatives. Section One of this chapter describes, in general terms, the two basic interim spent fuel management alternatives which the Commission evaluated. Section Two 

explains the computer models developed to examine the 

quantifiable costs and risks. Section Three lists the principal assumptions used to define the base cases that were 

evaluated for the alternatives. That is, this section discusses 

the important variables in choosing among alternatives and 

explains what values the Commission assigned to those 

variables to analyze the base cases. Section Four discusses 

the variations on the base cases that were evaluated. 

Section One: No-MRS and MRS Alternatives 

The Commission evaluated approaches to interim 

spent fuel storage that fell into two basic categories: 1) the 

No-MRS alternatives, in which all spent fuel continues to 

be stored at the reactor sites until a repository becomes 

available and 2) the MRS alternatives, in which some 

spent fuel is stored at a central Federally-owned facility until a repository becomes available. (See Figure 3.1.) 

To analyze the alternatives, the Commission postulated three start-up dates for the repository: 2003, 2013, 

and 2023. The 2003 date reflects DOE's current schedule 

for repository availability) The Commission chose to analyze the cases using the other dates to examine whether 

and how schedule delays might affect the Commission's 

conclusions. 

A. The No-MRS Alternatives 

In the No-MRS alternatives analyzed by the Commission, all fuel would be stored at the reactor sites until DOE 

was ready to accept the waste and ship it to the repository 

for disposal. The analysis assumed utilities would select 

from a number of currently available options to provide interim storage. These include: reracking, which increases 

pool storage capacity by refitting spent fuel pools with 

racks that hold more fuel assemblies; and dry storage, 

which stores spent fuel in metal or concrete casks, or in 

concrete bunkers. The analysis also considered whether additional options, such as dual-purpose casks (single casks 

that can be used for both storage and transportation), rod 

consolidation (decreasing pool storage requirements by taking apart intact spent fuel assemblies and combining them 

to reduce their volume), and transshipment (shipping fuel 

from one reactor site to another), would be available and, if 

so, how their use would affect the choice between the 

No-MRS and MRS options. 

17 
18 
B. The MRS Alternatives 

In the MRS alternatives analyzed by the Commission, 

spent fuel would be stored at the reactors until an MRS became available. Some spent fuel from some reactors would 

be transported and stored at an MRS until a repository were 

available for permanent disposal. The MRS would continue 

to operate until all the spent fuel had been emplaced in the 

repository. 

The MRS facility was analyzed with the schedule and 

capacity linkages defined in the Nuclear Waste Policy 

Amendments Act of 1987, 2with alternative linkages, and 

without linkages. With the MRS capacity limited under current law to 15,000 metric tons uranium (MTU), most spent 

fuel would be stored at the reactor sites at any given time. 

The MRS, then, would supplement at-reactor storage. 

Under the current statutory schedule linkages, construction of the MRS cannot begin until the NRC has issued a license for the construction of the repository, and 

construction of the MRS is "prohibited during such time as 

the repository license is revoked by the Commission 

[NRC] or construction of the repository ceases." 3DOE estimates that it will take at least 30 months to build a storage-only MRS4and at least five years to construct a 

repository.5If repository construction authorization were 

received in 1998, for example, DOE believes that, with the 

current linkages, an MRS could begin accepting waste in 

the year 2000, and a repository could begin operation in 

2003.6Therefore, a linked MRS would be available about 

three years before the repository, assuming construction 

proceeds according to the projected schedules. 

Section Two: The Models 

Most experts who expressed opinions to the Commission seemed to agree that the effects on public health and 

safety would be small and within regulatory limits regardless of whether an MRS were included in the waste management system. However, members of the public expressed concerns about the safety of various storage alternatives and greater concerns about the safety of transporting spent fuel. The Commission decided it needed to 

develop its own estimates of the costs and effects of the 

various spent fuel management alternatives as well as a 

method for comparing its estimates to those of DOE and 

Tennessee. 

To compare system-wide estimates of risks and costs, 

the Commission developed computer models that describe 

the flow of spent fuel through the spent fuel management 

system. These models are described briefly below; Appendix G gives a more detailed description. 

A. The System Model: MARC 

The model used to evaluate the risks of different system configurations was MARC: MRS Review Commission's Analysis of System Risk and Cost. It is a network 

model adapted from a DOE model.? (See Figure 3.2.) 

The DOE model from which MARC was adapted 

(TRICAM) calculated only transportation costs and risks. 

TRICAM was used by DOE only in the simulation mode, 

with "oldest fuel first" (OFF) always specified as the pickup rule to be followed. However, because the Commission's systems analysis encompasses more than transportation, the model had to be modified to calculate the risks of 

storage and of performing other functions, such as handling 

spent fuel, at the various facilities within the waste management system. The model also includes estimates of the 

costs of the various waste management functions, many of 

which were adapted from the cost accounts developed in 

the economic cost model described below. 

MARC shows how the spent fuel would be handled 

and transported through the waste management system 

from the time it is discharged from the reactors to the time 

it is placed in a repository. MARC calculates the costs and 

risks for each step in the flow. MARC is designed to operate in the "optimization mode," to figure out which combination of transporting and storing the spent fuel will incur 

the least cost or least risk. The resulting "pick-up rule" reflects the least cost or risk sequence and modes by which 

spent fuel is to be picked up from the reactors by DOE and 

shipped to an MRS or repository. 

MARC can be programmed to optimize either cost or 

radiological risk or some combination thereof. Most of the 

cases were run in the cost optimization mode (to minimize 

costs) because this mode was likely to produce higher (or 

more "conservative") estimates of system risks. Some 

cases were run in the risk optimization mode (to minimize 

risks). The differences in radiological risk from the risk optimization and the cost optimization runs were small and 

these differences will be discussed in Chapter Four. 

Although MARC was designed to be run in the optimization mode, it can be run in the simulation mode, in 

which a pick-up rule (such as oldest fuel first) is specified 

in advance and the model simulates the combination of 

19 
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FOr-certaiROO(poses'the computer Canbe told to'''simulate`;ratharjthan:',!optiMize:': That is it:can be, old to 

f011owaparticulat(Ule, ;cir fhat a partiCular:: package islOpicked I,Jpstir§f°,.:6Yen if doing costs the' . COmpatici 

:more. tnoney.' It then:ModelS4hebeSt:pOssibler§dhedUleS: an&Cattiers,'gkVen:thaf,COriditioh:: 

ObviouslY:, „some ludgMents'haVe been , thade in the basic assumptions; asffie van's size. It 

,„ 

this "" 

,might be Udeful:fo(the,CompahY:to: see What:eft:6a changing this one a ssumptio n , have; Orimeelihglhe 

,:sChedUle;40 On COSt§.The ‘comp:uters'il$0 -:,could, Citrielpiiyitti a SaMple'caSend arialYZeit tiSing the usual as-

, .1f-nptiiii-is‘;11-teri: :the user Pould4hanbe:the' n,van:§iie and:Sed howthat thangeSAhe dbets.:This , IS called 

'sensitlyity:atia y >., 

storing, handling, and transporting spent fuel that would result; it also estimates the system-wide costs and risks of 

this particular combination. However, MARC is very difficult to use in the simulation mode, because the user must 

describe the pick-up rule in advance, which requires a detailed schedule of the annual acceptance of spent fuel on a 

reactor-by-reactor basis. MARC was run in the simulation 

mode and the results were similar to those of DOE's TRICAM simulation. However, because of the difficulties in 

pre-specifying a pick-up rule, the Commission did not rely 

on MARC simulation runs to perform its analysis of the 

MRS and No-MRS alternatives. 

MARC receives information from several data bases, 

using them to describe how spent fuel would move through 

the system and to calculate risks and costs. The principal 

data bases provide facility-specific data, such as reactor 

spent fuel discharge projections, reactor rail accessibility, 

and repository capacity and acceptance schedules. Other 

data bases provide network data, such as routes, population 

density along the routes, unit risk data, and unit cost data. 

Unit cost data used in MARC come from the cost model 

data base described below. The transportation radiological 

unit risk factors used in MARC are from a modified version of RADTRAN III supplied by DOE. The radiological 

unit risk factors for activities at fixed facilities are taken 

from Commission-sponsored assessments. 8Appendix G 

and the MARC user manual describe the model and the associated data bases. 9 

B. The Cost Model: WACUM 

The Nuclear WAste Cost Data Base and SimUlation 

Model (WACUM) is a simulation model, with an accompanying data base, for computing costs.m The model estimates costs for the two basic alternatives and variations on 

them. WACUM was designed to analyze the uncertainties 

associated with the costs of the various elements of the 

spent fuel management system, including constructing and 

operating an MRS, and to provide cost estimates to be used 

in MARC. 

The basic cost data used in the model are subject to a 

wide range of uncertainty. In many cases, the estimates involve predicting the costs of yet-to-be developed equipment and facilities over a 40- or 50-year time period, with a 

still-evolving regulatory regime, and uncertain institutional 

framework. 

The accompanying data base" has two parts: a historical data base, which summarizes the past cost estimates, 

20 

2 0 
and a probabilistic data base, which was used in the calculation. The probabilistic data base was derived by a panel 

of experts who reviewed the historical data base to estimate 

future costs in a subjective but structured manner. WACUM is explained more fully in Chapter Six, where its results are discussed, and in Appendix G. 

C. Uses of Models 

The models are used to enable comparisons among the 

alternatives, so the Commission can make more informed 

recommendations. Models are tools to assist judgments, 

and their usefulness depends on some degree of skepticism 

about the certainty of data and assumptions. 

There are uncertainties associated with radiological 

risk predictions, especially for the low exposure levels associated with projected spent fuel management operations, 

and potential accidents associated with these operations. 

Health effects (primarily risk of cancer) from exposures to 

low radiation doses would not be expected to appear for 20 

to 30 years, and are predicted using conservative estimates 

based on observed health effects resulting from exposures 

to much higher radiation doses at much higher rates. Using 

a computer model does not reduce these uncertainties since 

the uncertainty in computer output can be no less than that 

in the input data and assumptions. 

However, using a computer which systematically 

models the flow of materials through the spent fuel management system, and the activities associated with this 

flow, provides a means for conducting a systematic and 

consistent comparison of risks among spent fuel management alternatives. Therefore, although the absolute levels 

of radiation doses for a given case cannot be determined 

accurately, the Commission was able to detect trends and 

to rank order alternatives in the instances when the trends 

were considered significant. 

Because of the difficulty of using MARC in the simulation mode, and because the model was not available 

until much later than the WACUM model which was developed specifically to do cost assessments, the Commission 

used WACUM for all cost assessments. MARC produces 

both cost and risk estimates but was used in the study only 

to assess and compare risks. In the MARC and WACUM 

runs the cost relationships among the cases analyzed are 

the same. The Commission also decided to run sensitivity 

analyses to test the effects that changing certain assumptions would have on the results. These sensitivity analyses 

are described in Section Four. 

Section Three: Assumptions of MRS and No-MRS Strategies 

To further define the base cases to be analyzed by 

MARC, the Commission made certain assumptions about 

the spent fuel management system. (See Figure 3.3.) Where 

possible, the same assumptions were made about both the 

MRS and No-MRS alternatives to facilitate comparing 

costs and benefits. The assumptions described below were 

made for the base cases. 

A. Maximum Exposures 

Assumptions: During each function performed to handle and transport spent fuel, workers and members of the 

general public are expected to receive as much as, but not 

more than, the maximum radiological doses specified in 

NRC and EPA regulations. 

The principal safety and environmental regulations applicable to the waste management system are those of the 

Nuclear Regulatory Commission and the Environmental 

Protection Agency. 12The models assume these regulations 

will be strictly enforced and, therefore, that the maximum 

expected radiation doses for normal and accident conditions should be within these regulatory limits. In practice, 

the expected doses should be less than the regulatory limits 

because facilities and equipment are designed to ensure a 

margin of safety in the design, and doses are required to be 

kept "as low as reasonably achievable" (ALARA). 13 

B. Spent Fuel Generation 

Assumptions: There will be no new orders for nuclear 

power plants; base cases include only spent fuel from 

plants operating or being constructed as of December 

1987; no substantial change will occur in burnup rates, 

post-1988 projected burnup rates of 36,600 megawatt-days 

per metric ton uranium (MWdIMTU) for boiling water reactors (BWRs), and 42,000 MWdIMTU for pressurized water reactors (PWRs);" and each plant will have a 40-year 

operating life. 

DOE's 1986 spent fuel storage projections were based 

on an optimistic high-generation projection of nuclear power growth in the United States instead of the no new orders 

cases. The National Association of Regulatory Utility 

Commissioners (NARUC), the State of Tennessee, and the 

21 
• ,,,,,, • • • • • 

Fi ure1.3—No-MRSandMRS ,ModelingAssumptions. 

, , 

Maximum:radiation:dOses are=to be Within "regUlatbrYilimitS 

• per t ft:JOIdOnpr?On::00E]t987°':No:Ne ,k01'0616iOle°00. 6 

fridre,trair=efaki000 the :feasible: 

•, :Full:core' reserve always maintained :•;.' ' 

o+ariSShiPrnent assumed; ; 

• Out-of-pool additional 5torage:proyided by existing:dry*Or ,,,, geit ................... 

NO at-reaCtdr .,rOddOnScilidatibri ,° 

„ °Any MRS will be storage=only MRS 

€•r a 

Any:MRS Will use dry storage:: • 

..,Any,MRS will be located in The Eastern UnitedStates: e • ,,,,,,,, 

:41.:RiSlcb%Of perforfrning‘a.funttiOn'.Suth as Stbrage:rbd:COnSOlidatioWor encapsulation ara:tha ,:sarne!whether3ha:, 

;;=iuriCtidniSzberfOrriled at an MRS or the repository=

•• • • < • 4 • x b Y • 

All spent fuel generated wirl be. di5"pose'd of in a Single:rebbSitoriy lOOated at:YUCca,Mbuntain; Nevada,:, 

• Repository will have a minimum operating life ,of, 25 years arida.MaXiMUM':of 45 oars; 

. 

• ransportatiomodes: only rail andhighwaT. % • n , 

Frbril-ieactbr rail/highWaY:mcide per-DOE trar*iciftation'sleM.tOtly.,(brily°,541%•%Of: reactors, hayef.spfl 

pccep.$) 

ePartMerif Of Energy SPent Fuel Storage 9eouirorhootp'.19,88,:'! DOE/RILL8S-34,:OctOber71 988.. 

General Accounting Office (GAO) challenged these 

projections. 

DOE's most recent projections, however, are based on 

no new orders for nuclear power plants, and are used in this 

study (1987 No New Orders Case.) The estimates are generally consistent with the NARUC and Tennessee projections, and they respond to GAO's objections. 

C. Storage and Other Functions at Reactors 

1. Reracking 

Assumption: Every nuclear utility will rerack its spent 

fuel pools (single-tier reracking only) to the maximum extent practicable before it uses other options such as rod 

consolidation or dry storage. 

Reracking means refitting pools with racks that hold 

more fuel assemblies than the initially installed racks. Reracking has been the utilities' preferred method of increasing at-reactor spent fuel storage, in part because it is the 

most economical way to increase storage space. The added 

racks handle heavier loads and store fuel assemblies in less 

space. Most utilities have reracked their pools at least once. 

While some reactors may have to use other measures to acquire additional storage capacity, about 75 percent of the 

reactors can provide sufficient storage using reracking until 

beyond the year 2000. 15 

According to recent NRC figures, there have been 130 

rerackings. 16From the original typical design of 1-1/3 reactor cores, utilities have increased storage to four to six 

reactor cores, in some cases even more. Future reracking 

will be limited; adding a second tier of racks is not consid22 

7 C) 2 ) 0 
ered a practical way to expand spent fuel storage 

capacity. 17 

2. Full-Core Reserve 

Assumption: Every utility will maintain enough pool 

storage capacity so that it can unload the full core of the 

reactor into the spent fuel pool, if necessary. This is commonly referred to as full-core reserve. 

Although full-core reserve is not an NRC requirement 

most utilities view maintaining full-core reserve as essential for orderly nuclear power plant operation. 

3. Transshipment 

Assumption: There will be no transshipment of spent 

fuel between reactor sites. 

Transshipment means shipping spent fuel from one 

reactor to another to alleviate storage problems. Carolina 

Power and Light Company and Duke Power Company 

have transshipped spent fuel within their individual utility 

systems. However, widespread intrautility shipments have 

not occurred, and there have been no interutility transshipments. Variations on this basic assumption were analyzed, 

assuming some intrautility transshipment (See Chapter Five 

for details.) 

4. Dry Storage 

Assumption: Reactors unable to expand their spent 

fuel pool capacity will use dry storage if additional on-site 

storage is needed. 

Dry storage means storing spent fuel at reactor sites in 

metal casks, concrete casks, 18or concrete bunkers. 19(See 

Figures 3.4 and 3.5.) 

A typical metal dry storage cask is made of steel or 

nodular cast iron. Virginia Power Company's Surry Nuclear Power Station uses a metal cask dry storage system. 

In bunker systems, the fuel is stored in stainless steel canisters contained in individual concrete modules. The Carolina Power and Light Company's Robinson Nuclear Project 

uses a small bunker system, which holds seven pressurized 

water reactor (PWR) assemblies per module. Duke Power 

Company has applied for a license for a larger bunker system, holding 24 PWR assemblies per module, at the 

Oconee plant. 

Most utilities will probably be able to store enough 

spent fuel in dry storage on-site to obtain life-of-plant storage capacity, either at the reactor sites or on utility-owned 

land contiguous to the reactor. It has been estimated that 

fuel could be stored safely in dry storage for up to 100 

years. 2° 

5. Rod Consolidation 

Assumption: No spent fuel will be consolidated at 

reactors. 

Four utilities have participated in rod consolidation 

demonstrations. Because the technology has not yet been 

shown to be technically and economically advantageous, 

no utility has chosen to rely on rod consolidation to expand 

on-site storage capacity. Therefore, for the two alternatives 

being considered, the analysis assumes no spent fuel will 

be consolidated at reactors. Sensitivity analyses were run, 

however, assuming some rod consolidation at reactors because the technology may mature to the point where it 

would be a useful alternative storage option. (See also, 

MRS Assumptions, below.) 

D. MRS Assumptions 

1. Functions 

Assumption: Any MRS will only provide spent fuel 

storage and will not perform other functions, such as rod 

consolidation or waste packaging. 

The Commission focused its analysis on the storageonly MRS because of DOE's current position that an MRS 

will be a storage-only facility at first, with the option of 

adding other functions later. 21DOE now finds that savings 

attributable to consolidation are not substantial enough to 

make consolidation worthwhile. 22However, as the systemwide parameters are further defined, the cost of the waste 

package container may become high enough for rod consolidation to be reconsidered. Therefore, the Commission 

considered how adding other functions later, such as rod 

consolidation, would affect the choice between the NoMRS and MRS options. 

2. Storage Technology 

Assumption: Any MRS facility will use dry storage 

rather than pool storage. 

Dry storage is DOE's technology of choice for the 

MRS. DOE prefers dry storage to wet storage because dry 

storage is a passive technology, requiring less monitoring 

and control than wet storage does. In addition, dry storage 

is partially modular, requiring a smaller initial investment 

to build. 

3. Risks 

Assumption: Risks of performing a function such as 

storage, rod consolidation, or encapsulation are the same 

whether the function is performed at an MRS or a 

repository. 

The equipment, facility design, and operation for these 

functions is expected to be the same regardless of where 

the function is carried out. 

23 
Figure 3.4—An Example of a Dry Storage Cask 

SEAL COVER 

NEUTRON SHIELD 

PRIMARY COVER 

SHIELD COVER 

TRUNNIONS 

REMOVABLE FUEL 

STORAGE CELL 

VESSEL WALL 

(GAMMA SHIELD) 

NEUTRON SHIELD 

BASKET ASSEMBLY 

COOLING FINS 

STAINLESS STEEL 

OUTER SHELL 

SOURCE: ELECTRIC POWER RESEARCH INSTITUTE 
Figure 3.5—Generic Horizontal Modular Storage System (NUHOMS) 

DRY STORAGE CANISTER FUEL TUBES 

011010011101-0110111111111111

.1.11 Es. 

EXHAUST AIR VENTS 

n= k

7e,3 

Et2112E 

cen c•f!!';'- 111611"-." "1-; 

1 • II

i

170.1.11. lig ■ • 

TRANSFER CASK 

HYDRAULIC 

RAM 

DOOR 

CONCRETE PAD 

HORIZONTAL STORAGE MODULES 

TRAILER 

INLET AIR VENTS 

SOURCE: DEPARTMENT OF ENERGY 

4. Location 

Assumption: Any MRS will he located in the Eastern 

United States. 

For its transportation and cost analyses, this study postulates hypothetical locations for an MRS. See Appendix G 

for an explanation. 

E. Repository Schedule and Location 

Assumptions: All of the spent fuel generated will he 

disposed of in a single repository located at Yucca Mountain, Nevada. The repository will have a minimum operating life, for accepting and emplacing spent fuel. of 25 years 

and a maximum operating life of 45 years. 

The Commission had to postulate a repository location 

to analyze the effect of an MRS on the waste management 

system, and at the moment, site characterization efforts are 

focused on Yucca Mountain. It may be many years before 

the suitability of the Yucca Mountain site is determined. If 

it is found to be unacceptable, the issue of how best to 

manage the Nation's radioactive waste will be reexamined. 

Although the location of the repository was not varied in 

the base cases, several variations were analyzed assuming 

delayed repository start-up to determine the effects of such 

delays on the need for an MRS. 

Under current law, the capacity of the first repository 

is limited to 70,000 MTU until a second repository is in operation. 23 However, to obtain a realistic estimate of lifecycle risks, costs, and benefits associated with spent fuel 

management. it was necessary to model a system which 

handles all of the commercial spent fuel expected to be 

generated, about 87,000 MTU. Introducing a second repository in the system would have significantly increased 

model complexity and uncertainty because the model 

would have had to assume some location and schedule for 

the second repository. both very uncertain. To reduce the 

complexity to a manageable level. it was assumed that all 

of the spent fuel would go to the first repository. The Commission believes that the potential error introduced by making this assumption is less than could have been introduced 

if a second repository site had been postulated. 

25 

7 0 2 3 0 2 0 7 0 
F. Transportation Modes 

Assumptions: Only railroads and highways are used 

to transport spent fuel. The base cases assume that only 54 

percent of the reactors have rail access. 

This division into percentages is called a modal split; 

truck transport and rail transport are called modes. 24DOE 

assumed this 54 percent/46 percent modal split in its MRS 

system study. 25Barge transport was not considered because 

it was not seen as having a significant effect on the MRS/ 

No-MRS decision. For trips to Yucca Mountain, whether 

from reactors or from a candidate MRS, barge transport 

could be, at most, only one segment of an intermodal shipment. It has been suggested that barges may be feeders to 

a railhead from those reactors with waterway access but 

without rail access. The model has been run using 100 percent rail transport in some cases to simulate the economic 

advantages of providing barge-supplemented rail access in 

this manner. 

Section Four: Sensitivity Analyses 

To see how changes in some assumptions would affect 

the analyses, the Commission conducted "sensitivity analyses." That is, after analyzing the base cases defined with 

the primary set of assumptions, the same cases were analyzed with one assumption changed at a time to see how 

great a difference, if any, that would make. For example, in 

the base case, the Commission assumed that only 54 percent of the reactors have access to rail transport. To see 

what difference it would make if more reactors could gain 

rail access, an idealized case was analyzed in which all reactors were assumed to have rail access. Such changes are 

called variations on the assumptions. (A list of the variations considered by the Commission is contained in Appendix H.) Variations were chosen that were realistic or else 

bounded the effects of the change. For example, there cannot be any transportation efficiency greater than 100 percent rail. Chapters Four through Six describe the results of 

these analyses. 

26 

fW 
Chapter Three Notes 

1.Isaacs, Thomas H., Associate Director, External Relations 

and Policy, Office of Civilian Radioactive Waste Management, 

Department of Energy, "DOE Position on the Monitored Retrievable Storage (MRS) Facility," Prepared Remarks before the Monitored Retrievable Storage Review Commission, May 25, 1989 

(Hereafter cited as Isaacs, Prepared Remarks), p. 4; "MRS 

System Study Summary Report," DOE/RW-0235, June 1989, 

(Hereafter cited as Task J), p. 69. 

2. 42 U.S.C. § 10168(d). 

3. 42 U.S.C. § 10168(d). 

4. Task J, pp. 13-16. 

5. Department of Energy, "Draft 1988 Mission Plan Amendment," DOE/RW-0187, June 1988, pp. 21, 50-52. 

6. Isaacs, Prepared Remarks, May 25, 1989, p. 4. 

7. TRICAM: Transportation RIsk and Cost Analysis Model. 

See, Office of Transportation Systems and Planning, Battelle Nuclear Systems Group, "MRS Systems Study, Task F: Transportation Impacts of a Monitored Retrievable Storage Facility," BMI/ 

OTSP- 07, May 1989 (Hereafter cited as Task F), pp. 14-15, 

and 18. 

8. Letter Report from ICF Technology Inc., September 14, 

1989, by Steve Baker, 601 Williams Boulevard, Fourth Floor, 

Richland, Washington 99352-3258; Golder Associates, Inc., "Final Report of Safety and Environmental Impacts for Alternative 

Spent Fuel Management Options," July 1989. 

Radiological unit risk factors are usually expressed as person-rem/shipment-kilometer for transportation and person-rem/ 

MTU of fuel handled or person-rem/activity for activities at fixed 

facilities. 

9. ICF Technology, Inc., "MARC User Manual and Model 

Documentation," July 1989. 

10.Golder Associates, Inc., "WACUM: Nuclear Waste Cost 

Database And Simulation Model User's Guide Version 1.13: 

Report to the Monitored Retrievable Storage Review Commission," 893-1032.210, June 20, 1989. 

11.Golder Associates, Inc., "Interim Spent Fuel Management Cost Data Base: Report to the Monitored Retrievable Storage Review Commission," 893-1032.120, June 1989. 

12. Radiation Safety and Environmental Regulations 

EPA 

• 40 CFR Part 190, Environmental Radiation Protection 

Standards for Nuclear Power Operations (the language of 

Part 190 is incorporated into 10 CFR Part 72) 

• 40 CFR Part 191, Environmental Standards for Management and Disposal of Spent Nuclear Fuel, High-Level and 

Transuranic Radioactive Wastes 

• 40 CFR Part 141, National Interim Primary Drinking Water Regulations (40 CFR 141.15 and 141.16 specify radioactivity standards) 

NRC 

• 10 CFR Part 20, Standards for Protection Against 

Radiation 

• 10 CFR Part 50, Domestic Licensing of Production and 

Utilization Facilities 

• 10 CFR Part 51, Environmental Protection Regulations for 

Domestic Licensing and Related Regulatory Functions 

• 10 CFR Part 71, Packaging and Transportation of Radioactive Material 

• 10 CFR Part 72, Licensing Requirements for the Storage 

of Spent Fuel in an Independent Spent Fuel Storage Installation (ISFSI) 

• 10 CFR Part 73, Physical Protection of Plants and 

Materials 

• 10 CFR Part 74, Material Control and Accounting Of 

Special Nuclear Material 

A more complete list of potentially applicable regulations and 

guidance is shown in the Department of Energy, "Monitored 

Retrievable Storage Submission to Congress," DOE/RW-0035/1, 

Vol. II, February 1986, Appendix I. 

13. 10 CFR 20.1(c). 

14. "Burnup" is a measure of consumption of fissile content 

of reactor fuel, expressed as either the percentage of fuel atoms 

that have undergone fission, or the amount of energy released per 

unit mass of nuclear fuel in the reactor. Units normally used for 

the latter are megawatt-days per ton of uranium or heavy metal. 

The terms "metric tons of uranium" (MTU), "metric tons of 

heavy metal" (MTHM) and "metric tons of initial heavy metal" 

(MTIHM) are all used in the literature. In its spent fuel projections, DOE expresses burnup in terms of megawatt days per 

metric ton of initial heavy metal (MWd/MTIHM). Although these 

terms are not precisely equivalent, the error introduced by using 

these terms interchangeably is between 2-3 percent and well within the uncertainties associated with estimating costs and risks associated with management of spent fuel. (See, for example, 

Department of Energy, Energy Information Administration, 

"World Nuclear Fuel Cycle Requirements 1988," DOE/EIA -

0436(88), 1988, Table B4, p. 63.) Therefore, to make the report 

more readable, burnup is expressed in terms of megawatt-days per 

metric ton of heavy metal. 

15.Ebasco, "Spent Fuel Storage Need and At-Reactor Capability Study," June 1989 (Hereafter cited as Ebasco, Need 

Study), Table 3-3. 

16.Ebasco, Need Study, p. 3-1. 

17.Ebasco, Need Study, p. 3-5. 

18.Two types of concrete casks have been designed. Both 

are made of heavily reinforced concrete with an inner metal liner. 

The unventilated type will hold 9 PWR or 25 BWR fuel elements, 

and weigh about 90 tons when loaded. The ventilated type will 

hold 17 PWR or 50 BWR elements, and weigh about 125 tons 

when loaded. The NRC is evaluating a Topical Report for a ventilated cask but has not yet made a decision on certification. 

19.Department of Energy, "Final Version Dry Cask Storage 

Study," February 1989, Chapter 4. 

20. On August 31, 1984, the NRC issued a final decision on 

what has come to be known as its "Waste Confidence Proceeding." In that proceeding, the Commission's Fourth Finding was 

that the Commission had "reasonable assurance that, if necessary, 

spent fuel generated in any reactor can be stored safely and without significant environmental impacts for at least 30 years beyond 

the expiration of that reactor's operating license at that reactor's 

spent fuel storage basin, or at either on-site or off-site independent 

spent fuel storage installations." 49 FR 34658. 

In its recently published proposed Waste Confidence Decision Review, 54 FR 39767 (September 28, 1989), the Commission 

proposed that this finding be revised to read: "The Commission 

finds reasonable assurance that, if necessary, spent fuel generated 

27 

;;) 
in any reactor can be stored safely and without significant environmental impacts for at least 30 years beyond the licensed life for 

operation (which may include the term of a revised license) of that 

reactor at its spent fuel storage basin, or at either on-site or offsite independent spent fuel storage installations." [Revised portion in italics] 

In discussing the basis for revising this finding the NRC stated, "In making the original Fourth Finding, the Commission did 

not determine that for technical or regulatory reasons, storage 

would have to be limited to 70 years. This is apparent from the 

Commission's use of the words . . for at least 30 years beyond 

the expiration of that reactor's operating license . . .' [emphasis 

added]. Similarly, in using the words 'at least' in its proposed revised Finding Four, the Commission is not suggesting 30 years 

beyond the licensed life for operation (which may include the 

term of a revised license) represents any technical limitation for 

safe and environmentally benign storage. Degradation rates of 

spent fuel in storage, for example, are slow enough that it is hard 

to distinguish by degradation alone between spent fuel in storage 

for less than a decade and spent fuel stored for several decades 

. . . The Commission does not see any significant safety or environmental problems associated with storage for at least 30 years 

after the licensed life for operation of any reactor, even if this 

effectively means storage for at least 100 years, in the case of a 

reactor with a 70-year license for operation...Thus, supported by 

the consistency of NRC experience with that of others, the Commission has concluded that spent fuel can be stored safely and 

without significant environmental impact, in either wet storage or 

in wet storage followed by dry storage, for at least 100 years." 

Although this is a proposed finding at this time, it is the latest 

statement resulting from a detailed technical review of this issue. 

21. Isaacs, Prepared Remarks, May 25, 1989, pp. 1, and 5-6. 

22. Isaacs, Prepared Remarks, May 25, 1989, pp. 6-7; Task 

J, pp. 38-39, 70. 

23. 42 U.S.C. § 10134(d). The 70,000 MTU in the statute can 

include both spent fuel and defense HLW. The DOE studies contemplate that the first repository will hold approximately 63,000 

MTU of commercial spent fuel and approximately 7,000 MTU of 

defense waste. 

24. Mode split usually refers to tonnage actually carried by 

truck or rail rather than sites served, as it is used here. 

25. Task F, p. 15. 

28 

7 0 2 2 0 7 
Chapter Four 

Health, Safety, and 

Environmental Effects 

Public health and safety, and environmental protection 

are serious concerns of the American people and were of 

highest priority to the MRS Review Commission during its 

study. This chapter compares the health, safety, and environmental effects of two alternative approaches to spent 

fuel management: having and not having an MRS facility. 

Section One covers radiological and non-radiological effects on health and safety. Section Two discusses special 

issues pertaining to health and safety that were raised during this study. Section Three considers potential environmental and socioeconomic effects. Section Four sets forth 

the Commission's findings regarding these effects. This 

chapter also summarizes the estimated radiological risks of 

transporting spent fuel, but Chapter Five covers transportation safety more fully. 

Section One: General Effects on Health and Safety 

A. Radiological Effects 

Radiation doses to workers and the public can result 

from spent fuel management operations at the reactor, the 

repository, or the MRS, and from transporting spent fuel 

from one facility to another. 

Radiation exposure for each of the base cases (NoMRS, linked MRS, and unlinked MRS) was estimated for 

each of three different repository start dates (2003, 2013, 

and 2023). Tables 4.1 and 4.2 summarize the results. Dose 

estimates are reported in terms of cumulative doses to 

workers and the public expected over the entire 40-year life 

of the spent fuel management program, from the time the 

fuel is removed from the reactor core until all the spent fuel 

has been buried in a geologic repository. These doses are 

referred to as "life-cycle" doses and are expressed in 

person-rem.' 

1. General Findings About Dose Magnitude 

The study found radiation dose estimates for the workers and the public to be very low for all of the cases and all 

of the repository start dates examined. (See Table 4.3.) 

In terms of latent cancer fatalities, calculations of occupational fatalities range from 6.8 to 10.4, a difference of 

3.6 fatalities, and predictions of public fatalities range from 

1.4 to 3.2, a difference of 1.8 fatalities. Cancer fatality calculations assume that each 10,000 person-rem will produce 

four cancer fatalities. 2These estimates are for the entire 

United States over the spent fuel management program's 

40-year life cycle. These differences amount to about one 

calculated occupational cancer fatality every 11 years and 

one calculated public cancer fatality every 22 years, assuming a 40-year life for the spent fuel management program. 

The total life-cycle public dose from the entire spent 

fuel management system for either the MRS or No-MRS 

alternatives would produce a calculated risk of about 0.04 

to 0.08 cancer deaths per year, assuming a 40-year life for 

the system. This is illustrated in Figure 4.1. 

The population within 50 miles of an MRS would receive about 0.1 person-rem per year 3from the operations at 

the MRS. This would produce about 0.00004 calculated 

cancer deaths per year. 

For comparison, the background radiation dose to the 

estimated population within 50 miles of an MRS would be 

about 300,000 person-rem per year. Background radiation 

doses to the population within 50 miles of an MRS are calculated to produce about 120 cancer deaths per year. Exposures to medical x-rays for the same population would 

result in doses of about 39,000 person-rem and are calculated to produce about 15 cancer deaths per year. 4 

2. Public Dose 

"Public dose" is defined as the total dose to members 

of the public (as opposed to workers) during all activities 

29 
Table 4.2=Total'SPent:Fuelikanagement:Life.:Cycle accuPational Public Poses 

e!' 0r,10 kr)" 

:Case 

,, 

WC-MRS!: 

Liirikesrty1FI6 NWPAA) 4 

15S. 

.4ARg P60. 6Saa:daOtiii1g: s"pe* h ttfuerthree,years:PelOre* ie*OOs' itOry start: daa. – _ 

. 

rap,OS.,)tOry.%areOlate; °•„tha linkechand; .; LI: :Plink! R: pa 

„ „ „

r sesa P bebaiise:fri. 

'Start" the year 2000: — 

Total Spent FUel.Mariagement, Life-cycle Public .DoseS. 

erson-rem) 

.2003 eP ° 2013" 20'23: 

8,100 8,100 8 100 

3,500? 3,6000 

,3,5006 = 3,500C ,o 

Table 4: 

Case 

NO-MR 

:a1V1FiSPegiris. a.c.oepplig :sp:antfdejthi'.6e .:yearsteforel.epository start:date. : 

?For a 2003:repository, start &46.; the linked.......... unlinked MRS pase:fithe...sar..nebecays0...i.11:00 t..P4§..Pg. t. e 

assumed; , „ .. , . , start ,. .„ , . . ... . . •,---- MRS i . asomed, to Atart ip;the year 200a ,.:. . ,..., „ „. , „ . . , . 

.- 'F;pie]noobor§:ateAtio,.sairrigAecauSe:of roundip9:off. 

.„ . ••::.i..,„.....‘ . . . ,,,,,,,,, . , • - - 

^ ,• ,,,,,,,,, 

associated with storing, handling, transporting, or disposing 

of spent fuel. Most of the dose to the public occurs during 

transport; the transportation dose accounts for over 95 percent of the total public dose in both MRS and No-MRS 

systems. (See Table 4.4.) It should be noted that in-transit 

doses to truck drivers and train crews are included in the 

public dose estimates from transportation; excluding these 

doses from the estimates would reduce public doses by as 

much as 75 percent. 5 . 

Without an MRS, public doses would be essentially 

the same regardless of the repository start date. (See Table 

4.1.) Having an MRS in the system would reduce these 

doses by about 60 percent. This reduction would occur because all transportation from the MRS to the repository 

would be by train, thereby reducing the transportation dose. 

3. Occupational Dose 

"Occupational dose" is defined as the total dose to 

workers during all activities associated with the storing, 

30 

7 0 2 2 o 7 5 
OCCUPATIONAL EXPOSURE PUBLIC EXPOSURE 

Linked MRS (NWF'AA)a... 

:Unlinked MRSb ' 

able 4.3—Comparison of Total Life-cycle Radiological Effects of MRS and NoMRS Systems (2013 Repository Start Date) 

10.4 8100' 3.2 

6.9 3500 1,4 

6.8 3500 1.4 

aLinked MRS:to begin operations in 2010. 

.bUnlinked MRS:tobegin operations in 2000. 

Person-Rem 

Calculated 

Cancer 

Fatalities 

Calculated 

Cancer 

Fatalities 

handling, transporting, and disposing of spent fuel. 

Occupational doses would increase as the repository 

start date was delayed. They would nearly double for the 

No-MRS and linked MRS cases if the repository start date 

was delayed from 2003 to 2023, but not for an unlinked 

MRS. (See Table 4.2.) The increase would be due primarily 

to doses from at-reactor spent fuel management activities. 

For an unlinked MRS, the increase due to the delayed repository would be only about 20 percent because many activities, instead of being carried out at the reactors, would 

be performed at the MRS, where there would be a greater 

reliance on remote operations and remote handling 

facilities. 

4. DOE and Commission Estimates 

Table 4.4 compares the Commission's dose estimates 

for linked MRS and No-MRS systems with the U.S. Department of Energy (DOE) estimates. Although the Commission's dose estimates were based on methodology and 

assumptions different from DOE's, the differences between 

DOE and Commission results are quite small. 

Commission estimates for occupational doses are 

somewhat higher than DOE estimates because the Commission used more conservative assumptions about doses 

to workers. Commission estimates of transportation doses 

to the public are higher than DOE estimates because: (1) 

the DOE estimates include loading and handling doses associated with transportation in the occupational doses for 

the facility where they are carried out rather than reporting 

them separately as the Commission did, and (2) DOE used 

unit risk factors developed by Argonne National Laboratory (ANL) for determining public dose from transportation, while the Commission used the modified Radtran III 

unit risk factors. 6The ANL model produces reduced doses 

for truck shipments but much higher doses for rail shipments. (See Chapter Five for a discussion of the differences.) The Commission estimates that adding a Nuclear 

Waste Policy Amendments Act (NWPAA) linked MRS to 

the system would decrease the public dose by 4,600 person-rem (1.8 calculated cancer fatalities) and the occupational dose by 3,800 person-rem (1.5 calculated cancer 

fatalities). DOE estimates that adding an MRS to the system would decrease the public dose by 1,500 person-rem 

(0.6 calculated cancer fatalities) but increase the occupational dose by 7,300 person-rem (2.9 calculated cancer fatalities). In either case, the differences between the MRS 

and No-MRS systems are relatively small even over the 40-

year period examined. 

5. Variations in Assumptions 

To determine the sensitivity of the dose estimates to 

changes in basic parameters and assumptions, the Commission performed sensitivity analyses for each of the three 

base cases (No-MRS, linked MRS, and unlinked MRS). 

The sensitivity analyses assumed the repository would start 

in 2013, but similar results would have been obtained if either of the other repository start dates had been used. The 

results of these sensitivity studies are shown in Table 4.5. 

(See Appendix H for a detailed list of the sensitivity analyses performed for this study.) 

The sensitivity analyses clearly demonstrate that both 

public and occupational dose estimates would remain low 

31 
100 .= 

10 

0. 01 

Medical 

X-Rays 

Background 

Radiation 

Spent 

Fuel Mgt. 

Figure 4.1—A Comparison of Calculated Cancer Fatalities From Natural 

Background Radiation, Medical X-rays, and Spent Fuel Management Activities 

Calculated Cancer Fatalities per year 

1000 

Doses from natural background radiation and medical x-rays are calculated using annual 

dose rates from NCRP Report No 93. "Ionizing Radiation Exposure of the Population of 

the United States.' September. 1987, and an assumed exposed population of one million 

persons within a 50-mile radius of the MRS. Doses from spent fuel management activities 

are based on calculations by the MRS Review Commission staff. Cancer fatalities are 

calculated using conversion factors of four cancer fatalities for each 10,000 person-rem. 

the conversion factor is based on factors used in the EPA Draft Environmental Impact 

Statement for the Proposed NESHAPS (National Emission Standards for Hazardous Air 

Pollutants) for Radionuclides, EPA 520/1-89-005, February 1989. Vol. 1. 

regardless of how the cases are modified. In fact, with few 

exceptions, the dose estimates in each sensitivity analysis 

are substantially the same as those in the base cases varied 

for the analysis. The one case worth noting is the use of 

100 percent rail transportation. estimated to reduce the public dose by nearly 90 percent. The reduction is due almost 

entirely to reduced transportation doses and is discussed in 

Chapter Five, It is interesting to note that using dual-purpose casks does not appear to reduce doses significantly 

(dual-purpose casks are discussed in Section Two, Part E of 

this chapter). and rod consolidation at the reactors appears 

to increase occupational doses somewhat but does not 

affect public doses. (See Section Two. Part C for a discussion of rod consolidation risks.) 

6. Findings 

The Commission finds that only small public or occupational radiological risks are likely to result from 

management of spent fuel regardless of whether the system has an MRS. 

Given the small absolute magnitude of the predicted risk and the uncertainty associated with the estimates of these risks, the Commission does not believe 

32 

7 0 2 .3 0 2 0 7 7 
Activity Center 

,Reactor 

Repository 

;Transportation 

Table 4.4—Total Life-cycle Doses in Person-rem 

for No-MRS and Linked MRS Systems 

NO-MRS LINKED MRS (NWPAA a 

, . Commission • 

• Estimatesb 

DOE 

Estimatesc 

Commission 

Estimatesb 

DOE 

Estimatesc 

130/13,500d <100/6,700 13013,000 <100/6,700 

4/300 <1/9,400 

<1/8,400 <1/5,200 <1/8,400' <1/3,100 

7,900/4,200 3,600/s 3,400/5,600 2,100/0 

Total 8,100/26,100 3,700/11,900 3,500/22,300 2,200/19,200 

..aMRS begins accepting spent fuel three years before repository start date. 

•bCommission estimates are based in each case on MARC analyses of systems with a 2013 repository start date. 

CDOE estimates for MRS and repository are taken from PNL-6857, "Preliminary Dose Comparisons for the MRS 

• Systems Study," April 1989. The No-MRS doses•are from system configuration 1 (No-MRS, No Consolidation). The 

: LAIRS doses are from system •configuration 4 (Storage-only MRS, No Consolidation): Transportation estimates are 

taken from BMI/OTSP-07 "MRS.Systems Study, Task F: Transportation Impacts of a.Monitored Retrievable Storage 

 Facility,'.' .May 1989, p. 25, Table 16. Since PNL-6857 provides no dose estimates for at-reactor activities, at-reactor 

doses were taken frort DepartMent of Energy, "Monitored Retrievable Storage Submission to Congress," DOE/ 

RW-0035/1-Rev. 1, Vol. II, February 1983, Table E-1, p. E-2. The repository in DOE's system handled only 63,000 MTU. 

.MARC systems handled 86,800 MTU. To provide a basis for comparison, the numbers ,in this table are extrapolated 

frbm.the actual DOE numbers. . 

dPublic dose/occupational dose. • - . , . 

.effi the DOE estimates, loading and handling doses associated with transportation are included in the facility 

e.g.,. MRS) occupational doses rather than reported separately as was done In the Commission estimates. 

these differences serve as a basis for discriminating 

among the alternatives. 

B. Non-radiological Risks 

1. Occupational 

Workers will be exposed to non-radiological hazards 

during the construction, operation, and decommissioning of 

the facilities which manage spent fuel. The sources of these 

hazards are routine occupational accidents. The magnitude 

of these hazards is estimated by multiplying the labor hours 

projected to construct, operate, and decommission the facilities by a reasonable hazard exposure rate. The planned labor effort for spent fuel management operations at reactors 

was estimated using information from contractors the Commission engaged.? 

Based on this analysis, the life-cycle non-radiological 

risk to workers is estimated to be about 40 fatalities and 

2,500 lost-time accidents regardless of what scenario is assumed or whether there is an MRS in the system. The nonradiological risk is summarized in Table 4.6. The risks are 

nearly identical for the No-MRS and the MRS systems. 

There are also non-radiological risks associated with 

the transportation of spent fuel; these are discussed in 

Chapter Five. 

2. Public 

With the exception of transportation risks, non-radiological risks to the public are minimal and were not considered in this analysis. 

3. Findings 

The Commission finds non-radiological occupational risk does not provide a basis for discriminating 

between MRS and No-MRS alternatives. 

33 

• to 
Sensitivity Analyses of Total Life-cycle Doses 

(2013 Repository Start Date) 

TOTAL SPENT FUEL MANAGEMENT LIFE-CYCLE 

° DOSES IN PERSON-REM 

Constrained 

MRSb 

Unconstrained 

MRSb 

3,500/22,300d 3,500/17,000 

3,400/18,400d 3,400/15,200 

3,500/21,000 3,500/16,400 

N.C.' N.C. 

N.C. 3,800/17,200 

N.C. 3,500/24,600 

3,500/19,100 

N.C. 3,500/17,000 

3,500/20,000 

N.C. 4,400/17,200 

N.C. N.C. 

N.C. N.C. 

N.C. N.C. 

No-MRS 

300/26,900 

8,100/22,100 

300/22,200 

8,100/26,100c 

8,065/19,600 

Alternatiye MRS Schedule' Lipkagee 

.MRS Located in Central U.S.: 

:Base Case 

;Base Case Optimized for Risk 

Casesa 

° 

' Intrautility TransbhipMent Allowed 7,500/26,200 

50% At-Reactor:ConolidatiOn: 8,000/32,900 

Consolidation at the MRS , „ ', ' , ',. , — . 

MRS Inventoli/ Limits: ' • ' , 

5;000 MTU . 

15,000 MTU 

: 30. ,000 MTU — 

„ 100% Rail Transportation, 

dal-purpose Casks 

-Dual-purpose Casks and + 100% Rail 

. • 

.aBase case assumptions are discussed in Chapter 3; Section 3. All other cases use base case assumptions 

:except as specifically•noted. — • 

• :bA:constrained MRS is an MRS whose schedule is linked to the repository schedule. Except where noted, the 

constrained MRS is linkedtathe repository in a way which allows the MRS to begin operation three years before 

Ithe. repository: An unconstrained MRS has no schedule constraints but may have capacity constraints. 

cPublic dose/occupation doSe: • 

•dMRS linked to rePositoiy in accordance with the 1987 NWPAA. 

,aMRS linked to repository. in away which .allows the MRS to begin operation five years before the repository. 

Not calculated • • • 

34 
Injuries • Deaths uries' 

800: 20 . 1:200 

700 

1,200 20 1 200 

2,700 40 2,400 

Table 4.6—Total Life-cycle Non-radiological Occupational Risk 

for MRS and No-MRS Systernsa 

MRS NO-MRS 

Activity Center 

Reactor 

MRS 

Repository 

TOTAL 

Deaths 

10 

10 

20 

The numbers would be approxiMately the same whether the MRS were linked or unlinked and regardless of 

the repository start date . 

Section Two: Special Issues 

Specific safety concerns raised during the Commission's deliberations include security risks, safety of spent 

fuel storage at reactors, safety of rod consolidation at reactors and at an MRS, safety at an MRS facility, and the use 

of dual-purpose casks. 

A. Security Risks 

Safeguards are taken to preclude the potential for sabotage leading to release of radioactive materials to the environment and diversion of fissile material in the spent fuel 

for production of nuclear weapons. At the MRS Review 

Commission's request, the Nuclear Regulatory Commission (NRC), on May 25, 1989, briefed the Commission on 

safeguards issues associated with managing and storing of 

spent fue1. 8 

In response to Commission questions, the NRC staff 

stated that spent fuel stored either at individual reactor sites 

or an MRS is a poor target for sabotage or diversion and 

that there is no identifiable credible threat of sabotage or 

diversion of fissile material. In any case, the radiological 

consequences of sabotage would be low. Rod consolidation, which involves removing spent fuel rods from the fuel 

assemblies, could produce some compromise of accountability, but this would be small and acceptable. The NRC 

staff also said there is no significant concern about the security of spent fuel shipments. A 1986 NRC staff review of 

the conceptual design of the safeguards to be provided at 

the MRS indicated that NRC safeguards requirements can 

be met. 9 

A related issue of concern to some who testified at the 

Commission's public hearings was that storing spent fuel at 

an MRS would make reprocessing an attractive option, and 

this might increase the risk of diversion of fissile materials. 10Reprocessing in the United States, however, appears extremely unlikely at this time because it is not 

economical. In any case, there appears to be little connection between MRS storage of spent fuel and a decision to 

reprocess, since spent fuel stored at reactors is also available for reprocessing, and most spent fuel would continue 

to be stored at reactors even if there were an MRS in the 

system." 

Analysis of security issues must take complicated concerns into account and requires access to classified information. Independent assessment of these concerns is 

difficult. The Commission defers to the NRC's expertise 

and accepts its assessment. Based on the NRC assessment, safeguards risks associated with spent fuel at a 

reactor, at an MRS, or in transit appear so small that 

35 
Figure 4.2—An Example of a Spent Fuel Pool 

Source• Virginia Electric Power Company 

they are nut a serious consideration in comparing spent 

fuel management alternatives. 

B. Storage at Reactors 

1. Storage at Operating Reactors 

The spent fuel management system is not totally integrated: that is, spent fuel storage and management operations at reactors are under the control of the individual 

utilities, while transportation, management, and disposal of 

spent fuel after it leaves reactor sites are under DOE control, There are approximately 100 operating reactors at 

about 70 sites managed by more than 50 different utilities. 12Storing spent fuel at a central DOE facility could 

enhance safety because the spent fuel would he under the 

control of management and staff whose primary task is its 

safe storage and management. Centralized control of spent 

fuel may also provide a potential safety benefit because it 

increases system compatibility. 

As the repository start date is delayed and spent fuel 

pools (see Figure 4.2) fill up, more reactors are expected to 

turn to spent fuel management operations (such as dry cask 

storage. transshipment, and rod consolidation) that were 

not contemplated when the reactors were designed. Such 

operations could divert workers' and managers' attention 

36 
from their primary duty, operating the reactors, because of 

increased attention to spent fuel management, or because of 

accidents (such as contamination of the spent fuel pool) resulting from such operations. 

However, spent fuel management operations have 

been safely carried out at reactors for many years under 

NRC regulatory control and by trained personnel. Once 

spent fuel has been removed from the reactor core, spent 

fuel handling and storage activities are separate from those 

activities associated with the production of electricity. Although the inventory of spent fuel at reactors is increasing, 

there is no reason to believe that safe management of the 

fuel cannot continue or that the fuel will interfere significantly with safe reactor operations. 

Dry storage of spent fuel at reactors is a passive and 

safe process. Once spent fuel is placed in dry storage casks 

or bunkers, it requires no additional care except periodic 

monitoring and security to assure that the casks or bunkers 

do not deteriorate, radioactive material is not released to 

the environment, and no unauthorized access to the spent 

fuel storage area occurs. 

It appears that most, if not all, reactor sites can safely 

store all of the spent fuel that would be generated during 

the reactor's 40-year operating life. In a study for the Commission of spent fuel storage needs and at-reactor capability, Ebasco concluded that most operating reactors can 

provide additional dry spent fuel storage at their sites on a 

schedule corresponding with their needs. This storage can 

be expanded as necessary to meet life-of-plant storage requirements (or beyond, in the event of an extended plant 

life). 13 

At most sites, life-of-plant storage can be accomplished by reracking spent fuel pools and using dry storage. 

Where sufficient space for dry storage does not exist, utilities may be able to consolidate spent fuel to create additional storage capacity in the spent fuel pool (although at 

some boiling water reactors this would be limited by 

weight restrictions on the spent fuel pool). As discussed below, there is no reason why such rod consolidation could 

not be carried out safely. Some utilities could solve their 

spent fuel storage problem temporarily by transshipping 

spent fuel from one utility-owned reactor to another. However, this cannot be viewed as a long-term solution since it 

does not increase total at-reactor storage capability. 

Although neither the Commission nor its contractors 

identified specific reactors which would have storage problems during the full operating life of the plant, it is possible 

that technical limitations at a few reactors would make it 

difficult to store all of the spent fuel generated during the 

reactor's operating life. It is also possible that public opposition could delay or halt the building of additional storage 

at a reactor. Therefore, it may be prudent to provide some 

away-from-reactor storage for those few utilities which 

may be faced with such a problem, rather than risk forced, 

premature shut down of the plants. More definitive information on reactors' storage capability should be available 

when DOE completes its present study on this issue. 14 

2. Storage At Shutdown Reactors 

The Commission examined whether storing spent fuel 

at permanently shutdown reactors could create safety problems. Although a few reactors may shut down before their 

licenses expire, and a few licenses expire before 2009, the 

bulk of the reactors now operating will reach the end of 

their presently licensed operating lives between the years 

2009 and 2030, as shown in Figure 4.3. 

Table 4.7 and Figure 4.4 show that substantial 

amounts of 5-year-old spent fuel 15will begin to accumulate at shutdown reactors after 2015 if there is no facility 

available to accept spent fuel. The NRC, in its "Waste 

Confidence Decision Review," 16has recently concluded 

that spent fuel can be stored safely and without any significant environmental impacts for at least 30 years beyond the 

expiration of a reactor's operating license at the reactor's 

spent fuel storage basin or at an on-site, independent spent 

fuel storage facility, or for a total of 100 years if an extended period of reactor operations is included. 

However, maintenance of spent fuel on-site after reactor shutdown is not without consequence. The activities 

which the licensee must carry out to meet NRC requirements for the various decommissioning options vary depending on the types and amounts of radioactive material 

remaining on-site after the plant shuts down.'? If spent fuel 

has been removed from the site, these requirements are 

usually minimal. If spent fuel is kept at the site: 

• security must be maintained to safeguard the spent 

fuel;' 8 

• the integrity of the spent fuel storage system must 

be maintained; 19and 

• a Certified Fuel Handler must supervise spent fuel 

handling. 20 

As a result of these requirements, storing spent fuel 

on-site after reactor shutdown is costly to the utility. Maintaining spent fuel at a shutdown reactor is expected to cost 

between $2 to $3 million more per site per year than if all 

spent fuel were removed. 21To avoid these costs, utilities 

will want to remove the spent fuel from the site as soon as 

possible. Therefore, it is likely that utilities would opt to remove all spent fuel by the fifth year after reactor shutdown 

when the last spent fuel discharged from the reactor becomes eligible for DOE to remove it. 22 

Following reactor shutdown, trained reactor personnel 

C 

37 
Number of Reactors 

1000 

100 

10 

II 

2❑25 2030 2035 2040 

0.1 

2000 

[ I 

2005 2010 2015 2020 

Year 

Figure 4.3—Shutdown Commercial Light Water Power Reactors (LWR)a 

MI Number shutdown each year 

Shutdown before 2000 b 

—Y— Total shutdown 

a Assumes all reactors will be shut down 40 years atter initial reactor startup date. 

Data from DOEIRL-88-34, "Spent Fuel Storage !Requirements 1988," October 1988, Table A 1 

b Includes only shutdown commercial reactors which still have spent fuel stored on-site. 

would probably seek employment where their skills would 

be more useful. Monitoring the stored fuel and maintaining 

security would probably be routine and monotonous and 

could be carried out as a part-time responsibility by persons 

whose principal duties were elsewhere. Under such conditions, these operations might not be performed as well as 

expected. sothere could be some risk that spent fuel storage and subsequent handling to prepare it for shipment to 

the repository would be performed under less than ideal 

conditions. This is unlikely, however, given the strict regulatory requirements under which the spent fuel must be 

stored and handled. Also, utilities may be able to hire outside firms with expertise in spent fuel handling to conduct 

some of these activities. 

A central interim storage facility would address these 

safety concerns because it would have a group of trained 

and experienced fuel handlers, health physicists, and security staff available at all times. Providing the necessary personnel at a single site rather than at individual utilities 

would be more efficient and result in substantial cost savings to the utilities. Furthermore, since the workers would 

handle spent fuel daily, they would be more experienced in 

performing routine handling operations that would occur 

only infrequently at a shutdown reactor and better able to 

handle emergencies that might occur. Therefore, although 

spent fuel can be stored safely at individual sites, early 

waste acceptance from shutdown reactors could provide 

benefits. 

38 
Figure 4.4—Spent Fuel Accumulation 

at Shutdown Commercial Light Water Power Reactorsa 

100 

80 - 

MI 60 -

Total 

40 - 

Pool Storage 

20 -

1111 

Dry Storage 

ton 

- 80 

-60 

- 40 

0 '`i . 

2000 2005 

11111 1111111 0000 mamma 

----=_-_,_„,,0 01111110111111111111.HOITHi 

2010 201 

2020 

2025 

2030 2035 2040 2045 a." 

Thousands of M1 t-1 of five year old fuel' ) 

3 Assumes all spent fuel stays at reactors indefinitely. Accumulation figures can be found in Table 4.7. 

b Five year old fuel is used because under the existing contracts between the utilities and DOE, generally, 

DOE will not begin to accept spent fuel from the utilities until it has aged five years since its discharge from 

the reactors. 10 CFR 961.11, Appendix E, Section 0, paragraph 3. 

Table 4.7—Spent Fuel Accumulation 

at Shutdown Commercial Light Water Power Reactorsa 

MTU of Five Year Old Fuels 

YEAR DRY STORAGE POOL STORAGE TOTAL 

2000 0 500 500 

2005 0 500 500 

2010 0 1.500 1.500 

2015 500 4,000 4.500 

2020 7,500 21,000 28,500 

2025 12,000 29,000 41,000 

2030 19,500 40,000 59,500 

2035 27,000 54,000 81,000 

2040 29,000 55,500 84,500 

2045 30,000 57,000 87,000 

aAssumes all spent fuel stays at reactors indefinitely. Accumulation shown graphically in Figure 4.4. 

Five-year-old fuel is used because under the existing contracts between the utilities and DOE, generally 

DOE will not begin to accept spent fuel from the utilities until it has aged five years since its discharge from the reactors. 10 CFR 961.11, Appendix E, Section Et, paragraph 3. 

39 
Figure 4.5—Fuel Assembly 

and Fuel Rod 

UPPER 

END 

CAP 

FUEL 

CLADDING 

4.312" OD 

0.02S- WALL 

SPACER 

LOWER 

ENO 

CAP 

0 010:0100E1]10 

11 11 111111111111 

1 

O0 

ACTWE 

LENGTH 

Source: Nuclear Regulatory Commission 

On balance, the Commission finds that, under normal circumstances spent fuel can be stored safely at reactor sites, using either pool or dry storage. during the 

operating life of the reactor and for up to 30 years 

thereafter. However, it may be prudent to provide a central interim storage facility where spent fuel would be 

under the full-time care of trained personnel and management whose exclusive responsibility is the fuel's safe 

storage and handling. 

C. Rod Consolidation 

Another safety issue is spent fuel consolidation. The 

Commission studied whether spent fuel consolidation can 

be carried out safely on a production scale at reactors, at an 

MRS, or at the repository and whether there are system 

benefits to be obtained from consolidation. 

During rod consolidation. the non-fuel-bearing components (upper and lower fuel-assembly tie plates, assembly spacer grids, and any other assembly structural 

members) are removed from spent fuel assemblies, reduced 

in volume, and stored. The fuel rods are collected and 

closely packed into a bundle inside a canister to achieve 

volume reduction, thereby potentially reducing the space 

required for storage, transportation, or disposal. Figure 4.5 

shows a typical fuel assembly and fuel rod. 

Until recently, DOE, when comparing MRS and NoMRS options, has assumed consolidation would be a part 

of the spent fuel management system. In addition, a number of utilities have considered fuel rod consolidation as a 

way to increase spent fuel pool capacity. 

To ascertain whether rod consolidation would affect 

system risk substantially, the Commission analyzed a NoMRS case in which 50% of all spent fuel is consolidated at 

the reactor site 23and an MRS case in which spent fuel 

which passes through the MRS is consolidated at the MRS. 

(See Table 4.8.) In the No-MRS case, public doses remain 

essentially the same whether there is at-reactor consolidation, but there is a small increase in occupational dose at 

the reactor. In the MRS case, consolidation at the MRS 

produces no significant change in either public or occupational risk. 

The Commission sponsored an independent evaluation 

of the risks, benefits, and economic costs of rod consolidation at reactors, at an MRS facility, and at the repository. 24 

In assessing the risks, factors considered were the maturity 

of the technology, contamination control. generation of 

secondary wastes, worker exposure, criticality, potential 

accidents, and, for consolidation performed at the reactor. 

potential adverse impacts on reactor safety. This assessment concluded that both wet consolidation (which would 

be used at reactors) and dry rod consolidation (which 

would be used at an MRS or repository) are technically 

40 

7 0 2 J 0 2 0 3 
TABLE 4.8—Comparison of Total Spent Fuel Management Life-cycle 

Doses for Systems with and without Consolidation 

(2013 Repository Start Date) 

. • . • • • Activity Center 

NO-MRS UNLINKED MRSa 

No 

Consolidation 

Cohsolidationb 

At Reactors' 

No- ° 

° Consolidation 

Consolidation 

at MRS 

. , 

;Reactor• 130/13,500d 130/21,500' , 130/1,900 130/1,900 

, MRS 5/600 10/900 

RepdSitory <1/8,400 <1/8,400° <1/8,400 <1/8,400 

:Transportation 7,900/4,200 7,900/2,900 3,400/6,100 3,700/6,000 

Total 8,000/26,000 8,000/32,000 3,500/17,000 3,800/17,200 

„ 

unlinked MRS was selected to provide an upper bound for the radiological effects resulting from consol- 

' idation at the MRS. The MRS is assumed to begin operation in the year 2000. 

bAssumeS 50% of all spent fuel consolidated at reactors 

dAssurnes all fuel which goes through the MRS is•conSblidated. 

dPublic dose/occupational dose. 

. 

feasible, but are still in the developmental stage. The NRC 

staff, in its 1986 evaluation of a draft of DOE's MRS proposal later submitted to Congress, essentially came to the 

same conclusion concerning consolidation at the MRS . 25 

For wet consolidation at reactors, additional staffing requirements and potential pool contamination are key utility 

concerns. For dry consolidation at an MRS or repository, 

production rate and generation of secondary wastes are potential problems. 26 

In its initial MRS proposal, DOE stated that "consolidation at an MRS offered system advantages by providing 

more compact packages of waste, thus reducing the number 

of packages to be handled, transported, and put underground." 27However, after conducting a series of system 

studies reexamining the role of the MRS in the waste-management system, DOE now finds no significant benefits to 

be obtained from rod consolidation at the MRS. In testimony presented to the Commission DOE stated, "The 

DOE will not presume at this point that the spent fuel will 

be subjected to any operations like consolidation because 

there is no clear incentive for such operations...The selection of the Yucca Mountain site has allowed the DOE's 

studies to focus on the economics of various waste-package 

concepts for that site, and these studies have not identified 

sufficient advantages for consolidation to warrant its use at 

present."28 Therefore, although rod consolidation probably 

can be done safely at an MRS, there appears to be little incentive at present to introduce the potential risks associated 

with this immature technology into the MRS facility. This 

could change if, for example, increases in projected disposal packaging costs provide greater incentive to reduce the 

number of packages to be emplaced in the repository. 

At-reactor rod consolidation also can apparently be 

done safely, 29but has yet to be demonstrated at the commercial scale necessary to make it an attractive alternative 

to dry cask storage for the utilities. Utilities which have 

tried rod consolidation have opted for dry storage instead. 39 

The Commission finds that rod consolidation has 

yet to be demonstrated on a production-rate basis. 

Whether performed at reactors or at an MRS, rod consolidation, like any other technology, poses some health 

and safety risks, although these are estimated to be 

small. Decisions on whether rod consolidation would 

provide sufficient benefits to the waste management 

system as a whole to justify the risks and costs must 

await further development of the technology, the shipping casks, and the repository. Until the need for and 

feasibility of rod consolidation for the waste manage7 

41 
ment system are determined, utilities are expected to 

continue to examine the benefits and costs of at-reactor 

rod consolidation and make decisions appropriate to 

their individual needs. 

D. Safety of the MRS Facility 

The Commission considered whether adding an MRS 

facility would introduce substantial additional risks or environmental impacts into the spent fuel management system. 

A number of people expressed concern to the Commission about the potential safety and environmental impacts associated with adding another facility to the 

system. 3 ' Most of these concerns relate to transporting 

spent fuel to and from the MRS. However, the State of 

Tennessee, which extensively analyzed the MRS that DOE 

planned to site near Oak Ridge, opposed siting the MRS 

there, but not on safety or environmental grounds. 32 

The NRC staff evaluated the DOE proposal for an 

MRS and concluded that (1) the nature of the operations involved—passive storage and relatively simple 

mechanical processes—indicates the MRS would create 

a limited potential for accidents or adverse consequences; (2) the MRS conceptual design appears reasonable from the standpoint of public health and safety, 

and (3) it appears from the conceptual design that NRC 

requirements can be met. 33The Commission agrees 

with this assessment. 

E. Dual-purpose Casks 

The State of Tennessee has proposed an integrated 

No-MRS system which it claims is superior to the integrated MRS system proposed by DOE. The centerpiece of 

the Tennessee proposal is the use of dual-purpose casks. 

Dual-purpose casks are designed to be used for dry storage 

and subsequent shipment of spent fuel to the repository. 

(See Figure 4.6.) One of the principal advantages claimed 

for dual-purpose casks is that using them reduces the number of times spent fuel must be handled. 34As a result, occupational radiation exposure to workers would be 

reduced. 35 

A No-MRS case using dual-purpose casks was analyzed using a computer code called MARC (MRS Review 

Commission's Analysis of System Risk and Cost—see 

Chapter Three, Section Two and Appendix G). The occupational dose was reduced by about 15% from 26,000 to 

22,000 person-rem due to reduced cask loading and handling doses at the reactor. (See Table 4.5.) However, the 

public dose remained essentially the same. 

There are some potential problems with using dualpurpose casks. First, such casks are not currently approved 

for use in the United States, although they are approved for 

use in the Federal Republic of Germany and their use is being considered by other European countries. 36(See Appendix D.) The NRC expects to receive and complete review 

of an application for certification of a dual-purpose cask 

within the next few years. However, there can be no assurance now that certification will be forthcoming. Dual-purpose casks will have to be certified under two sets of 

regulations, 10 CFR Part 71 (transportation) and 10 CFR 

Part 72 (storage). Transportation requirements are generally 

more stringent than those for storage, and transport casks 

must be recertified every five years. A concern regarding 

whether a cask can be designed to meet both sets of requirements is deterioration of the cask seal during long 

storage periods before transportation. However, it is expected that dual-purpose casks will have a double lid and 

two sets of seals so that the outer seals can be tested and replaced, if necessary, without opening the cask or removing 

the spent fuel to ensure containment after long periods of 

storage. 

Another potential problem is physical deterioration of 

the basket which holds the fuel rods in place in the cask. 

The principal concerns are: (1) whether the cask and basket 

will maintain their integrity throughout prolonged storage 

periods, perhaps up to 40 years, before transport, and (2) 

whether the NRC will have sufficient confidence in this integrity to allow transport without requiring that the casks 

be opened for inspection. If dual-purpose casks have to be 

opened for inspection before shipping, their apparent risk 

advantages would be substantially reduced. 

The Commission finds that the use of dual-purpose 

casks in either an MRS or a No-MRS system should be 

seriously considered because the casks could require 

less handling and create less occupational exposure. 

However, dose reductions are small and, given the uncertainties cited above, the dose reductions from using 

dual-purpose casks do not provide a basis for discriminating between MRS and No-MRS options. 

(For additional discussion of dual-purpose casks, see 

Chapter Five, Section One, Part B.) 

42 

7 0 
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Figure 4.6—A Dual-purpose Cask 

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Section Three: Environmental and Socioeconomic Effects 

This section discusses the environmental impacts 

which might be significant in comparing spent fuel management systems with and without an MRS. These include 

the potential environmental impacts associated with dry 

storage of spent fuel at reactor sites and construction, operation. and decommissioning of an MRS facility. 

A. Effects of Storage 

1. At Reactors 

The environmental impacts associated with at-reactor 

pool and dry storage of spent fuel assemblies are expected 

to be insignificant. Dry storage will involve land use. However. most utilities have sufficient land to accommodate dry 

storage, and land acquisition was considered under the environmental impact assessment for the original reactor 

licensing actions. 

When licensing at-reactor operations, the NRC must 

consider environmental impacts. The NRC has already licensed the dry storage of spent fuel at the Virginia Power 

Company's Surry Nuclear Power Station and at Carolina 

Power and Light Company's H•R. Robinson Nuclear Project. In each case, the NRC found no significant environmental impact. 

2. At an MRS Facility 

DOE has evaluated the range and types of environmental effects of an MRS and submitted its evaluation to 

Congress.'? The information in this section is based on that 

study. 

DOE evaluated the environmental impacts of six MRS 

43 
site-design combinations: three candidate sites with two design concepts at each. The two design concepts were based 

on identical receiving and handling concepts but different 

spent-fuel storage concepts: sealed storage cask and field 

dry well. Since environmental impacts are to some extent 

site specific, it is impossible to characterize accurately all 

of the environmental impacts until the MRS site has been 

identified. However, the DOE evaluation was designed to 

compare the environmental effects of specific site-design 

combinations and to reveal risks or impacts of elements of 

the MRS facility design for three different types of sites. 

This provides a basis for drawing general conclusions 

about the expected environmental impact of an MRS. 

Based on this evaluation, DOE found no design features for 

either storage concept that created significant adverse impacts or any that resulted in significantly different effects 

across the three candidate sites. 

Preconstruction and construction activities are expected to degrade, temporarily, the ambient air quality in 

the immediate vicinity of the site. Short-term total suspended particulate standards may be exceeded due to dust 

from land disturbance and heavy vehicle traffic. No significant aiborne emissions are anticipated from constructing 

and operating an MRS facility. 38 

Waste heat generated by the facility is expected to include about 23 megawatts (MW) from heat generated from 

the radioactive decay of spent fuel in the storage areas and 

25 MW from the facility's heating and air conditioning 

cooling tower.39No perceptible changes in the downwind 

environment are anticipated. Decommissioning an MRS is 

not expected to include major demolition or regrading. 

Therefore, impacts from decommissioning activities are expected to be negligible. During construction, water quality 

could be temporarily degraded from high-suspended solids 

content of the runoff. Settling solids in runoff ponds before 

discharging the water to surface waters will mitigate such 

degradation. The MRS facility will be designed so that radioactive waterborne effluents are not discharged into the 

environment. Effluents from wastewater treatment are expected to meet all State and EPA standards for industrial, 

municipal, and domestic wastewater disposal. 

The largest ecological impact will be the clearing of 

land and subsequent loss of this land to production and 

ecological processes. Up to 320 acres will be needed, depending on the functions to be carried out at the MRS. 

B. Socioeconomic Effects 

The major socioeconomic impact resulting from the 

development of any site-design combination is the loss of 

the site for potential commercial development, with resulting potential loss of additional tax revenues. In the absence 

of offsetting financial compensation, any demands the 

MRS facility or its employees create on public services 

would have to be met by State, Tribal, and local government revenues. An adverse image for the local area, either 

through perpetuation of economic uncertainty or through 

fear of environmental hazards, could also affect commercial development. Although little actual health risk from radiation exposure is expected, the MRS facility may 

generate socioeconomic impacts because of the public's behavioral reactions to the perceived risk (the so-called "stigma effect"). This is discussed in more detail in Chapter 

Seven. 

The jobs and incomes the MRS creates would attract 

people into the area and create demands for housing, 

schools, community services, and infrastructures such as 

utilities, roads, and sewers. 

Aesthetic impacts include projected noise levels, principally during construction, and visual impacts. Distance 

and natural barriers would attenuate noise. Visual impacts 

would be similar to that of any multi-story building complex. The largest building at the facility would be the Receiving and Handling (R&H) building, a concrete structure 

97 feet (about 9 stories) high. The main stack, 165 feet 

above the ground level, would be on top of the R&H building. The 36-acre storage area would be an array of concrete 

casks about 22 feet ta11. 40 

In summary, based on the DOE environmental analysis, the environmental impacts of an MRS are expected to 

be similar to those associated with constructing and operating any similarly sized industrial facility. 

C. Findings About Environmental and Socioeconomic Effects 

The Commission finds that the environmental impacts associated with spent fuel management will be 

small and within regulatory limits for all spent fuel 

management alternatives considered, regardless of 

whether they include an MRS. 

44 

/ 9 0 
Section Four: Findings 

The Commission finds that occupational, public, 

and environmental effects associated with storing and 

managing spent fuel are small and are expected to be 

within appropriate regulatory limits regardless of the 

spent fuel management alternative selected or the repository start date assumed. The Commission also finds 

that the differences in risks among the alternatives considered are so small they do not provide a basis for discriminating between MRS and No-MRS alternatives. 

45 
Chapter Four Notes 

1.Person-rem is a unit of population dose equivalent obtained by multiplying the dose equivalent in rem by the population exposed. In the International System of Units, this would be 

expressed in person-sieverts. 

2. Estimates of the number of cancer fatalities resulting from 

exposure to ionizing radiation vary from about 100 to several hundred fatalities per million person-rem. The estimate of 400 fatalities per million person-rem used in this report is based on 

conversion factors used in the U.S. Environmental Protection 

Agency's (EPA) Draft Environmental Impact Statement for Proposed NESHAPS (National Emission Standards for Hazardous 

Air Pollutants) for Radionuclides, EPA 520/1-89-005, February, 

1989, Vol.], see, for example, p. 6-15. 

3. The total life cycle dose from the MRS is about four person-rem (see Table 4.4). Assuming a 40-year life for the system, 

the yearly dose would be 0.1 person-rem. 

4. Dose from natural background radiation: 0.3 rem/year x 

one million persons exposed = 300,000 person-rem. Dose from 

medical x-rays: 0.039 rem/year X one million persons exposed = 

39,000 person-rem. The 0.3 rem/year and 0.039 rem/year figures 

are taken from the National Council on Radiation Protection Report No. 93, "Ionizing Radiation Exposure of the Population of 

the United States," September 1987, p. 53. The exposed population of one million persons is based on an assumed population 

within a 50-mile radius of the MRS—roughly equivalent to the 

estimated population for the previously proposed site near Oak 

Ridge, Tennessee. This same population estimate was used to calculate the population dose from activities at the MRS. 

5. The percent of in-transit doses to the truck driver and train 

crew was estimated by performing two runs on the MARC 

computer model (one for an MRS system and one for a No-MRS 

system), with the program modified so that it would not calculate 

doses to the driver and crew. 

6. Modifications to RADTRAN III are described in the June 

8, 1989, letter and attached draft report from Thomas H. Isaacs, 

Associate Director, External Relations and Policy, Office of Civilian Radioactive Waste Management, Department of Energy, to 

Jane A. Axelrad, Executive Director, MRS Review Commission. 

("Development of RADTRAN-based Radiological Unit Risk Factors for Use in TRICAM," May 31, 1989). 

7. Golder Associates, "Safety and Environmental Impacts 

for Alternative Spent Fuel Management Options," July 1989. 

8. McCorkle, George, Deputy Director, Division of Safeguards and Transportation, Office of Nuclear Material Safety and 

Safeguards, U.S. Nuclear Regulatory Commission, Transcript of 

Briefing Before the Monitored Retrievable Storage Review Commission, May 25, 1989 (Hereafter cited as Briefing Transcript, 

May 25, 1989). 

9. Nuclear Regulatory Commission, "Staff Evaluation of 

U.S. Department of Energy Proposal For Monitored Retrievable 

Storage," NUREG-1168, March 1986 (Hereafter cited as 

NUREG-1168). 

10.For example, see Johnsrud, Judith, Ph.D., Director, Environmental Coalition on Nuclear Power, and Research Director, 

Food and Water Inc., Transcript of Monitored Retrievable Storage 

Review Commission Public Hearings (Hereafter cited as Hearings Transcript), December 1, 1988, p. 139; Bechtel, Dennis, Coordinator, Clark County Comprehensive Planning Department, 

Hearings Transcript, January 9, 1989, p. 47; Fulkerson, Robert, 

Executive Director, Citizen Alert, Hearings Transcript, January 9, 

1989, p. 289; Drey, Laura, News Editor, Coalition for Alternatives 

to Shearon Harris, Hearings Transcript, February 16, 1989, pp. 

170-171, 179-180, 183. 

11.Spent fuel is generated at a rate of about 2,000 metric 

tons of uranium (MTU)/Yr. An MRS with a 15,000 MTU limit, as 

now specified in the NWPAA, would be able to hold only 40 percent of the 40,000 MTU expected to be accumulated by the year 

2000 and only 25 percent of the 60,000 MTU expected to be accumulated by 2010. 

12.On December 31, 1988, there were 107 light water reactors (70 pressurized water reactors and 37 boiling water reactors) 

operating in the United States. Department of Energy, "Commercial Nuclear Power 1989, Prospects for the United States and the 

World," DOE/EIA-0438(89), Appendix C. 

13.Ebasco, "Spent Fuel Storage Need and At-Reactor Capability Study," June 1989, pp. 5-10. 

14.The Department of Energy's Office of Civilian Radioactive Waste Management is sponsoring the Facility Interface Capability Assessment (RCA) Project. The project objectives are to 

determine and document existing and planned facility capabilities 

to store and ship spent fuel and identify facilities where possible 

interface changes could benefit the Federal waste management 

system. Nuclear Assurance Corporation, the contractor performing the study, will visit 76 sites including all 122 facilities from 

which commercial spent fuel will be accepted by the Federal 

waste management system. The project is scheduled to be completed in early 1990. 

15.The fuel's age is important because, under the existing 

contracts between the utilities and DOE, generally, DOE will not 

accept spent fuel from the utilities until five years after its discharge from the reactors. 10 CFR 961.11, Appendix E, Section B, 

paragraph 3. 

16.U.S. Nuclear Regulatory Commission, Waste Confidence 

Decision Review, 54 FR 39767 (September 28, 1989). (See Chapter 3, Note 20.) 

17.Based on personal communications between James C. 

Malaro, MRS Review Commission staff and the following staff of 

the Nuclear Regulatory Commission: Peter Ericson, Project Manager, Decommissioning and Environmental Project Directorate, 

Office of Nuclear Reactor Regulation (August 22, 1989); Michael 

Bell, Chief, Regulatory Branch, Division of Low Level Waste 

Management and Decommissioning, Office of Nuclear Material 

Safety and Safeguards (August 28, 1989); and Philip Ting, Section Leader, Requirements and Oversight Section, Domestic Safeguards and Regional Oversight Branch, Division of Safeguards 

and Transportation, Office of Nuclear Material Safety and Safeguards (August 30, 1989); and on examination of the following 

documents: a) Amendment 23 to License for Humboldt Bay Unit 

3 authorizing SAFSTOR until November 9, 2015 (Docket 50-133, 

July 19, 1988) and b) Amendment 3 to License for Fermi 1 extending SAFSTOR until March 20, 2025 (Docket 50-16, April 28, 

1989.) 

18.There are no generic safeguards requirements for storing 

spent fuel at shutdown reactors. Safeguards requirements are tailored to each plant's specific circumstances in accordance with the 

requirements of 10 CFR Part 73, "Physical Protection of Plants 

0 

46 
and Materials." Specific security requirements are withheld from 

public inspection because public disclosure could increase a 

plant's vulnerability to sabotage. However, Pacific Northwest 

Laboratory, in estimating SAFSTOR costs, assumed a security 

force consisting of a minimum of five armed personnel per shift 

would be maintained as long as the spent fuel remained on-site. 

NUREG/CR-0672, Addendum 1, "Technology, Safety, and Costs 

of Decommissioning a Reference Boiling Water Reactor Power 

Station, Effects on Decommissioning of Interim Inability To Dispose of Wastes Offsite," July 1983, p. 3.3. 

19.For the spent fuel pool, this includes maintaining water 

level, quality, temperature, and circulation; maintaining a supply 

of make-up water for the pool; and conducting a surveillance program to assure the continued integrity of neutron-absorbing materials used to control criticality. 

20. A Certified Fuel Handler is someone who has been trained to handle fuel (including spent fuel) at the site for which he or 

she is certified. Humboldt Bay, for example, has an NRC-approved program for training and certifying fuel handlers. Although removing and disposing of spent fuel is considered an 

operational activity, neither storage of spent fuel at a reactor site 

after reactor shutdown nor subsequent removal of spent fuel from 

the site requires the presence of a trained reactor operator. 

21. Pacific Northwest Laboratory estimates the cost of maintaining spent fuel storage at a site following reactor shutdown to 

be $2.2 million per year for a one or two pool site and $2.7 million per year for a three pool site. This cost is assumed to be independent of the quantity of spent fuel stored and is expected to be 

significantly less if the shutdown reactor is collocated with an operating reactor. Pacific Northwest Laboratory, "MRS Systems 

Study Task G Report," PNL-6876, April 1989, p. 3.19. 

22. See Note 15. 

23. It was assumed that all spent fuel was consolidated at 

each reactor which could achieve life-of-plant storage in the spent 

fuel pool through consolidation. 

24. Ebasco, "Rod Consolidation Costs, Risks, and Benefits 

Study," June 1989 (Hereafter cited as Ebasco, Rod 

Consolidation). 

25. NUREG-1168, p. 2. 

26. Another possible concern is whether rod consolidation 

might raise the danger of criticality of the fuel. However, criticality during consolidation or with storage or handling of consolidated fuel appears extremely unlikely. Ebasco, Rod Consolidation, 

pp. 3-13 and 4-10. 

27. Department of Energy, "Report of the Task Force on the 

MRS/Repository Interface," DOE/RW-0044, February 1986, 

p. 2-1. 

28. Thomas H. Isaacs, Associate Director, External Relations 

and Policy, Office of Civilian Radioactive Waste Management, 

Department of Energy, "DOE Position on the Monitored Retrievable Storage (MRS) Facility," Prepared Remarks before the Monitored Retrievable Storage Review Commission, May 25, 1989 

(Hereafter cited as Isaacs, Prepared Remarks, May 25, 1989), 

PP. 6-7. 

29. Department of Energy, "Final Version Dry Cask Storage 

Study," DOE/RW-0220, February 1989, p. 1-95; Ebasco, Rod 

Consolidation, pp. 3-20. 

30. The four utilities are Duke Power Company (Oconee 

Units 1 and 2), Maine Yankee Atomic Power Company (Maine 

Yankee), Northeast Utilities (Millstone 2), and Northern States 

Power (Prairie Island). Ebasco, Rod Consolidation, Section 3.1. 

31. For example, see Lowery, Leon, Legislative Representative, Environmental Action, Hearings Transcript, December 2, 

1988, pp. 351-352; Clarke, James McClure, U.S. House of Representatives, 11th District, North Carolina, as presented by Claudine 

Cremer, District Assistant, Hearings Transcript, February 17, 

1989, pp. 262, 267; Sharp, Jane, Board Member, Conservation 

Council of North Carolina, Prepared Remarks, February 16, 1989, 

pp. 1-2. 

32. McWherter, Ned, Governor, State of Tennessee, "Tennessee's Position on the MRS: Final Comments to the Monitored 

Retrievable Storage Review Commission," July 20, 1989 (Hereafter cited as Tennessee's Final Comments), p. 4. 

33. NUREG-1168, Chapter 1. 

34. Tennessee's Final Comments, pp. 3-4. 

35. Hoskins, Raymond E., "A Systems Evaluation of the 

High-Level Nuclear Waste Management System Based on Integration of Dual Purpose Cask Into The System As An Alternative 

to DOE's Proposed Monitored Retrievable Storage Facility As An 

Integral Part of The System," June 1989, pp. V-23-V-24. 

36. When dual-purpose casks are used in European countries, 

the fuel is transported shortly after the cask is loaded. In the United States, the spent fuel would likely be stored at reactor sites in 

the dual-purpose cask for up to 20-30 years before being shipped. 

This extended storage prior to shipment is a cause of concern in 

the United States. 

37. Department of Energy, "Monitored Retrievable Storage 

Submission to Congress," DOE/RW-0035/1-Rev. 1, Vol. II, Environmental Assessment for a Monitored Retrievable Storage Facility, February 1986 (Hereafter cited as DOE/RW-0035/1-Rev. 1, 

Vol II). 

38. DOE/RW-0035/1-Rev. 1, Vol. II, Table 3, p. xviii. 

39. DOE/RW-0035/1-Rev. 1, Vol II. p. xvi. 

40. DOE/RW-0035/1-Rev. 1, Vol. II, p. xxi. 

7 

47 
Chapter Five 

Health and Safety Effects of 

Transporting Spent Fuel 

The transportation of spent fuel is an issue of great 

concern to many people. That was evident from the testimony heard by the Commission around the country, and 

the Commission made it a high priority in its study. This 

chapter examines the effects of transporting spent fuel and 

compares the safety of transportation as it would be carried 

out in the spent fuel management alternatives under 

consideration. 

Section One examines the radiological effects of 

transporting spent fuel with and without an MRS. Section 

Two examines the non-radiological risks with and without 

an MRS. Section Three shows the results of sensitivity analyses performed to make certain that differences in assumptions would not change the Commission's findings. 

Section Four presents the Commission's findings. Appendix J contains background information about the way spent 

fuel transportation is regulated and managed. 

Section One: Radiological Effects 

To compare the overall radiological effects of having 

and not having an MRS, the Commission estimated the total radiation exposure to all people during spent fuel transportation as it would be conducted for each alternative and 

then used a conversion formula to calculate how many 

deaths might result from each. 

A. MRS and No-MRS Base Cases 

The base cases in this chapter's analysis, using the 

computer model MARC (see Chapter Three, Section Two), 

are the same as the base cases—No-MRS, linked MRS, and 

unlinked MRS—outlined in Chapter Three, Section Three, 

and used in Chapter Four. The dual-purpose cask variation 

explained below in Part B uses a different set of 

assumptions. 

To limit the number of cases considered to a reasonable number, a repository opening date of 2013 is assumed 

for all cases in this chapter. The repository start date only 

has marginal effect on the transportation risk. A few cases 

involving repository start dates other than 2013 also were 

considered. These, and the detailed modeling assumptions 

and computer output, are described in a report prepared by 

ICF Technology Incorporated for the MRS Review 

Commission.' 

1. Total Radiological Dose 

Table 5.1 shows the total amount of radiation exposure that would result from transportation if an MRS were 

part of the spent fuel management system and if it were 

not. The total amount of radiation exposure to all people 

during transport is expressed in person-rem, a measure of 

the effect of radiation on people. (Table 5.1 also contains 

the results of the dual-purpose cask variation discussed 

separately in Part B of this section.) 

The "in-transit dose" is the dose that would be received by both the crew and the public during transport; the 

"handling dose" is the dose to workers during loading and 

unloading of casks onto and from transportation vehicles. 

"Total transport dose" is the sum of these two and is the 

total radiation dose that would be received by the workers 

and crew, and the general public along the paths of travel. 

This includes expected doses during normal transport and 

accidents. Estimated normal transport doses are significantly higher than estimated accident-related doses. 2Table 

5.1 shows that transportation of spent fuel, if there were not 

an MRS, results in a total dose of 12,200 person-rem. If 

there were a linked MRS, transportation of spent fuel 

would result in a total dose of 9,000 person-rem. 

49 
Cases 

Table 5.1 Total Life-cycle. Transpoetation 

' ,.Radiolividal Risk. Repository in2013 

(54% tail/46% truolatom reactors; 100%:taillram.MRS) 

In-transit HaridIng 

Yose° Dose 

, 

Total 

Transport 

DoSeCalculated 

Cancer 

Fatalities 

No-MRS 7,900 4,300 12,200 4.9 

NOLMRS(dual- 210 4,100 4,300 1.7 

.puposeces s 

1009/01rairirom 

reactors) 

.Linked. MRS 3,400 5,600 

(NWFy■A) 

Unlinked MRS 3,400 6,100 9,500 3.8 

DOE,NO=MRS' 3,600 N C 9 N.C. N.C . 

DOE; MRS` N.C. N.C. 

,\Alsfet%:_ 

.:'Strategy 

'K.,13$':iO'bOiO:opeeatio:ns in 2010 

., ,, . 

::. '.?MRStOpegin beg: in 200Q— _ 

:: ,`E:i:dase.a. Were:Peeritedihthelf.:1ePa*ent of Energy's !MRS Systems ;Study, Taalc F: TeahsportatiOn 

, . 

is 

 , , _ . 

'Irrtpacts,'dt. a Mo. iiitorOd7RetrieVaple Storage Facility MeV A989:, :P.: 5.,iThO'li",006.6 itary, ir):PPE',$:,yst0r.n handled °. only::p,p04m:tij:4NIRG,'sysfetti6 handled 07 (7:ioi:Y nirtu 'To' 16• -1-6/ide'a'bai' for Corrioaii§ohtheseniiMbAit were . . : ,.. . • • : - • . ,eXtrapOlated'frOm'the'aCtUalppEAUttibera::. 

,, ,.:, 

10,DOEs western strategy, western reactors ship spent fuel directlyto the repository ratherthan'to the 

MRS: ose Person tton=. em •• •• „ • _ , 

E>.ccePt.for:theNo:MRS dual-purpose cask case, which assumes 100 percent rail transport from reactors 

=. Not Calculated' 

To calculate the number of fatalities that would result 

from such exposure, the Commission used the conversion 

formula used in Chapter Four. The formula is that for each 

10,000 person-rem incurred, there would result 4 calculated 

latent cancer deaths. This means that transportation of 

spent fuel would result in about 5 calculated latent fatalities 

if there were no MRS and in less than 4 calculated fatalities 

if there were an MRS. These estimates are for the entire period during which the facilities would operate, or no more 

than one-tenth of one calculated latent cancer per year. The 

expected background radiation dose during the same time 

period would produce an estimated 120 cancer deaths per 

year to a population of a million people. The difference between the numbers with and without an MRS is far too 

small to be useful in deciding between the two alternatives. 

Relative to the MRS alternative, the No-MRS alternative calls for a high proportion of truck use. This is because 

according to the DOE transportation system study assumptions,3adopted here for the base cases, many reactors do 

not have access to rail lines and would ship fuel all the way 

to a repository by truck if there were no IVIRS. 4If there 

were an MRS, some fuel could travel to the MRS by truck 

and then be placed on a train to go to the repository. 

To estimate the radiation exposure from transportation 

for each alternative, the Commission used the transportation radiation dose data contained in a modified version of 

50 

7 0 2 0 0 
able urrOgate'' 

` , ifetdOte'TrriO'prtation 

RepositOryiri 2013 

54% iiiii/46% truck from reactor; 

100°/0" rail front, MRS) 

Cak-miles 

',cases 'On milliOns. in millions) 

Q-MRS 64 74.1 

Linked MRS' 9' 

:NWP 

ipnlinked MR 

in i;Y:)0)=.." 

MRSIo bbbin oder'ation's=in2010 

RADTRAN III, a new data base supplied by DOE, rather 

than the transportation dose data used in the DOE system 

study. The latter study used radiological dose data developed by Argonne National Laboratory. The RADTRAN 

data set produces higher estimates of truck doses and lower 

estimates of train doses than the Argonne data set does. 

The two data sets differ because of differences in assumptions about exposure. These are assumptions about such 

factors as the number and spatial distribution of people in 

rail yards, and the amount of shielding that may be provided by structures and vehicles. 5Because the Commission 

used the RADTRAN III data, its dose estimates for the 

cases involving a large proportion of truck use are higher 

than they would have been if the Argonne dose data had 

been used. Similarly, the Commission's dose estimates for 

cases involving a large proportion of train use are lower 

than they would have been if the Argonne data had been 

used. The difference between the MRS and No-MRS dose 

is larger in the Commission's estimates than in DOE's system study estimates, but the differences are small in both 

sets of estimates. There are uncertainties associated with 

dose data sets and, therefore, with the calculated results. 6 

2. Surrogate Measures 

In some of their studies on the transportation issue, 

DOE and the State of Tennessee use "surrogate measures" 

to approximate risk.' For example, to compare the relative 

radiological risk of various alternatives, these studies add 

up the "cask-days" (the total number of days a transport 

cask is in transit) or the "cask-miles" (the total number of 

miles casks travel). The assumption is that having more 

casks on the road would irradiate more people than getting 

all the fuel sent to its destination with fewer casks. "Shipment-miles" (the total number of miles to be traveled by 

all the shipments added together) is used as a surrogate for 

accident probability, since the probability of an accident 

varies directly with the total miles traveled, all other things 

being equal. 

"All other things being equal" is an important caveat, 

and surrogate measures must be used with an awareness of 

their limitations. First, they represent only the in-transit 

portion of transport operations and do not portray all of the 

transport risks, which also include exposure to workers 

while handling the spent fuel. As Table 5.1 shows, handling risks are a significant element of total transport risk. 

Second, two shipment-mile numbers, representing two different alternatives with different transport mode mixes, are 

not comparable for considering non-radiological risks. 

Trucks and trains have very different traffic fatality rates; 

the fatality rate per train-mile is much higher than the corresponding rate per truck-mile. (Non-radiological risks for 

the different alternatives are discussed in Section Two, below.) Therefore, given two alternatives for interim spent 

fuel storage, each with a different mode split between truck 

and rail, a case with the lower total shipment-mile number, 

but higher number of train miles, may actually have more 

traffic fatalities and may not necessarily lower the overall 

transportation risk. As can be seen from the discussion in 

Section Two on non-radiological risks, traffic fatalities can 

be several times greater than projected cancer fatalities. 

Table 5.2 shows the surrogate risk measures (shipment-miles and cask-miles) for the base cases portrayed in 

Table 5.1. 

B. Dual-purpose Cask Variation 

The two cases examined so far in this chapter assume 

that transportation of spent fuel would be by both truck and 

train to an MRS (or repository in the No-MRS case) and by 

train from the MRS to the repository. When DOE proposed 

an MRS in Tennessee, it asserted that having an MRS in 

the spent fuel management system would reduce transportation risks because an MRS could collect incoming small 

truck and rail shipments and combine them for transport to 

the repository in large rail casks shipped by dedicated 

trains (trains that would carry no cargo other than the spent 

fuel). The State of Tennessee challenged DOE's assumptions about transportation. Tennessee's position has 

evolved over time, and they now propose a No-MRS system in which spent fuel would be put into large casks that 

51 
could be used for both storage and transport, called dualpurpose casks. 8These casks would be shipped by rail directly from the reactors to the repository on dedicated 

trains. If a reactor did not have direct access to rail transport, the casks could be carried by barge or heavy-haul 

truck to the nearest railhead to be reloaded onto dedicated 

trains and sent to the repository. Tennessee argued that this 

method would reduce the total shipment-miles and caskmiles and thus reduce the overall radiological exposure 

during transportation. Tennessee also said that exposure to 

workers would be reduced because the casks require one 

less handling step, since dual-purpose casks would not necessitate returning the casks to the spent fuel pool to load 

fuel into transport casks. 

The Commission analyzed a dual-purpose cask NoMRS case under assumptions favorable to the concept, including assumptions about maximum transportation efficiency. All reactors were assumed to have rail access and 

all transport from reactors was assumed to be by dedicated 

trains. These changes in assumptions lowered the total 

transportation dose estimate to 4,300 person-rem as shown 

in Table 5.1. Because of the all-rail assumption, the dualpurpose cask variation has the lowest radiological dose estimate of any of the cases examined, including those discussed in Section Three, below. 

If a combination of standard storage and transport 

casks with the same capacity as the dual-purpose casks 

were used in the same all-rail transport case, the same dose 

estimates would result for transport to a repository, because 

the casks would travel the same number of cask-miles and 

be loaded and unloaded the same number of times. However, since standard storage casks would have to be returned to the spent fuel storage pool and the spent fuel 

transferred to a transportation cask, the radiological exposure at reactors for standard casks is higher. 

However, overall doses for all the cases are small, and 

so are the differences among them, both in person-rem and 

the numbers of calculated latent fatalities they would produce. The small differences in the dose estimates do not 

provide a clear-cut rationale for choosing between the MRS 

and No-MRS alternatives, including the dual-purpose cask 

variation, on the basis of transportation radiological risks. 

Also, the dual-purpose cask case analyzed assumed 

that the dual-purpose cask would be transportable even after long storage. Regulations might require the cask to be 

opened for testing (of the spent fuel basket, for example) 

before it is shipped after prolonged storage. 9This would 

nullify the dual-purpose casks' theoretical advantage in reducing handling dose. 

C. Findings 

The Commission finds that the estimates of the radiological effects of transporting spent fuel are small, 

and the difference between the estimates for different 

alternatives is not large enough to make transportation 

effects significant in choosing between alternatives. 

Section Two: Non-radiological Risks—Traffic Accidents 

One of the consequences of transporting spent fuel 

would be an increase in the number of train and truck traffic accidents, simply because there would be more trains or 

trucks traveling. The radiological consequences of such accidents were taken into account in the analysis in Section 

One above; measures to prevent and manage the radiological consequences are discussed in detail in Appendix J. 

This section, Section Two, considers the non-radiological 

risks posed by spent fuel transportation, defined for the 

purposes of this study as the number of traffic fatalities that 

would result from train or truck accidents during the transport of spent fuel. 

Overall, there is practically no difference between the 

results for the base cases—No-MRS, linked MRS, and unlinked MRS. About 16 traffic fatalities would result from 

transportation for each, during the entire time the MRS 

and/or the repository would operate (see Table 5.3). This is 

less than one fatality per year. Each year, 45,000 traffic 

deaths occur in the United States. These differences in traffic fatalities among the alternative strategies are not significant enough for them to factor in a decision on whether to 

build an MRS. 

A. Traffic Fatality Rates 

Truck accident statistics show the fatality rate for 

large combination tractor-trailer trucks is about 0.05 deaths 

per million vehicle-miles traveled." ) 

To determine the rail fatality rate, statisticians have 

used two different measures, one for miles traveled by entire trains and another for miles traveled by individual 

freight cars. The fatality rate for entire trains is about two 

deaths per million miles." The rate for freight cars is much 

smaller. The freight-car rate is approximately 1/70 of the 

entire-train rate since trains average 70 freight cars each. 

52 

7 0 9 0 
3 ,3 

15,3 

flePoP0c!FY IfY 2013 

.:Traffics 

15!5 4 ' 

 8hipment-miles 

( in millions) 

;64'.7:' 

7.8 

26 9 

•No,i■AF:38:(5L/<; rail/46% truck) " 

No-fyll3S (Oual-purpose Casks; 

,100`,Y?:r4il) , 

-Jiinked MRSa;(NWPAA; 

'54% `rei1/46% truck from 

reactors;100% rail.frorn 

MRS) * ' ' 

, g 

• • ,,,,,,,,, • y 

:Cases 

MRS: tp beginoperatiohS':in 2010 ;

,,,,, • ,, ,,, - 

; ° g Table, 5.37—Life-cycle Non-radioiog ical %Risk 

Consistent with the DOE transportation system study, 

spent fuel, when transported by rail, is shipped on "dedicated" trains, 12that is, trains that carry nothing but spent 

fuel. These trains would carry three or five casks—three if 

leaving a reactor, five if leaving an MRS. This study uses 

the entire-train rate to estimate the fatality rate for these 

dedicated trains going to an MRS or repository, since the 

entire cargo is spent fuel. The collision of the train—not 

the number of railway cars involved—is the important 

component for calculating train accidents. 

When empty casks are returned to reactor sites, they 

could be attached to non-dedicated trains. That is, the rail 

car carrying the empty cask would be part of a train with 

about 70 other cars carrying other kinds of cargo. Therefore, only one-seventieth of the accident would be attributed to empty cask transport. This study uses the freightcar rate to estimate the fatalities for these trips. 

B. Base Cases and Dual-purpose Cask 

Variation 

The non-radiological risks for the No-MRS and the 

MRS alternatives are presented in Table 5.3. The dualpurpose cask case, a variation of the No-MRS base case, 

was assumed to use 100 percent rail transport. The estimates of fatalities are for the entire period of the first repository program. 

Table 5.3 provides an illustration of how little correlation there is between total shipment-miles (see Section 

One, above) and fatalities from traffic accidents for cases 

with very different mode splits. All three cases have nearly 

identical results for traffic fatalities—about 15—but very 

different shipment-miles. Fatality rates for trains are substantially higher than the rates for large combination tractor-trailer trucks; the difference in the fatality rates is so 

great that the substantially lower shipment-mile figure for 

the 100 percent rail case barely compensates. Indeed, in the 

100 percent rail case, if the empty casks were modeled as 

being returned to the reactors via dedicated trains instead of 

conventional trains, the fatalities for the all-rail case would 

have been almost twice as high because of the additional 

train trips required. 

C. Findings 

The Commission finds that the non-radiological 

risks associated with the alternatives are small and that 

differences among them are insignificant in determining 

the need for an MRS. 

53 

qty 
Table• 5.4=tffects of Linkages:on , Life=c Cie 

15.3 

:15.9 

5, ••••,, 

•.Traffics 

Calculated 

a Cancer 

.1*, Fatalities 

3.6 

3. 7 

3.6 

Total. 

.°, Transport ` 

:pose: ; ; „ 

persomremy, 

',9;bbo , 

°9,500, 

9%,"2001. 

9,100 

Linked: 

pr)oi*ed ; M9 

MRS (1.■1WPAAohdoCilo ,' 

:linkages; 'notapaoktjt: 

– „ MR,S:(15;000:MTU capacity , 

lii-nit;7nO,schedule: ; 

„ b ,=••• - • % 

ases 

Rennsitoryin 

iai1146% frxiakfrani*eaatiirs;100 6/0 rail from 

MRS•tb tiegin.;oikzieraficinS. ,,201 

,bMRS to begin:operatioQsin 2000 – 

MRS) 

Section Three: Sensitivity Analyses of Radiological 

and Non-radiological Factors 

To see how changes in certain assumptions would 

affect the results of the base case analyses, the Commission 

conducted "sensitivity analyses," as explained in Chapter 

Three. It examined the effects of linkages, transshipments 

among reactors, increased rail use from reactors, routing to 

avoid population centers, changing the theoretical location 

of the MRS, and rod consolidation at reactors. These factors have both radiological and non-radiological 

implications. 

A. Linkages 

Provisions in the Nuclear Waste Policy Amendments 

Act (NWPAA) link the schedule for developing an MRS to 

progress on developing the repository. The linkages restrict 

the MRS schedule so that the MRS could begin operating 

no earlier than three years before the repository begins operating. The linkages also limit the MRS's capacity to 

10,000 MTU before the repository's opening and 15,000 

MTU thereafter. 

Table 5.4 shows the effects of these schedule linkages 

and capacity constraints—separately and combined—on 

transportation risks. They show the changes in estimated 

radiological dose and non-radiological (traffic accident) 

fatalities. 

Table 5.4 shows that linkages have little effect on 

transportation risk, either radiological or non-radiological. 

The estimated doses vary in range from a low of 9,000 

person-rem to a high of 9,500 a change of less than 8 percent. The traffic fatality differences are even smaller. Lifecycle traffic fatality estimates range from 15.3 to 15.9—a 

change of less than 5 percent. The differences are small because in all cases all spent fuel must ultimately be moved 

to the repository. 

B. Intrautility Transshipment 

Intrautility transshipment was analyzed for its effects 

on system safety performance. The effects on transportation risks were estimated to be small. (See Table 5.5.) 

In the No-MRS case, transshipment would provide an 

opportunity for reactors with truck access only to ship to 

54 

7 3 9 
til Ette6ii O'f Transshipment on Life'rqdle: 

Transportation Risk 

'Repository in'2013— § (54%!rail/46% truck froni`readters; 100% raiUfrerit MRS) 

No-MRS 12,000 

Transshipment 

:n4i=ts.201 Oa 

MRS 2616a 

Transshipment 

15.6 

15:3 .• 

15.4 

3.8 

'?.* 

ex rqn t. 

NWPAA schedule linkage's; no Ce0aCitjr:lirnitS, 

',Unlinked (No schedUle linkageS no capacity irnitS) 7

Traffic 

Fatalities 

TOtal: 

:Ransport, Dose 

(person-rem ' 

Calculated 

..40ooci.‘„ 

Fatalities: 

reactor sites (owned by the same utility) having rail access 

and take advantage of the greater transportation efficiency 

for the eventual trips to the repository. In this case, transshipment would reduce total truck miles and increase rail 

miles slightly. The effect is to reduce dose and increase 

traffic fatalities very slightly. With an MRS in the system, 

transshipment plays a lesser role with respect to transport 

efficiency resulting in smaller differences in doses. 

C. Increased Rail Transport from Reactors 

Most cases analyzed in this chapter follow the assumptions in the DOE transportation system study about 

use of rail service from reactor sites: 54 percent of the sites 

have rail access, and for those which ship by rail, fuel is 

shipped in three-cask dedicated trains. 

Assumptions about both the mode mix (proportion of 

trains and trucks) and the number of casks per train can be 

varied. Section One, Part B analyzed the dose in a case in 

which all reactors were assumed to have ready access to 

rail service and all spent fuel was transported 100 percent 

by rail. Even in this extreme case, the decrease in transport 

radiological risk was small: the dose changed from 12,200 

person-rem for the No-MRS case to 4,300 person-rem for 

the 100 percent rail case with dual-purpose casks (Table 

5.1). Section Two showed that traffic fatalities remained 

virtually the same despite variations in mode mix." 

D. Population Avoidance Routing 

It has been proposed that transportation routes be chosen to avoid population centers to minimize the number of 

people exposed." Avoiding population centers of certain 

sizes (for example, 500,000 or greater) would not necessarily minimize the total number of people exposed along 

the entire route. A direct route near or through some large 

population centers might actually expose fewer people during the whole trip than a longer, more circuitous route 

avoiding those centers; for example, the longer trip could, 

to avoid one center of 500,000 people, go through three 

centers of 400,000 people each. 

The routing rationale used in this study is the Department of Transportation's (DOT) highway routing rule for 

trucks and an analogous one for rail. There is no Federal 

55 
•,4•3 , %. 

ases: 

:Traffic 

i Fatalities, 

CalCOla'ted, 

Cancer : 

Total..' 

Transport; 

Dose.: 

(person `rem) 

'EaSterkMI. ,500,– A 

° ° A 

.„, 

Table 5.6—jEffects of MRS Location;on Life,cycle 

ransportatiori Ris 

). • ,,,,,, ,,,,,,, 9 , 

2013;,mRs in 20w 

54% riiI/46% truck from - reactors;:106% rail from f MRS) 

, • , ^ • , • • , ^ ,,,,,,, • • , 

•• • ,,,,,, r • 

•. 

A. C entral MRS ° '10;500 – " '" 

E in I i< e`a ''( ■1O.:SchedLile:lihkadeho capacity 

^ ,^ • %.• • 

• 

routing standard for rail (see Appendix J). The DOT high 

way routing standards do not require that trucks avoid population centers. They only require that trucks use the Interstate System bypass or beltway when available.' 5The 

Commission defers to DOT's expertise in highway routing. 

To test the population-avoidance concept for rail, the 

Commission developed a No-MRS, 100 percent rail case 

which avoids population centers of 500,000 people or 

more. The result is that travel would increase from the 7.8 

million train-miles of the previous 100 percent rail case to 

9.1 million train-miles. Radiation dose estimates would remain virtually unchanged at 4,300 person-rem; however, 

estimated traffic fatalities would increase from 15.5 to 

18.2. Therefore, this variation does not appear to reduce the 

already low transportation risks, and may slightly increase 

them. 

E. MRS Location 

Recommending a site for an MRS is outside the Commission's charge. For analytical purposes, the MRS was assumed to be located at a theoretical (generic) site in the 

Eastern United States identified by an averaging method 

described in Appendix G. To test the effects of the MRS location on transportation risks, the location of the MRS was 

changed to a generic central U.S. site. The results show little change in risk as a result of a change in MRS location 

(see Table 5.6). 

The slight increase in radiological risk for the central 

MRS case is attributable to an increase in truck shipmentmiles: from 16 million to 25 million. The slight decrease in 

traffic fatality estimates is due principally to a reduction in 

the miles traveled from the MRS, since a centrally-located 

MRS would be closer to the proposed western-located repository than an eastern-located MRS would be. In the extreme case, if the MRS were located at the repository site, 

the transportation risk would be the same as the No-MRS 

case, since all spent fuel must move from the reactors to 

the repository site in both cases. 

F. At-reactor Rod Consolidation 

If spent fuel rods are consolidated at a reactor, the reactor's spent fuel pool can store a greater quantity of spent 

fuel. Hence, at-reactor rod consolidation is an alternative to 

dry storage to increase interim storage capacity at some reactors. To test how using rod consolidation might affect 

transportation risks, the Commission analyzed a No-MRS, 

at-reactor consolidation case. About 50 percent of the reactors would have the capability to consolidate. 16This case 

assumed that these reactors would consolidate fuel to the 

end of their operating lives. Truck cask capacity 

(3PWR/7BWR assemblies) was not increased to take advantage of the reduced volume of the consolidated assemblies because the 80,000-pound gross vehicle weight legal 

limit for trucks would be exceeded. That is, the case of 

using overweight trucks—with its permitting and other institutional issues—was not modeled. (For a discussion of 

overweight truck issues, see Appendix J.) Rail cask capacity was, in effect, doubled. Since rail shipments contribute 

little to radiological dose, consolidation had limited effect 

on overall transportation dose (Table 5.7). Reduction of the 

56 

7 0 1 0 0 0 
Traffic 

Fatalities 

15.5 

10.8 

Calculated 

Cancer 

Fatalities 

4.9 

4.3 

Table 5.7-Effects of At-reactor Rod Consolidation 

on Life-cycle Transportation Risk 

Cases 

'Consolidation at 50% of 

reactors , 

Repository in 2013; No-MRS 

(54% rail/46% truck from reactors) 

Total 

Transport 

Dose 

(person-rem ) 

12,200 

10,800 - 

number of rail shipments needed, however, lowered the 

traffic fatality estimate from over 15 to under 11. 

G. Findings 

The Commission finds that estimates of transport 

risks would remain low in all variations on the base 

cases, and the differences among the realistic options 

are small. These differences should play no discriminating role in determining the need for an MRS. The theoretical 100 percent rail No-MRS case had the lowest 

transport dose estimate, partly because the model's unit 

dose rates are much lower for rail than truck. 

Section Four: Findings 

The Commission finds that transportation risks—

both radiological and non-radiological—associated with 

all of the spent fuel management alternatives are small 

and are not discriminating in the determination of the 

need for an MRS. Further, because the risks are small, 

apparent differences in results arising from the use of 

different assumptions, whether they pertain to transportation mode split or the role of special casks, are 

equally non-discriminating in the decision-making. 

This finding is in accord with the results of other 

studies, although the numbers may differ. Before undertaking these analyses, the Commission conducted a 

review and critique of transportation and siting-related 

studies by the Department of Energy and the State of 

Tennessee, directly addressing the need for an MRS. 17 

These studies also found that transportation risks are 

small. Indeed, the Commission agrees with both the 

current position of DOE 18and the conclusion of the 

University of Tennessee" that these small risks should 

not be a discriminating factor in determining the need 

for an MRS. 

57 
Chapter Five Notes 

1.ICF Technology Inc., "Transportation Impacts of the Federal Waste Management System," October 1989 (Hereafter cited 

as ICF, Transportation Impacts). 

2. For example, for the No-MRS case in Table 5.1, of the 

7,900 person-rem in-transit dose in the No-MRS case, only 70 

person-rem are attributable to accidents. 

3. Office of Transportation Systems and Planning, Battelle 

Nuclear Systems Group, "MRS Systems Study, Task F: Transportation Impacts of a Monitored Retrievable Storage Facility," May 

1989 (Hereafter cited as Task F), p. 15. 

4. Only 56 percent of the reactors are assumed to have rail 

access. 

5. McSweeney, T.I., Office of Transportation Systems and 

Planning, Battelle Nuclear Systems Group, personal communication Sherwood C. Chu, MRS Review Commission staff, August 

24, 1989. 

6. ICF, Transportation Impacts, Section 7.0. 

7. ICF Technology Incorporated, "Historical MRS Siting and 

Transportation Studies: A Review and Analysis," June 1989 

(Hereafter cited as ICF, Historical Transportation Studies). 

8. Hoskins, Raymond E., "A Systems Evaluation of the 

High-Level Nuclear Waste Management System Based on Integration of Dual Purpose Cask into the System as an Alternative to 

DOE's Proposed Monitored Retrievable Storage Facility as Integral Part of the System," June 30, 1989. 

9. It is NRC's practice to recertify transport casks at fiveyear intervals. 

10.Department of Transportation, Federal Highway Administration, John Grimm, Director, Office of Motor Carrier Information Management And Analysis, personal communication 

Sherwood C. Chu, MRS Review Commission staff, June 5, 1989. 

11.Department of Transportation, Federal Railroad Administration, "Accident/Incident Bulletin No. 156," July 1988, 

pp. 5, 16. 

12.Task F, p. 18. 

13.Radiological risk would not be affected by increasing the 

number of casks per train since dose is calculated on a per cask 

basis. Only non-radiological risk would be affected because there 

will be fewer train-miles traveled from the reactors. If five casks 

were shipped per train from reactors instead of three, each million 

train-miles of three-cask trains traveled would be reduced to 

600,000 train-miles. The fatality rate for trains is about two per 

million train-miles, so the fatality rate would be lowered by 0.8 of 

one fatality. For the cases studied, rail travel ranged from 2.3 to 

7.8 million miles in three-cask trains. If five-cask trains were used 

throughout, the reduction in estimated traffic accident fatalities for 

the cases analyzed would be in the range of 1.8 to 6.2 fatalities for 

the life-cycle of the whole shipping campaign. 

14.Hamilton, William, Manager, Nuclear Waste Department, 

Westinghouse Electric Corporation, Transcript of Monitored Retrievable Storage Review Commission Public Hearings (Hereafter cited as Hearings Transcript), December 1, 1988, p. 45; 

Massaro, Tony, Director of Environmental Affairs, City and 

County of Denver, Colorado, Hearings Transcript, January 5, 

1989, p. 18. 

15.49 CFR 177.825(b). 

16.Ebasco, "Spent Fuel Storage Need and At-Reactor Capability Study," June 1989, Table 3.3. 

17.ICF, Historical Transportation Studies. 

18.Isaacs, Thomas H., Associate Director, External Relations and Policy, Office of Civilian Radioactive Waste Management, Department of Energy, "DOE Position on the Monitored 

Retrievable Storage (MRS) Facility," Prepared Remarks Before 

the Monitored Retrievable Storage Review Commission, May 25, 

1989, pp. 19-21. 

19.University of Tennessee, Transportation Center, "Monitored Retrievable Storage of Spent Nuclear Fuel: Transportation 

Studies," December 16, 1985, revised October 20, 1986, p. 48. 

58 

7 0 0 2 
Chapter Six 

Spent Fuel Management Costs 

This chapter analyzes the costs that would be incurred 

by the Department of Energy (DOE) and utilities that operate nuclear power plants if a monitored retrievable storage 

(MRS) facility were or were not part of the U.S. spent fuel 

management system. Section One explains the costs and 

defines terms used in this analysis. Section Two explains 

what data sources the analyses used and what differences in 

results are created by using one rather than another data 

source. Section Three analyzes the costs of the various 

spent fuel management alternatives examined by the MRS 

Review Commission and shows how the costs change with 

time. Section Four explains the effects of discounting. Section Five contains the Commission's findings. 

Section One: Background 

The costs this chapter discusses are those of managing 

all the spent fuel that has been or will be produced at existing U.S. nuclear power plants, from the time the fuel is 

discharged from the reactor to when it is emplaced in a 

repository. The study assumes that no more nuclear plants 

will be built in the United States. The basic unit of analysis 

is the "life-cycle cost" of the entire national spent fuel 

management and disposal system. It is called life-cycle because it refers to the entire time the spent fuel management 

program operates. 

Estimates of the time period required to emplace all 

the spent fuel in permanent geologic disposal vary somewhat with assumptions about how long existing reactors 

will operate, whether reactors' operating lives will be extended, whether reactors will shut down early, when reactors still under construction will become operational, and 

what system—MRS or not—is used to manage the spent 

fuel. However, this chapter's analyses assume that the last 

removal of spent fuel from an operating reactor core in the 

United States will take place in the year 2037 and that all 

spent fuel will have been emplaced in the repository by the 

year 2050 at the latest. 

Figure 6.1 and Table 6.1 illustrate where spent fuel 

would be stored from 1995 through 2045 if there were a 

linked MRS in the system in 2000 and a repository in 2003. 

Figure 6.2 and Table 6.2 illustrate where the same amount 

of fuel would be stored if there were no MRS and if a repository were delayed until the year 2013. Each figure 

shows how much fuel would be stored where in a given 

year. For example, Figure 6.1 shows that in the year 2015, 

if there were a linked MRS, a relatively small amount of 

fuel, only about 400 metric tons uranium (MTU), would be 

in dry storage at reactors, about 28,000 MTU in pool storage, 15,000 MTU in MRS storage, and about 28,000 MTU 

at the repository. For the same year, Figure 6.2 shows that, 

if there were no MRS, slightly more than 20,000 MTU 

would be in dry storage, almost 50,000 MTU in pool storage, and only 2,000 MTU at the repository. 

The cases these figures illustrate are two of the six 

principal cases analyzed in this chapter. The purpose of the 

analysis is to estimate how and why spent fuel storage and 

transportation costs will vary over time as the location of 

the spent fuel changes. As the two figures illustrate, the 

variation between sceparios can be quite large even though 

the total amount of spent fuel to be stored, transported, and 

disposed of remains the same. 

Some costs would be paid by the utilities directly and 

some by the Nuclear Waste Fund (NWF). The proportion 

each would pay also varies considerably among the cases 

this chapter analyzed. 

Under current law, utilities pay the costs of managing 

and storing spent fuel while it is stored at reactors. The cost 

of storing spent fuel at reactors includes the cost of reracking pools to increase their capacity and providing out-of59 

7 0 t* 
60 

7 02 `3 0 2 1 0 4 

Figure 6.1—Location of Spent Fuel, MRS in 2000. Repository in 2003a•b 

MRS 2000. Repository 2003 

Thousands of MTU 

11111 1111•1411 

20 —tam/ Al.. ilik# 0 41::P 4111ffi► 47/ 

0 1 1 i r 1 i r c 1 

1995 2000 2005 2010 2015 2020 2025 2030 2035 2040 2045 

Dry Storage IMMRS Storage MI Pool Storage Repository 

One 87.000 MTU repository 

aSource: WACUM Simulator Model 

bData given in Table 6.1. 

100 

80 — 

60 — 

40— 

Table 6.1—Location of Spent Fuel, MRS in 2000, Repository in 2003 a b 

YEAR 

DRY STORAGE 

AT-REACTORS 

1995 1,286 

2000 3,194 

2005 3,562 

2010 2,351 

2015 422 

2020 174 

2025 201 

2030 0 

2035 0 

2040 0 

2045 0 

:Source: WACUM Simulator. 

Shown graphically in Figure 6.1. 

POOL 

MRS STORAGE 

STORAGE AT-REACTORS REPOSITORY 

0 29,860 0 

2,000 36,125 0 

12,099 33,273 2,000 

15,000 30,157 12,787 

15,000 27,862 27,786 

15,000 19,516 42.785 

15,000 10,737 57.784 

9.768 3,592 72,784 

2.308 543 83,783 

0 148 86,607 

0 0 86,756 
7 0 2 3 0 2 1 0 5 

100 

80 - 

60 - 

Figure 6.2—Location of Spent Fuel, No-MRS. Repository in 2013" 

No—MRS, Repository in 2013 

40 - 

AlOF IMPdiMPT111111111111111E•7 20 - 

/Nor / 

0 

1995 2000 2005 2010 2015 2020 2025 2030 2035 2040 2045 

Dry Storage I-1 MRS Storage Pool Storage MN Repository 

One 87,040 MTU repository 

aSource: WACUM Simulator Model 

bData given in Table 6.2, 

Table 6.2—Location of Spent Fuel, No-MRS, Repository in 20138 6 

YEAR 

DRY STORAGE 

AT-REACTORS 

POOL 

MRS STORAGE 

STORAGE AT-REACTORS REPOSITORY 

1995 1,286 28.680 0 

2000 3,711 36,807 0 

2005 8,019 42,026 0 

2010 13,932 46,362 0 

2015 20,007 49,914 1,149 

2020 20,819 43,857 12,798 

2025 19,208 36,799 27,715 

2030 15,459 28.037 45,644 

2035 8,311 20.438 57,596 

2040 1,048 13,272 72,436 

2045 0 0 86,756 

'Source: WACUM Simulator. 

uShown graphically in Figure 6.2, 

I 

61 
pool dry storage if necessary. If a repository or an MRS 

were not operating or did not have adequate capacity, spent 

fuel stored at shutdown reactors would have to remain 

there. In this case, the utility would incur considerably 

more expense for spent fuel management and security than 

if the spent fuel could be removed and responsibility for it 

turned over to the Department of Energy. DOE analyses do 

not include these costs as a component of at-reactor costs, 

but the Commission believes these costs are a legitimate 

component of total system cost and should be considered in 

evaluating the need for an MRS facility. 

After spent fuel leaves the reactor site, costs are to be 

paid from the federally administered Nuclear Waste Fund 

(NWF). The NWF pays the costs of: transporting spent fuel 

from reactors to the repository and, if it exists, the MRS; 

building and operating the repository and MRS; funding all 

of DOE's research and development to support the design 

of the national nuclear waste management and disposal 

system; benefit payments to State governments or Indian 

Tribes; and the department's expenses to administer the national nuclear waste program. 

Utilities are required to pay into the NWF one mill per 

net kilowatt-hour of electricity they generate from nuclear 

sources. This fee is treated as an operating expense and 

passed on to consumers through the utilities' rates. At-reactor storage costs incurred directly by utilities are also passed on to ratepayers, but some utilities may have to pay 

considerably more than others for this storage. For example, a utility operating a new reactor with a large pool 

might incur little extra expense if the repository were delayed and an MRS were not available, as in the case illustrated in Figure 6.2, while a utility operating an older reactor with a smaller pool might have to add substantial 

amounts of dry storage in the same circumstances. The distribution of system costs is discussed in Chapter Seven. 

Section Two: Cost Estimate Data Sources and Differences 

The cost analyses in this chapter are based on several 

data bases. Each data base has its uses and limitations. This 

section explains the data sources, then explains the differences among them. 

A. Data Sources 

The primary data sources for this chapter are DOE's 

Total-System Life-Cycle Cost (TSLCC)' and a data base 

and a model developed for the Commission—the Interim 

Spent Fuel Management Cost Data Base (ISFM) and The 

Nuclear WAste Cost Data Base and SimUlation Model 

(WACUM). 

1. DOE Cost Analyses 

a. TSLCC 

Annually since 1983, the Department of Energy has 

estimated the national nuclear waste management and 

disposal system's life-cycle costs and has reported them 

in the Total-System Life-Cycle Cost Report (TSLCC). 

DOE's purpose in doing so is to determine whether or not 

the fee levied on nuclear-generated electricity and paid into 

the NWF will produce enough revenue to pay for the projected costs of the system over its lifetime. Table 6.3 lists 

the estimates made each year in this Total-System LifeCycle Cost Report. 

The estimates change from year to year because of 

changes in: (1) the configuration and components of the 

system being costed, (2) assumptions about when system 

components would become operational, and (3) assumptions about how much waste would be created. There have 

been significant changes in each assumption since 1983. 2 

The 1983-1987 estimates in Table 6.3 are given in 

ranges, because, before the Nuclear Waste Policy Amendments Act of 1987 (NWPAA), DOE was estimating costs 

for characterizing three sites for the first repository. Thus, 

the total cost varied according to which of three repository 

sites was used, and DOE provided a range to reflect that 

fact. The single value shown for 1988 reflects the fact that 

the NWPAA directed DOE to characterize only the Yucca 

Mountain site. 

In the system studies 3(see below), prepared by DOE 

for the Commission, and in the 1989 TSLCC report, DOE 

discussed two major modifications to previous system designs, both of which have major cost implications. The first 

is the substitution of a "basic" MRS, which would limit its 

services essentially to storing intact spent fuel, in place of 

the earlier proposal for a "fully integrated" MRS, which 

would have consolidated and packaged spent fuel. In a 

two-repository system, such as the one the Nuclear Waste 

Policy Act of 1982 envisioned, the MRS would service 

only the first repository, with the second repository receiving spent fuel directly from the reactors. DOE believes that 

building a basic, rather than integrated, MRS would reduce 

an MRS facility's estimated cost from $3.1 billion to $1.8 

billion for a one-repository system and from $2.3 billion to 

62 
Table 6.1—Comparison of Historical Total-system Life-cycle Cost Estimates 

Year6f Estimate 

Range of Estimate in Billions of 

Current Dollars` 

Range of Estimate in Billions of 

Constant 1988 Dollars 

1483 ; 19 3 to 19.8 23,7 to 24.3 

1984: 20.9` to 24.4 24.7 to 28.8 

:1985 ‘, 23,816. 29:7 27.1 to 33.8 

1986 28,216 34.0 28.9 to 37.4 

1987 32.1 to 38.2 34.5 to 41.0 

1988. 11 32.0 32.0 

° aSouiCe: Department of Energy;, t'APalysie of the TotakSyStem Life-Cycle Cost for the Civilian Radioactive 

Waste'MariageMent PrograMJDOE/f3W-0236; May 1989, p. - 1-11. 

izInClUdes,onlV cost paid by the Federal;government from the Nuclear Waste Fund; utilities' cost for at-

, reactor storage are not inCluded." 

'cCOrrent'dollars are;`dollars" ofthe prior to the year of the estimate, i e ,the 1983 estimate reflects 

prices prevailing in :1982,'etc, except for 1988 Which uses 1988 dollars because the report was not issued until 

. 

,4The 1 988 estimate was Maga tor systemintluding a packaging MRS and two repositories. The range in a 

the"pre-Vipus years was the of a range for development and evaluation (D&E) and repository costs 

"reflecting:the charatterilation of three repositories in:different geologic media. The 1988 estimate reflects 

the Nuclear; Waste policy•ATiOdnient Act (NWPAA) directing DOE to characterize only one repository at 

'Yucca MOuntain: ' ' • " 

$1.4 billion in the two-repository case. 4The second major 

change reflected in the 1989 TSLCC report involves building one repository rather than two. DOE estimates that this 

change would reduce the estimated total system cost by 

$7.3 billion.5The 1989 estimate in Table 6.3 is based on a 

two-repository, "packaging" MRS to be comparable with 

earlier years' estimates. If a basic MRS with only one repository were used instead, the total system cost would 

drop to $23.8 billion. 6In this analysis, the Commission 

used the basic MRS and a one-repository system as the basis for comparing alternatives. 

Although detailed in design and well documented and 

rigorous in its analysis, the TSLCC report was of limited 

use in analyzing the economic aspects of the charge that 

Congress gave to the MRS Review Commission. The 

TSLCC report's focus is largely limited to DOE's current 

program strategy, which does not include the No-MRS alternative. The Commission was required to evaluate DOE's 

strategy as well as the principal alternatives to it, specifically the No-MRS alternative. Further, the TSLCC Report 

rests on "a single set of engineering assumptions" and thus 

does not provide an adequate basis for analyzing the uncertainty in the cost estimates evident in the year-to-year variations observable in Table 6.3. 7 

b. System Studies 

DOE's system studies include a wider range of alternatives. The studies were based on some 90 different cases, 

corresponding to different system configurations and 

schedules, but all of the cases were based on the same set 

of engineering cost estimates. Hence, DOE's analysis of 

the uncertainty inherent in the cost estimates is limited; 

moreover, DOE did not consider delays in the repository 

program beyond the year 2013. 

2. Commission Analytical Tools 

Because of the DOE studies' limitations and the record of significant increases in the estimates of the total 

program costs, the Commission conducted an independent 

survey of existing cost estimates and developed its own analytical tools, a data base and a simulation model, to analyze their uncertainty. 

63 
a. The Interim Spent Fuel Management Cost Data 

Base (ISFM) 

The ISFM has two parts: (1) a historical data base 

which summarizes previous cost estimates and (2) a probabilistic data base that was derived from a panel of experts 

who reviewed the historical data base and estimated a probability distribution for each principal cost in a subjective 

but structured manner. 8 

The costs were organized into 90 "accounts" defined 

so they could be used as input data in the WACUM cost 

simulation model described below. An account can be understood as a discrete cost-incurring activity in the spent 

fuel management system, such as reracking pools, unloading casks, or making benefit payments to States or Indian 

Tribes. 

To define the probabilistic data base, the experts met 

as a group. After being trained in probabilistic cost estimation, the group developed a probability distribution for each 

of the 90 cost accounts in the probabilistic version of the 

ISFM cost data base. 9Although the group used the historical estimates that had been made by DOE and others as a 

point of departure, their goal was to forecast a range for the 

degree of uncertainty in these costs for each account. The 

principal reasons for uncertainty are that the technology is 

still being developed; the estimates have to extend 40 or 50 

years into the future; the regulations are still evolving; and 

legislation may change. 

b. The Nuclear WAste Cost Data Base and SimUlation Model (WACUM) 

WACUM was developed to estimate the spent fuel 

management and disposal system's costs under a variety of 

possible cases. It was designed to use the ISFM cost accounts to analyze the uncertainty associated with the costs 

of various system elements, including the MRS construction and operation. 1 ° WACUM constructs a "requirements 

file" that indicates how large or small various system parts 

would have to be—for example, MRS capacity, how many 

casks are needed for at-reactor storage, and for how long 

the facilities in the system will have to operate. Then the 

model combines the requirements file with the data base to 

estimate the total system cost for different assumptions 

about what the composition of the system would be, e.g., 

whether it would include an MRS and when the repository 

would begin to operate. WACUM allows the user to choose 

among three pick-up rules: oldest fuel first (OFF), which 

was used in the DOE studies;" oldest fuel first from storage pools which are full (FUL), and oldest fuel first from 

pools which are full and have been reracked (RRK). 12 

The MRS Review Commission's Analysis of System 

Risk and Cost (MARC) network optimization model (described in Chapter Three) also can be used to analyze costs 

and has been used to analyze various alternatives. The 

analysis in this chapter relies primarily on the WACUM 

model and the ISFM data base, but the relationship between the costs of the cases analyzed is the same whether 

the WACUM or MARC costs are used. 

B. Data Differences 

Table 6.4 compares cost estimates prepared for the 

Commission by DOE to the Commission's WACUM estimates. 13With two exceptions, DOE's estimates use the 

same cost assumptions and estimating methods as the DOE 

system studies and TSLCC report. They assume a single 

repository and the same'repository and MRS schedules 

used in the Commission's cases. Total costs and component 

costs (parts of the total cost, such as at-reactor costs) for 

three cases and three schedules are shown. 

The apparent correlation between the total cost estimates suggests more similarity between the DOE and 

WACUM estimates than a comparison of the individual 

cost components justifies. Significant differences between 

the two estimates are the result of differences among the 

types of costs included, the basic assumptions used, and the 

estimation methods used. 

1. Assumptions and Inclusions 

a. Totals 

DOE included in its estimates the costs of processing 

high-level defense wastes as well as civilian wastes; 

WACUM estimated only civilian waste costs. If defense 

wastes had been included, the WACUM totals would be 

about 10 percent higher. 14 

b. At-reactor Storage Costs 

Another major source of difference between the estimates is apparent in the treatment of at-reactor storage 

costs. The costs of acquiring and servicing dry storage facilities comprise most of DOE's estimated at-reactor storage costs, while WACUM includes a considerably wider 

range of costs in this category. The WACUM estimates include the costs of reracking pools, loading and unloading 

casks, and all necessary at-reactor infrastructure, as well as, 

most important, the costs incurred by delaying the removal 

of spent fuel from shutdown reactors. DOE discusses the 

costs of delaying the removal of spent fuel from shutdown 

reactors in the Task G Report of the system studies, but 

does not incorporate them into its estimates of total system 

costs. 15 

As illustrated in Table 6.4, which shows the costs of 

delaying the removal of spent fuel from shutdown reactors 

in brackets under total at-reactor costs, 16the shutdown reactor costs become substantial in cases in which the reposi64 

7 0 
Table 6A--Comparison of WACUM and DOE Total-system 

Life-cycle Cost Estimates ° b 

(Billions of Constant 1989 Dollars) 

YEAR 

REPOSITORY STARTS NO-MRS LINKED MRS' UNLINKED MRS' 

WACUM DOE WACUM 

23.0 .26.9 

0.9 1.2 

NI' . ' [0.5] 

9.7 9.8 

2.4 3:7 

9.6 9.7 

2.5 

2013 

TOTAL 26:6 

At-Reactor 5. 1 

[Shutdown Reactors] [2.7] 

Development & Evaluation 9.0 

Transportation 3.3 

Repository 9.2 

MRS 

Benefits' 

2023 

TOTAL 28.0 27.9 29.5 

' .At-Reactor '. 6.6 2.3 - 5.9 , 

[Shutdown Reactors] [3.6] NI , [3.0] 

Development & Evaluation 9.0 , 13.7 9.6 - 

° Transportation 2.9 2.3 2.9 

Repository° 9.4 9.2 94 

MRS , 1 7 

Benefits 0.4 

DOE WACUM DOE 

, 25.2 27.0 25.2e 

• 0.4 0.9 0.4 

NI [0.2] NI 

• 

10.1 9.8 10.1 

2.7 3.8 2.7 

9.4 9.7 9.4 

1.9 2.8 1.9 

0.7 0.7 

27.8 26.7 27.4 

1.5 1.1 0.4 

NI [0.3] NI 

12.3 9.8 12.0 

2.5 3.3 2.7 

9.1 9.2 9,1 

1.7 3.2 2.4 

0.7 - 0.7 

30.1 27.2 30.0 

2.3. 1.4 0.4 

NI [0.5] NI 

14.3 9.9 13.8 

2.6 2.8 2.8 

9.1 9.4 9.1 

1.7 3.7 3.1 

0.6 0.7 

2003 

TOTAL 24.8 

Ai-Reactor :2.3 

[Shutdown Reactors] [1.2] 

Development & Evaluation 9.0 „ 

Transportation 3.7 

Repository' 9.7 

MRS 

Benefits 

•• 'Estimates were supplied by DOE. at the Commission's request for these cases. WACUM estimates were 

made with the WACUM cost simulator.. See Appendix d acceptance schedules. 

'DOE estimates were made in 1988 dollars. They were converted to 1989 dollars by means of the implicit 

GNPcprice deflator, as:explained, in Note 13, Chapter 6. • • . ° • 

. MRS is assumed: to open three years before the repository and is ,subject to a 15,000 MTU capacity limit 

per NWPAA. 

MRS is assumed to• begin operating in the year 2000,.without a capacity limit. 

'DOE's estimates for the unlinked MRS in 2000 are the same as those for the linked MRS. 

Cost of delaying the rem,oval•of spent fuel from shutdown reactors, included in at-reactor components. 

'°Ooth estimates based single repository. :WACUM assumes. an efficient (RRK) pick-up rule is used in 

which fuel is picked udfirstfrom reactors that are full anClhave.been reracked, then from full reactors and then 

° :reverts to the oldest fuel fir‘st rule.• .DoE assUrnes,the oldest fuel first pick-up rule. 

•I'inbluded in the roptisitory and/or MRS account in the WACUM estimates. • NI indicates not included. • 

25.7 

2.0 

NI 

11.8 

2.3 

9.2 

27.9 

3.7 

[1.3] 

9.7 

3.3 

9.2 

2.1 

65 

7 01•.; 0 2 9 
tory is significantly delayed and an MRS with sufficient capacity to accept the fuel is not available. In the extreme 

case, in which the repository does not open until the year 

2023, the shutdown reactor costs would add $3.6 billion to 

the total system costs of a No-MRS case but would amount 

to only $0.5 billion if an unlinked MRS had been operating 

since 2000. If these costs were not included in the Commission's estimates of at-reactor storage costs, the estimate 

would come much closer to DOE's, but the difference between the total system cost estimates, in most cases, would 

grow rather than shrink." Shutdown reactor costs are included in the WACUM estimates but not in those made by 

DOE. As the repository is delayed, this difference is the 

principal reason why the No-MRS alternative becomes 

more expensive than the unlinked MRS case in the 

WACUM estimates, but remains less expensive in the 

DOE estimates. 

The differences between at-reactor storage estimates 

also are partly attributable to the different pick-up rules. 

DOE used the oldest fuel first pick-up rule, and WACUM 

used the more economically efficient RRK pick-up rule described in Section Two, Part A.2, above. The oldest 2fuelfirst pick-up rule is inefficient because older fuel may be 

picked up from reactors with in-pool storage capacity before fuel can be picked up from reactors with full pools 

which must put spent fuel in dry storage. Thus, more expense is incurred for dry storage than an efficient pick-up 

rule would incur. Using a more economically efficient 

pick-up rule reduces at-reactor storage cost about ten percent, but this reduction translates into a much smaller reduction in total system costs since this cost category 

comprises a relatively small part of the total. 

c. Development and Evaluation Costs 

Development and evaluation (D&E) costs are also a 

significant source of difference in Table 6.4 in the delayed 

repository cases. The panel of analysts which created the 

ISFM data base for the WACUM model did not attempt to 

establish a probability distribution for these costs. The information available at the time reflected the parallel characterization mandate calling for DOE to ascertain the 

suitability of three repository sites simultaneously, rather 

than making the sequential characterization mandated by 

the NWPAA, which directed DOE to characterize only the 

Yucca Mountain, Nevada site. Since most costs in this category are related to the repository, the panel did not believe 

it had adequate information to establish a meaningful probability distribution for D&E costs. Hence, in the WACUM 

model, D&E costs are held essentially constant at the level 

of the DOE estimate for the repository in the year 2003 

case. D&E costs for the MRS and the transportation system 

are included or excluded as appropriate for the case being 

analyzed. 

DOE assumes that D&E costs will continue to accumulate if the repository is delayed and, when the delay is 

considerable, this creates a significant difference between 

the two estimates. If the D&E costs in the WACUM estimates were to be escalated at the same rate observed in the 

DOE estimates for the cases in which the repository is assumed to be delayed, the WACUM total cost estimate 

would increase by approximately 15 percent. 18 

2. Treatment of Uncertainty 

The WACUM estimates, described in Section Two, 

Part A.2.b, were made with the probabilistic or encoded 

version of the ISFM cost data base. DOE's estimates usually include a 20 to 40 percent contingency, but they are 

based on today's best engineering judgment of what it 

would cost to build or operate the cost component in 

question. 

Since the WACUM estimates explicitly focus on uncertainty in cost and since the uncertainty involved in some 

system elements is so great, the WACUM estimates tend to 

be higher than the DOE estimates for many of the system's 

individual cost accounts. For example, the repository cost 

component in Table 6.4 is derived from ISFM data for several accounts, a major one being the cost of the waste package. WACUM's "expected" or average value of the 

probability distribution, derived from the ISFM data base, 

for the cost of an individual disposal waste package is 

$73,000. This is more than twice as high as the DOE's 

$31,000 estimate. However, the modal, or "most likely," 

value, in the judgment of those making the estimates for 

the ISFM data base, was $45,000 per package, which is 

higher than but much closer to DOE's estimate. The reason 

the average or "expected" value of the probability distribution is higher than the modal or "most likely" value is that 

those persons who encoded the data base assigned a "maximum," or 90 percent, value of $150,000 per waste package. They assigned this value because they believed there 

was a great deal of uncertainty about the materials and 

technology that eventually might be required to meet the 

repository license requirements. As a consequence, the 

average or expected value of the probability distribution is 

"pulled" considerably above the modal value. 

The State of Tennessee's cost analyses also use a 

probabilistic approach, which, although different from the 

one used to construct the ISFM data base for WACUM, 

also yields higher estimates than DOE's analysis.' 9This 

basic difference in the approach to cost estimating is most 

relevant in explaining the differences in the estimates of 

the costs of the repository and the MRS facility, where 

66 

7 0 2 0 
the development of new technologies and the consequences 

of evolving regulatory and licensing issues are most 

prevalent. 

Table 6.5 shows the probability distributions for the 

totals and cost components for the same three cases (NoMRS, linked MRS, unlinked MRS) and repository start 

schedules (2003, 2013, 2023) used in Table 6.4. The total 

costs are the underlined numbers in each column. The 

probability levels were estimated by WACUM, using 

Monte Carlo simulation. 2° This technique uses a large 

number of iterations to construct a distribution describing 

the probability that the System's total costs and its components will fall above or below a particular value. Individual 

cost account values are selected for inclusion in a particular 

iteration based on the probability they were assigned in the 

encoded data base. That is, about 10 percent of the time the 

minimum value for an individual cost account will be included in an individual iteration and about 10 percent of 

the time the maximum or 90 percent value will be included. Eighty percent of the time the average value (EV) is selected. The figure's three columns, 10 percent, EV, and 90 

percent contain values in billions of constant 1989 dollars. 

The EV column in Table 6.5 is the same as the WACUM 

column in Table 6.4. The percentages have the same meaning as explained in Section Two, Part A.2, above. 

The uncertainty in the estimates for the 90 individual 

cost accounts is reflected in the very wide range between 

the 10 and 90 percent levels for the totals. The wider the 

individual cost account ranges, the wider the distribution 

ranges for the totals. The breadth of the range might suggest extreme uncertainty but it might be noted that the difference between the initial cost estimates and final cost of 

completion for most large nuclear facilities is much greater 

than the range in Table 6.5. For every case analyzed, the 

expected value of the total system costs is within the range 

estimated for every other case, although the overlap is quite 

small in the case of the lowest cost case (No-MRS, repository in 2003) and the highest cost case (linked MRS in 

2020, repository in 2023); the expected value of $24.8 

billion in the No-MRS, repository in 2003 case barely 

exceeds the $24.0 billion lower limit in the linked MRS in 

2020, repository in 2023 case. 

Considerably more disparity is evident in some of the 

cost components. The low end of the range for at-reactor 

costs in all three of the No-MRS cases exceeds the upper 

end of the range of the three unlinked MRS cases (shown 

in the far right column). In both cases in which the repository is delayed (the 2013 and 2023 panels), the expected 

value MRS costs in the linked strategy fall below the lower 

end of the range of MRS costs estimated for the unlinked 

MRS strategy. Since the same volume of spent fuel will 

have to be transported and emplaced in the repository in all 

cases, as might be expected, little variation is observed between the cost categories in the cases shown in the table. In 

general, however, the comparison of the expected values 

and the estimated ranges shows that uncertainty in the underlying cost data is so great that it is hard to be very 

confident that the differences observed in the estimates are 

significant. 

The DOE estimates, listed in Table 6.4, fall within the 

range projected by WACUM in Table 6.5, although, as the 

preceding discussion indicates, this may be more a function 

of averaging and off-setting assumptions than any sort of 

mutual validation of the two sets of estimates. 

These comparisons are not intended to show that one 

set of estimates is more "correct" or "accurate" than another. Using different data and methods to estimate the 

building and operating costs for first-of-a-kind facilities 

that probably will not be built until well into the next century should not be expected to result in closely comparable 

estimates. Rather, these comparisons are intended to illustrate the nature of the differences among the estimates and 

the degree of uncertainty inherent in them. 

Section Three: Cost Analysis 

Table 6.6 summarizes the estimated costs of three 

components of the spent fuel management and disposal 

system for some of the cases that the Commission evaluated. The first column, MRS Cost, includes the estimated 

costs for designing, constructing, and operating a storageonly or "basic" monitored retrievable storage facility, 

which does not package or consolidate spent fuel. The second column, Federal Cost, includes all cost estimates the 

Federal government would pay out of the Nuclear Waste 

Fund. Included are the cost of the MRS facility (in column 

1), the repository(ies), transportation, payments to States or 

local governments, and program management. The third 

column, At-reactor Cost, records the estimated costs for 

managing and storing spent fuel at reactors, paid for by 

utilities directly. The costs of delaying the removal of spent 

fuel from shutdown reactors are included as a component 

of at-reactor costs. As explained above, DOE does not include these costs in its estimates. The fourth column, Total 

67 
Table 6:5-Comparisons Of 19% and 90WProbabillty'LeVe s. 

For Total-system Life-cycle, Costs: Selected Cases 

f Billions Constant 1989 DPllara); 

.YEAR° :1° :!: ::: .:. 

„REE'OSITORY• " 

A :STARTS - • . 0=l MR844 :'::" . LlINKED',MRS:(NWPAA)`, - ;;'UNLINKED. MRS°, l,' 

„4:1:0%°: : :',.°,.;: EV:. l i 1190% i :4 „ ,. 10% 1,•1°:'', ", ',EV', ; :%: 4 ‘.,.'';90%:' 1: %- ' - "90%- 

° "'" ..... 

-ti-AL ::20:.0 l4 

At-Reactor ‘4. : 1.9 % ‘ • 

: :Development & ::NM 

EValOation‘• 

fransporta4 " ?.P4.:' 

tion 4 

Repository 7.0 l .: 

MRS ' 

2013 

TOTAL ' :22 2: ' 

At-Reactor : ll 4.6 , 

Development & , NM 

Evaluatibne ' 

Transporta- , l - 2.3 ' 

{ion 

RepoSitory 6.6 

MRS , , 

, . 

2023 1 

TOTAL 23.8. 

. At-Reactor . . -6.0... 

'Development&„ , " NM:• 

•EVatuatione l l • • 

..,Transporta- . 21 • 

: lion: • 

lepOsitbry :." ' 6:9 l 

MRS • • 

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2 ":8 

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° ° 3.7,. -,'; 

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- • .• 

•,..3..6,.: 

12.8 

.0°.', 

^14 ve 

,d4.0 ,,,,, ,,.4• ,.: ,•4 ■ ,, ,,.4.4. , ^^4, 

ticti3'' „ '., 

Sour6e;Table 6.4,laSSUMOS One:87;000 MP.) 'repository: and an veffiCierit:(FIRK) pick-up Tule: See: 

Appendix for accelotance:ph0c1010. °.: ' ,;: ;:: ° :‘ ' 

Based on a 500 iteration Monte Carlo SIMUlatiOn:Usinglthe WACUM bribodedldatAlbese.:"10%" Meane'therell‘ 

is a 0.:1 prObability the number Will be less than thevalue, VI:gated andl` .490%!: :means there is A 40.,.0‘.; 

number :will be less than the. Value iriditated::"EV%listhe'expected and.lthe mean Cf.the:probability; ° „ ,,,,,, .4„„ distribution : :4l ° " " " ,,, :MRS is to begin operations ,ti-free yepr$ before the repository. 

MRS is to begin operations ini:tne year 2000 and is.not 'subject tovan inventory 'Constraint: , 4 , •4 , 

A probability distribution was not estimated ljorlthe preponderance of coSt,4., reported in trfiS : lleategOry • thereibre a Monte Carlo simulation:would not yield meaningful results.' 

NM indicates not meaningful 

a 

68 

7 0 2 1 1 2 
Table 6.6-Comparison of Total-system Life-cycle Costs for 

Selected RepositOry Start Dates 

Billions of Constant 1989 Dollars) 

.,Panel One: Repository in 2003 

(1), 

'MRS COat 

(2) 

> Federal Cost 

(3) (4) 

At-reactor Cost Total Cost 

22:.5. • 2.3 24.8 

1.4ilked .MRS 2000, 2 25.7 1.2 26.9 

Orilir*et(MRS 1998' 2.9 26.3: 0.7 27.0 

t.hilihked:MRS 2000', : 26.1" . 0.9 27.0 

Panef,TWO:RepositOrylin 2013 

No MRS: 21.5 5.1 26.6 

Linked MRS 2010y 2.1 '24.2,, 3.7 27.9 

Unlinked MRS2000‘ 3. 2, -25.6 1.1 26.7 

Unlinked MRS 2008 2. 24.9 2.2 - 27.1 

Parie(thiee.:.AeO.OsitOry in 2023', 

• No-MRS sffi : • 21.4: 6.6 28.0 

Linked ;MRS .2020! •1•.7 23.6 5.9 29.5 

Uriltriked:MRS2000•. .3.7 25.8 1.4 27.2 

Unlinked14RS,201CY 

 • 

1 25.1 3.2 28.3 

Source: Table,6.4:, 

bThree-Vear'stfiedule linkage:and inventory limit of 15,000 MTU per NWPAA. 

:‘`.NO"inventorylOit 

Cost, contains estimates of the total system costs, the sum 

of columns 2 and 3. 

The table is divided into three panels. The first summarizes the estimates for cases that assume, in accordance 

with the Department of Energy's current goal, that a repository would be operational in 2003. Cases summarized in 

the second panel assume that a repository would be delayed 

until 2013, and those in the third assume it is delayed until 

2023. 

The cases summarized include No-MRS, a linked 

MRS, and an unlinked MRS system. 21The linked MRS is 

assumed to be linked as specified in the NWPAA, in which 

the MRS and repository schedules are linked, and the MRS 

inventory is limited to 15,000 MTU. 22The unlinked MRS 

systems analyzed here are constrained by neither schedule 

linkage nor inventory limit. 

Table 6.6 captures only a few of the parameters used 

to characterize spent fuel alternatives' cost. Additional fac69 

70 
tors could be varied to produce different cost estimates; for 

example, one could assume a variety of additional functions that could be performed at an MRS, phased construction of an MRS, whether or not spent fuel is consolidated, 

various MRS locations, alternative strategies for shipping 

fuel from western reactors, the use of dual-purpose or universal casks, whether one or two repositories are built, and 

alternative schedules for generating and accepting spent 

fuel. Some of these factors are discussed elsewhere in this 

report, but the analysis here considers only DOE's currently preferred alternative, the basic or storage-only MRS, 

under different assumptions about the timing of the repository. Table 6.6 illustrates how the costs of several spent 

fuel management alternatives would change as the repository start date is delayed and how changes in the date affect 

judgments about choices among alternatives. The principal 

points to notice are: 

• At-reactor storage costs increase if the repository is 

delayed. The most dramatic increase occurs after 

significant numbers of reactors reach the end of 

their operating lives and are shut down. Five years 

after a reactor is shut down, all fuel can be removed 

and significant security and spent fuel management 

costs can be avoided if an MRS or a repository is 

open and has adequate capacity to accept the fuel. 

• MRS costs increase if the repository were delayed 

and the facility is not linked to the repository. MRS 

costs increase because it must operate longer. 

• In the No-MRS case, the increase in at-reactor storage costs was less than the costs of adding an MRS 

to the system until many reactors reached the end of 

their operating lives and were shut down. If the repository is delayed beyond 2015, the costs of a NoMRS system and an unlinked MRS system that begins to accept fuel in 2000 become approximately 

the same measured in undiscounted dollars. 

The trade-off between increased at-reactor storage 

costs and the costs of including an MRS in the system is a 

principal determinant of the cost differences among alternative strategies. For example, in Panel One of Table 6.6, 

repository in 2003, at-reactor storage costs in the No-MRS 

case are estimated to be $1.4 billion more than the case in 

which an unlinked MRS would begin operating in 2000. 

However, the increased cost for at-reactor storage amounts 

to only 50 percent of the $2.8 billion required to add an 

MRS to the system. 

In Panel Two, repository in 2013, the difference between at-reactor costs in the No-MRS case and in the unlinked MRS available in 2000 is $4 billion, almost triple 

the difference for cases in 2003, and exceeding the $3.2 

billion it would cost to add the MRS to the system. Development and evaluation costs, however, are $0.8 billion 

lower ($9.8 billion minus $9.0 billion) in the No-MRS 

case, as can be seen in Table 6.4, so the total cost for the 

No-MRS system is still slightly below the cost for the MRS 

system. 

In Panel Three of Table 6.6, repository in 2023, additional at-reactor storage costs incurred in the No-MRS case 

exceed the cost of including an unlinked MRS available in 

2000 in the system, as well as the additional D&E costs, 

and the MRS system is less expensive than the No-MRS 

system. 

Comparisons between a No-MRS alternative and a 

linked MRS alternative show that the cost advantage of the 

No-MRS system persists in all the cases compared, with 

additional at-reactor storage costs always less than the cost 

of adding an MRS facility to the system. 

Although total costs do not vary greatly, even when 

considering quite extreme cases, the differences in the incidence and distribution of the cost components are significant. In the unlinked MRS case, the cost to be paid directly 

by utilities would be only a little more than 20 percent 

($1.1 billion / $5.1 billion) as much as it would be in a NoMRS system, in both the 2013 and the 2023 cases. It could 

be argued that since the Nuclear Waste Fund is derived 

from levies on nuclear-generated electricity, therefore paid 

for by the ratepayers of nuclear utilities, this fact is irrelevant. However, as was discussed previously, the distribution of at-reactor storage costs among utilities will vary 

quite significantly depending on their age and design. 

Moreover, from the perspective of the planning horizon 

used by the current management of utilities, the fee the 

utility must pay into the Nuclear Waste Fund is fixed by 

law, and the amount the utility will have to pay into the 

fund is largely outside the utility's direct control. Within 

this planning horizon, the proportion of the national spent 

fuel management and disposal system's costs which the 

Fund finances will not affect the utility's financial performance. However, utility-paid at-reactor storage costs will 

affect the utility's financial performance. Therefore, utilities have an economic incentive to favor spent fuel management alternatives that reduce at-reactor storage costs. 

0 

70 
Section Four: The Effects of Discounting 

A dollar received today is more valuable to an individual or the government than a dollar received a year from 

now. Conversely, a cost incurred a year from now is less 

onerous than a cost incurred today. The principle involved 

is simple: Abstracting from inflation, a dollar deposited in 

a savings account paying 4 percent today, for example, will 

have earned four cents in interest in a year. Thus, no one 

would trade a dollar available today for any less than a dollar and four cents available a year from now. For the Federal government or an individual to make rational decisions 

about how resources should be allocated, differences in the 

value of those resources over time must be accounted for. 

The accepted way to do this is to discount future income or 

costs at a rate which reflects the value or cost which would 

have been received had the dollars been available today. 

The discounted value is called the "present value." The 

higher the discount rate used to compute the present value 

the lower the present value will be, all else being equal. 

Opinions differ about the appropriate rate of discount 

to be used in comparing alternatives through time, but most 

experts agree that discounting should be done. 23Since the 

costs considered here are adjusted to correct for expected 

inflation (that is, since "constant dollars" are used in all 

calculations), the discount rate reflects only the implied 

value of the resources foregone and does not reflect expected increase in price. 

DOE's cost studies have traditionally been reported in 

undiscounted, constant dollars, so the Commission used 

undiscounted dollars to make its studies comparable to 

DOE's. However, because the spent fuel management and 

disposal system's benefits and costs will be incurred at different points in time under different alternatives and cases, 

the Commission made cost comparisons based on present 

value and on an undiscounted current, or nominal, value 

basis. 

Tables 6.7 and 6.8 compare the costs of the alternatives and cases previously discussed. 

Discounting results in modest increases in the relative 

cost advantages of the No-MRS alternative over the unlinked MRS system as the repository is delayed. On a nominal value basis, a system without an MRS is estimated to 

have almost the same total system cost as one with an MRS 

if the repository is delayed to 2013 and is slightly less expensive by 2023. On a present value basis, the No-MRS 

system retains its cost advantage of about 6 percent as the 

repository is delayed in both the 2013 and 2023 cases. The 

major cost account increasing the cost of No-MRS cases is 

the increase attributable to the delay in removing spent fuel 

from shutdown reactors. The preponderance of this cost occurs after 2015, as Figure 6.3 illustrates. The figure shows 

the annual costs for delaying the removal of spent fuel 

from shutdown reactors in both nominal and present value 

terms for a No-MRS case in which the repository is delayed until 2023. In nominal value terms, the annual cost of 

delaying spent fuel removal from shutdown reactors peaks 

in 2037 at $145 million but the present value of the cost in 

2037 is only about $22 million. 

Compared to a linked MRS system, the cost advantage 

of the No-MRS alternative remains at about 5 percent, regardless of whether the comparison is based on the nominal 

or present value. Recalling the analysis of the uncertainty 

of the cost estimates shown in Table 6.5, cost differences of 

this magnitude clearly are small relative to the inherent uncertainty in the cost data from which they were derived. 

Discounting the at-reactor storage costs decreases the 

relative importance of the cost of the at-reactor storage 

component that is attributable to the removal delay, but the 

relative importance of the total at-reactor storage category 

in total system costs remains unchanged. In the linked 

MRS cases, delaying the repository opening reduces the 

relative cost of the MRS because the facility is built later 

with "cheaper" discounted dollars, and this tends to reduce 

the cost advantage of the unlinked MRS compared to the 

linked MRS. 

In general, however, discounting does not significantly change the relationships among the costs of alternatives. Systems without an MRS are less expensive if the 

repository comes on line as scheduled; if the repository is 

delayed, the cost differences shrink as at-reactor storage 

costs accumulate. 

71 
72 

7 0 2 ; 0 2I i 6 

27.0 12.6 

,27 02 12.5, 

• 2 0 

1.0 24 8 11.6 

12.5 

o-MR 

Linked :?0 

Onlink:e0MRS'1998°°:. 

LlnlinkeOl:MAS 

:Panel:Three: Repository 

in 2023 > 

NO MRS;; 

Lin kepi, miR,s ;202Q 

Unlinked :1■4F,IS;2000' 

.28;0 

y 6z 

'9 0; "29 5 

° 1 , 4: - 27.2 

4 28 3 

Table,6. Comkarison;of Total-system Life-cyclecosts for Total- system 

elected Repository :Start Dates:%. resent'Value.:an 

Nominal Value, 

MRS Co0 

ominal .; 'Present 

anei One': `Repository in Value a ' Value; 

2003 

N9 MR 

Liiiked;MFAS 201:0 

hifri00: 10§b66. 

MRS 2608 

.1 5 7.4 1 

°8. 3 

6 1 

1.8 26'.6: 9.2 

1 27.9 -

0°,6:" 9.7 

1.1 27.1 

!Source: Table 

.: 6,p(egent'yalUe*iS:in, bil 

.value bi 

three-yea( schedule, 

NainyentorY 

At=reactorCost TOtal Cost 

-Present Nominal preserif Nsmirial Pre6.ent 

Value "".value`"" Value ° Veftie 

lions:of constant -',10..'doildrs' qisoounted:at• an . annual :ratelOf . %.4%. --„— "'. lions Of:constant. 19 9:dolla s.. , , .. ., . , °. 

linkaP'eano. inVeritory,lirnit br.15 ; 090 MTU oerNyvPM. 

- , 

- , 'Pll .;. . • ! VI 
Table 6.8 Comparison'of Total-system Life-cycle Costs : aNominal Value and 

Present Value for Selected Cases 

Year Repository 

Starts - NO=MRS: Linked MRS' Unlinked MRS" 

2003- 

'PV NV PV V PV NV 

'TOTAL 11.6• 24.8 • 12.5 26.9 12.5 27.0 

'At reactor 1. 0 2.3 0.6 1.2 0.5 0.9 

,[Shutdown" [0.4j [1.2] [0.5] [0.1] [0.2] 

Reactors] 

DevelopMent & 6.3 9‘.0. 6.6 9.8 6.6 9.8 

Evaluation 

Trahsportation 1.0 3,7 1.1 3.7 1.7 3.8 

Repository 3.2 9. 7 3.2 9.7 3.2 9.7 

MRS 0.9 2.5 1.1 2.8 

2013 

TOTAL 9.2 26.6 9.7 27.9 9.7 26.7 

At-reactor 1.8 5. 1 1.5 3.7 0,6 1.1 

[Shutdown - [0.6] ' [2.7] [0.4] ' [1.3] [0.1] [0.3] 

Reactorsr 

Development & 4.8 9.0 5.0 9.7 5.1 9.8 

Evaluation 

Transportation cys 3.3 - 0.6 3.3 0.8 3.3 

Repository 2.0 9.2 2.0 9.2 2.0 9.2 

MRS 0,6 2.1 1.2 3.2 

-2023, 

TOTAL 7.4 28.0 7.8 29.5 7,9 27.2 

At-reactor 2.0 6.6 2.0 5.9 0.7 1.4 

[Shutdown [0.7] [3.6] [0.6] [3.0] [0.2] [0,5] 

Fieactorsi 

Development & 3.8 9.0 3.8 9.6 4.1 9.9 

Evaluation 

Transportation 0.4 2. 9 0.4 2.9 0.5 2.8 

Repository 1.3 9.4 1.3 9.4 1.3 9.4 

MRS 0.3 1.7 1.3 3.7 

aSource: Table 6.4. 

Nominal value (NV) is in billions of constant 1989 dollars, present value (PV) is in billions of constant 1989 

dollars discounted at an annual rate of 4%. 

`MRS is to begin operations three years before the repository and to be limited to 15,000 MTU per NWPAA. 

'MRS is to begin operation,in the year 2000 and to have no capacity limit. 

' Cost of delaying the removal of spent fuel from shutdown reactors. This is included as a part of "Atreactor" storage costs. 

73 

7 0 2 j J 2 1 1 7 
Cii6tpee:ye-a-e0f;4101 ROMOil',OfgOent 4Fue 

Shutdown Reactors' 

vure 6 3 

pComparison of arid Present Ua!pa:, _ _ 

Ontad :at 4 Percei,it) 146.01Rs; . RePositbrOn 4 2023 ;Case 

?A , 

ne 

Millioris of Dollars a , 

160 

404; 

:120 

100 

.0. 

,A991 20001 

;+ ;Nominal:Value; 

= 

NoL.MRS,', FfelzioitolV2023‘: !: 

Section Five: Findings 

The Commission finds that the costs of building 

and operating an MRS are greater than the savings in 

at-reactor storage costs if the repository starts according to current DOE schedules or is subject to a modest 

delay. If the MRS is delayed beyond 2013, when the cost 

of delaying the removal of spent fuel from shutdown reactors begins to accumulate, then the cost differences 

between a No-MRS and unlinked MRS system become 

negligible. 

Since the criteria that the Commission used to 

evaluate the desirability of including a monitored retrievable storage facility in the national spent fuel management and disposal system are not limited to lowest 

cost, these data do not demonstrate conclusively that a 

No-MRS strategy is to be preferred, even if one is optimistic about the repository schedule. Moreover, the uncertainty apparent in the cost data suggests it would not 

be prudent to base decisions primarily on what is currently perceived to be the lowest cost strategy. 

74 

7 0 
Chapter Six Notes 

1.Department of Energy, "Analysis of the Total-Systems 

Life-Cycle Cost for the Civilian Radioactive Waste Management 

Program," for years 1983 through 1989. 

2. The most significant changes occurred between the 1987 

and 1988 estimates as a result of the passage of the 1987 Amendments to the Nuclear Waste Policy Amendments Act of 1987. As 

previously described, these amendments directed the Department 

of Energy to make a number of changes in its basic plan for 

developing the waste system, and the cost consequences of these 

changes were included for the first time in the 1988 report. The 

intent of the NWPAA was to reduce the cost of the system by reducing the number of alternative sites to be studied, or "characterized," as to their suitability as a location for a repository. The 

TSLCC report estimates that these changes reduced the lifetime 

cost of the system by $5.6 billion. At the same time, DOE included in its 1988 estimates the benefits to be paid to States and localities affected by the repositories and the MRS, according to the 

schedule included in the NWPAA, which amounted to $0.9 billion. Along with other more minor changes the net effect of the 

1987 amendments, according to DOE, was to decrease the cost of 

the system by $5.9 billion. As in previous years, the Department 

also made changes in design and planning assumptions which increased total system costs between 1987 and 1988. For a system 

that is comparable to the one reflected in the 1987 estimates, these 

changes, along with an adjustment for inflation, amounted to $5.8 

billion, so the net effect was to leave the estimate of the total cost 

of the system virtually unchanged. Department of Energy, "Analysis of the Total-System Life-Cycle Cost for the Civilian Radioactive Waste Management Program," DOE/RW-0236, May 1989 

(Hereafter cited as TSLCC 1989), pp. 1-8, 1-9. 

3. Department of Energy, "Summary Report of the MRS 

System Studies," May 1989. (Hereafter cited as Task J) 

4. TSLCC 1989, p. 6-7. The basic MRS, in DOE's proposal, 

would retain the option to conduct packaging and consolidation 

should future developments or information make that desirable. 

The cost savings discussed in the TSLCC report, however, assume 

that packaging and consolidation do not become practical and the 

MRS remains only a storage and staging facility throughout its 

useful life. 

5. TSLCC 1989, p. 1-10. Such a change would require an 

amendment to the NWPA which imposes a 70,000 MTU limit on 

the first repository. 

6. TSLCC 1989, p. 1-6. 

7. TSLCC 1989, p. 1-1. 

8. Dershowitz, W., Breeds, C., Roberds, W., and Miller, I., 

"Interim Spent Fuel Management Cost Data Base: Report to 

Monitored Retrievable Storage Review Commission," Seattle: 

Golder Associates, 1989 (893-1032.120) (Hereafter cited as 

ISFM Cost Data Base). 

9. ISFM Cost Data Base, pp. 22-31. 

10.Miller, I., and Fuget, W., "WACUM: Nuclear Waste Cost 

Database and Simulation Model User's Guide Version 1.13: Report to the Monitored Retrievable Storage Review Commission," 

Seattle: Golder Associates, 1989. 

11.In its system studies, DOE discussed the effects of the 

OFF pick-up rule on costs and showed that it would lead utilities 

to incur greater at-reactor storage costs than a more efficient rule. 

The data reported in the Task J and TSLCC reports, however, are 

derived using OFF. 

12. "Full" means that any additional storage of spent full 

would encroach on a reserve adequate to store the reactor's operating core should that be necessary. 

13.The DOE estimates summarized in the table were made 

by DOE at the Commission's request assuming that all the spent 

fuel generated would be emplaced in one repository. As noted previously, the NWPA would have to be amended to do this. There is 

a great deal of uncertainty about the second repository schedule 

and the type of geologic medium in which it would be built. Basing the estimates on the assumption that all spent fuel would be 

emplaced in one repository is an analytic device employed here in 

an attempt to prevent the uncertainty associated with a second repository from reducing the comparability of the estimates. The 

DOE estimates were converted from 1988 dollars to 1989 dollars 

by use of the Implicit GNP Deflator, which increased at an annual 

rate of 4 percent in 1988 and at an annual rate of 4.4 percent in 

the first two quarters of 1989. "U.S. Financial Data," St. Louis 

Federal Reserve Bank, July 29, 1989. 

14. "WACUM Versus DOE Systems Study Comparison," 

Golder Associates, Inc., September 1989, p. 4. 

15.Wood, T., et al., "MRS Systems Study Task G Report: 

The Role and Functions of Surface Storage of Radioactive Material in the Federal Waste Management System," Pacific Northwest Laboratory, PNL-6876 (Hereafter cited as Task G), pp. 

3.16-3.22. 

16.The costs are included in the at-reactor total. 

17.The costs used were taken from the Task G Report, pp. 

3.21 and 3.22, specifically, $2.2 million per year for a site with 

one or two shutdown reactors, $2.7 million for a site with three 

shutdown reactors, $410,000 for one shutdown reactor at a site 

which also has an operating reactor and $610,000 for a site with 

two shutdown reactors and an operating reactor. The costs included in the original encoded ISFM data base were higher, ranging 

from a low or "10 percent" estimate of $2 million per year per 

site to a high or "90 percent" estimate of $5 million per year per 

site. These costs do not start accumulating until all the spent fuel 

at the reactor is at least five years old and, thus, could be sent to a 

repository or an MRS if it were available. 

18.DOE essentially treats D&E costs as fixed costs which 

continue to accumulate at a more or less fixed rate if the repository is delayed. Although this may a realistic reflection of the 

budgetary response observed in the real world for fairly short term 

delays, it is not an appropriate assumption to use in modeling the 

waste system costs over a 40- or 50-year planning horizon. Because D&E costs are a large component of total costs, such an assumption reduces the credibility of the cost estimates as a whole. 

19.Hoskins, R., "A Systems Evaluation of the High-Level 

Nuclear Waste Management System Based on Integration of Dual 

Purpose Cask Into the System as an Alternative to DOE'S Proposed Monitored Retrievable Storage Facility as an Integral Part 

of the System," Knoxville, Tennessee: University of Tennessee 

Waste Management Research and Education Institute, 1989, pp. 

V-25 to V-39. See also Hoskins, R., "Probabilistic Assessment 

of Nuclear Waste Fund Fee Adequacy," Waste Management '88 

for an explanation of a probabilistic approach to cost estimation 

and decisionmaking. 

75 

2 1 9 
20.The simulation was a restricted Monte Carlo simulation 

made with triangular probability density functions containing only 

the minimum, expected, and maximum values. 

21.All MRS estimates assume that the MRS is located in the 

Southeastern United States and that the repository is located in 

Nevada. A "western strategy" is also assumed which means that 

reactors located west of 100 degrees longitude ship their spent 

fuel directly to the repository while reactors east of that line send 

spent fuel to the MRS. In scenarios in which the MRS comes online before the repository opens, the WACUM cost simulation 

model keeps track of the fuel that western reactors would have 

been allowed to ship under the operative pick-up rule if they 

would have been permitted to ship to the MRS and gives this fuel 

first priority to ship to the repository once it opens. 

22.If the MRS has reached its capacity limit but the repository has not, the WACUM cost simulation model allows reactors to by-pass the MRS and ship directly to the repository. This 

assumption reduces the cost of the MRS compared to an assumption which requires all spent fuel to be passed through the MRS 

facility. 

23.Lind, R., Discounting for Time and Risk in Energy Policy, Washington, D.C.: Resources for the Future, 1982, presents a 

complete discussion of the importance and methods of discounting in public policy. 

76 

7 0 20 Let 
Chapter Seven 

Distributional Considerations and 

Equity 

This chapter discusses the distribution of the costs and 

effects of the national spent fuel management system. 

"Distribution" refers to the incidence of costs and effects: 

which individuals or governing bodies pay which costs, 

and who is affected by the siting, construction, and operation of facilities in the system. "Equity" means the fairness 

or justice of the distribution. The spent fuel management 

system's distribution of costs to, and effects on, individuals 

has not been as completely analyzed as have the system's 

technological and logistical aspects. However, these distributional and equity concerns have played an important role 

in the controversy surrounding MRS proposals. Concerns 

include which regions of the United States would have access to an MRS and in which region an MRS should be 

built. 

Although it is common to discuss costs to governments or to businesses, all costs and risks are ultimately 

borne by individual citizens, consumers, ratepayers, taxpayers, or stockholders. 

Section One of this chapter discusses compensation to 

States and localities for costs and risks their citizens might 

incur if an MRS or a repository were located in their jurisdiction. Section Two discusses problems that may arise 

from "stigma effects"—the economic and psychological 

effects of perceptions about nuclear waste facilities. Section Three considers equity issues. Section Four discusses 

some of the efficiency and equity aspects of the arrangements used to finance the system. Section Five presents the 

MRS Review Commission's findings. 

Section One: Compensating State and Local Governments 

The Nuclear Waste Policy Amendments Act of 1987 

(NWPAA) outlined payment schedules intended to compensate States, localities, or Indian Tribes for additional 

burdens on services or infrastructure that locating an MRS 

or repository in their jurisdiction might create. For example, roads surrounding the MRS might have to be upgraded, the police force might have to be increased, and the 

school system might have to be enlarged. Although some 

Members of Congress advocated annual compensation as 

high as $100 million per year to States or Indian Tribes in 

whose jurisdictions a repository was located, and $50 million per year for hosting an MRS facility,' the NWPAA included a lower compensation schedule. The NWPAA 

specifies compensation for repositories of $10 million per 

year until spent fuel is accepted and $20 million per year 

thereafter; for the MRS, the act allows $5 million per year 

until operations start and $10 million per year thereafter. 2 

The NWPAA directed the Department of Energy 

(DOE) to limit its efforts to characterize a repository site to 

the Yucca Mountain site in Nevada and specified what a 

State or Indian Tribe benefit agreement should contain. 

Among the specified provisions is a requirement that the 

State or Tribe signing such an agreement waive its right to 

disapprove the repository site recommendation. DOE asked 

the State of Nevada to enter into negotiations to fashion a 

compensation agreement but Nevada declined. 3 

DOE has testified that it would prefer to locate an 

MRS through direct negotiations between the Office of the 

Nuclear Waste Negotiator and individual States in hopes of 

bringing the facility on line sooner than the current linkages permit. 4If the negotiations were successful, and if 

Congress approved the negotiated agreement, the cost of 

compensating the State might be greater than the NWPAA 

specified. 

In theory, identifying governmental service burdens 

and costs and arranging efficient compensation mechanisms should be straightforward because these burdens and 

costs are fairly concrete and quantifiable, like roads, 

schools, and police. If successfully executed, the compensation would offset any inequities created for States, localities, or Tribes. Such compensation or mitigation 

programs have been designed and implemented successfully as a part of large construction projects, such as 

77 

7 0 2 2 1 
power plants and oil pipelines. 5However, in practice, determining appropriate compensation to State and local gov 

ernments or Indian Tribes may involve complex and 

contentious negotiation. • 

Section Two: Stigma Effects 

Regardless of their size, payments to States, localities, 

or Indian Tribes affected by an MRS's or repository's location may not mitigate all of the cost of siting and its effects 

on individuals. For example, the negative images that nuclear waste facilities engender may create costs for individuals that may not be administratively practical or desirable 

to fully compensate. Experts may not agree with the public's perception of risk on which the negative images of nuclear waste facilities are based, but if the population widely 

shares these images, the resulting costs may be real and 

significant. Such costs may be directly monetary, such as a 

decline in property values; they may be less direct but still 

economic, such as a change in the community's or State's 

appeal as a place to live, work, or locate a business; or they 

may be more psychological than economic, the manifestation of increased anxiety and apprehension of neighboring 

citizens. These costs are referred to as "stigma effects." 

Although concern about stigma effects has played a significant role in the MRS debate, there is no objective, agreedupon method to measure and compensate for them. Nor is 

there agreement on whether or not such compensation is 

necessary or desirable. 

Payments to States, localities, and Indian Tribes may 

be partly premised on stigma effects, or a negotiated agreement may explicitly acknowledge them, but it still may not 

be feasible, practical, or desirable to compensate the individuals that incur them. For example, if an offer were made 

to compensate those who suffered increased anxiety because a nuclear waste facility was located in their neighborhood, it would be administratively impossible to distinguish those truly experiencing increased anxiety from those 

merely wanting to be compensated. 

A related difficulty is that much of the stigma associated with nuclear waste facilities is the result of individuals' perceived risks which appear to exceed by orders of 

magnitude the experts' estimate of risks, as discussed in 

Chapters Four and Five. Policy should respond to risks 

which reflect the best information available. But the dilemma for policymakers is that although the costs are real, the 

perceptions of risk that create them may be the product of 

misinformation or varying value systems. 6 

Stigma effects played an important role when Tennessee objected to DOE's initial proposal to locate an MRS in 

that State. Lamar Alexander, then governor, argued that locating an MRS facility at an Oak Ridge site would be detrimental to the State's aspirations for "high tech" economic 

development to cluster around the Tennessee Technology 

Corridor between Oak Ridge and Knoxville.? 

A survey of civic and business leaders by the University of Tennessee's Center for Business and Economic Research indicated that DOE's proposal to locate an MRS in 

Oak Ridge evoked negative images, but no attempt was 

made to determine the dollar cost associated with them. 8 

Similarly, Nevada's Socioeconomic Advisory Panel studied 

comparable effects associated with the proposed Yucca 

Mountain repository site and concluded that although they 

could not quantify the stigma effects' magnitude, they believed the effects existed and might be significant. 9 

Studies also show that building an MRS offers individuals economic benefits that offset stigma effects. Communities close to an MRS would benefit economically 

during the facility's construction and operation. Tennessee's studies estimated that such benefits would amount to 

approximately $115 million per year in additional wages 

and salaries during the construction of the facility and $37 

million per year in additional wages and salaries during its 

operation. The studies estimated that about 700 permanent 

jobs would be associated directly with the facility, and 560 

jobs would be associated with the increased economic activity it would create.") 

The broadly based Clinch River MRS Task Force, 

after comprehensive consideration, agreed on a set of 

conditions, including compensation, mitigation, local participation, and procedural safeguards, which they 

believed would make the MRS acceptable to the 

community." 

7 

78 
Section Three: Equity Considerations of MRS Alternatives 

The Commission's discussion of the need for an MRS 

considered equity among localities, States, regions, and 

ratepayers of different utility systems. The Commission 

considered such questions as whether it is fair for some 

people, some regions, and some companies to bear the 

costs of spent fuel management while others do not, and 

how unfairness can be avoided or compensated. 

Since the number of facilities in the national spent fuel 

management and disposal system is small (perhaps only 

one repository), the stigma effects associated with spent 

fuel management will be focused on a small number of 

communities and States once spent fuel is moved away 

from the reactors. Without an MRS, individual reactor sites 

will continue to accumulate spent fuel which, over an extended period of time, may also impose stigma effects. But 

thus far, MRS alternatives, rather than the No-MRS alternative, appear to be directly evoking the most equity 

concerns. 

A. Equity in the Siting Process 

For the imposition of the costs associated with stigma 

effects to be considered equitable, most analysts contend 

that the process used to select the facility's location must 

be fair, objective, and nonpartisan. If an MRS, or any similar facility, is built, some State or locality will have to bear 

both the quantifiable costs and risks and the stigma effects. 

If an unwanted facility is built, costs and risks are inevitable, making some inequity inevitable. However, if the selection of one site over another is seen as fair, and the 

facility is acknowledged to be necessary to the public good, 

the result may be seen as equitable. 

Although the State of Tennessee was careful to enumerate the costs and risks it believed would be incurred 

were the MRS to be located in Oak Ridge, the foundation 

of its objection was that DOE had short-circuited the process specified in the Nuclear Waste Policy Act to objectively 

and "scientifically" pick the best site for such a facility. 

Nevada, too, believes the process by which Yucca Mountain was selected as the focus for site characterization was 

politically biased and unfair. 

B. Geographic Equity 

1. Local or Community Equity 

Although the local or community level stigma effects 

resulting from the location of a facility may be the most direct, they may also be the easiest to deal with. First, the facility's direct or indirect economic benefits, which are concentrated at the local level, may mitigate the stigma effect 

to some degree. Second, individuals with particularly 

strong feelings or concerns may be able to move to another 

community, albeit at considerable personal sacrifice, but, in 

many cases, without a major disruption in their employment, lifestyle, or social circumstances. It might even be 

possible to compensate individuals for moving expenses if 

they chose to move from the immediate vicinity of the facility within some limited period of time after the facility's 

location was announced. Although some individuals might 

be compensated whose desire to move was unrelated to the 

facility, probably few would choose to bear the inconvenience of moving simply because compensation was 

available. 

2. Equity at the State Level 

Stigma effects which are asserted to have spread their 

incidence across an entire State may be somewhat more 

tenuous to identify and also more difficult to compensate. 

The direct economic benefits become much more dilute as 

the distance from the facility increases. Moreover, individuals usually will not be able to adjust by changing their residence to an unaffected State without a major disruption in 

their economic and social circumstances. It also probably 

would not be feasible to distinguish those wishing to leave 

a State because of stigma effects from those wishing to 

move for unrelated reasons. However, it may be possible to 

mitigate some State-level stigma effects by using advertising or educational campaigns aimed at firms or individuals 

that might be considering locating in the State or by improving transportation to address transportation safety 

concerns. 

3. Regional Equity 

Although equity among regions (such as East and 

West) has been an important concept in the MRS and repository controversy, the logic is murky. Any stigma effects which could be assumed to be spread over a wide, 

multi-State region are hard to define or identify, even conceptually. The desire for regional balance or equity may 

well be the expression of a political concern or defense to 

keep a facility from being located in a region. 12But there is 

no geologic, environmental, or other objective reason 

why large, multi-State regions should not be considered as 

sites for an MRS or a repository. Exempting a broad region 

from consideration for a controversial facility may be a natural political accommodation, but it appears to have little to 

do with equity as the concept is generally understood. 

79 
C. Equity Among Ratepayers 

The most straightforward application of equity principles to the spent fuel management and disposal problem is 

the treatment of nuclear utility ratepayers. Under current 

law, the MRS will be financed in the same way as the repository: from the Nuclear Waste Fund, to which utilities 

are required to pay fees according to the net amount of 

electricity they generate from nuclear power plants. Some 

utilities stand to benefit more than others, depending on 

such considerations as where an MRS is built, what services it offers, when it is built, and how the regulations governing its operation work. 

If a repository were built in the West and an MRS in 

the East, reactors in the western States might have to store 

fuel on-site until the western repository could accept it, 

while reactors in the other regions could ship fuel to an 

MRS. Thus, a western utility with a filled pool would have 

to add dry storage facilities at its own expense, while an 

eastern utility could avoid those costs by shipping spent 

fuel to the MRS, financed by the Nuclear Waste Fund. Analysts feel this arrangement violates the "equal treatment of 

equals" equity principle—traditionally applied to other 

such governmental activities as taxation and expenditures—which says that a tax is equitable if it treats "equally situated taxpayers equally."' 3 

Some degree of departure from the "equal treatment 

of equals" precept would be inevitable if there were an 

MRS. All utilities with nuclear power plants would pay 

into the Nuclear Waste Fund, but only some would benefit—the ones that store fuel at the MRS. Individual payments to the Fund would be greater the more electricity a 

utility generates by nuclear power, while the utility's benefits are greater the more spent fuel it stores at the MRS. 

Also, differences in the adequacy of spent fuel storage capacity at different utilities, coupled with an economically 

inefficient "oldest fuel first" pick-up rule, would cause 

some utilities to derive more benefit than others from their 

share of an MRS's costs. 14 

The fewer the services the MRS performs, the greater 

the likelihood that inequities will result. A "fully integrated" and "on-line" MRS would provide consolidation 

and packaging services for all spent fuel processed. Thus, 

at least those services would be generally distributed 

among utilities in proportion to their power generation. The 

benefits of a storage-only facility, especially if constrained 

by an inventory ceiling, would be limited to fewer utilities, 

and the disparity between the benefit received and the cost 

incurred would be greater from the standpoint of individual 

ratepayers. 

Thus, the greatest potential inequity seems to be the 

lack of correlation between ratepayers' costs for an MRS 

facility and the same ratepayers' benefits from the facility, 

especially if the MRS's role and size were limited. Concern 

for regional equity, which has focused on siting effects and 

has received the lion's share of attention, appears to be 

more closely related to political considerations than to 

equity as the term is generally understood. 

Section Four: Economic Efficiency and Equity in MRS Financing 

If it were financed through the Nuclear Waste Fund, 

an MRS would be essentially free to an individual utility's 

stockholders. The MRS cost is a small enough part of the 

total national spent fuel management costs financed 

through the Fund to have relatively little effect on the utility's fee, at least over a typical utility financial planning 

horizon. Moreover, because the utility's payment to the 

Fund is mandatory, public utility commissions normally 

would allow the payment as an operating expense and incorporate it into the utility's rates. Thus, the ratepayers pay 

the fee. Under these arrangements, the utility has an incentive to favor a spent fuel management and disposal system 

that includes an MRS and an even stronger incentive to use 

an MRS.' 5 

If an MRS were to be financed by a user-fee system, 

in which a utility's costs were based on how many units of 

storage (or other services) it used, the utility would have an 

incentive to compare the MRS costs with those of other 

spent fuel management options. If the cost and convenience 

(such as reduced time and management attention needed 

for spent fuel management) of using an MRS were comparable to the cost of using other options (such as rod consolidation, reracking, or dry storage at the reactor site), the 

utility would probably decide to use the MRS. If storage or 

consolidation technology were to change, making it cheaper to use another option, utility managers might decide not 

to use the MRS. Public utility commissions could review 

the choice made by the utilities' management and may or 

may not allow the cost to be passed on to ratepayers. Thus, 

the utility's stockholders would share with its ratepayers 

some of the financial risk involved in picking a spent fuel 

option. 

The Tennessee Valley Authority, in testimony before 

the Commission, advocated user-fee financing of an MRS 

80 

7 0 2 3 0 
on both economic efficiency and equity grounds. 16The 

reasons just outlined suggest that the user-fee system would 

produce more economically efficient choices and result in a 

lower cost to society than a mandatory payment system, 

unless other circumstances made the user-fee system impractical. These arguments are summarized below. 

A. DOE/Utility Contracts 

It might be argued that the existing contracts between 

DOE and utilities specify a mandatory system, and that 

since utilities have made their plans accordingly, it would 

be disruptive and costly to change to a user-fee system. 

However, a number of major changes in the technological 

and institutional context of the national spent fuel management and disposal system have occurred since the contracts 

between the utilities and the department were concluded. 

Schedule delays and changes have created pervasive uncertainty about the date at which the repository will be available. The NWPAA's linkages between the repository and 

the MRS are widely regarded by utilities, as well as others, 

to have decreased substantially the value of the MRS to the 

overall system and to utilities. Moreover, because of the 

linkages, any uncertainty about the repository's start date 

means uncertainty about the start date for the MRS. 

Utilities are making plans to provide storage capacity 

at reactor sites on the assumption that the MRS will not be 

operational by 1998, and, even if it were, it would not be 

able to meet utility needs for out-of-pool storage. The existing degree of fluidity and uncertainty is so great that it is 

difficult to envision a major disruption in plans and expectations being brought about by a change in the MRS financing arrangements. The costs of the MRS constitute 

only about 10 percent of the total costs to be covered by the 

contracts between the utilities and DOE, thus the financial 

effect of a change in the contracts would be relatively 

modest. 

B. Economic Efficiency 

It could also be argued that user funding would not increase economic efficiency because utilities would use an 

MRS even if it were more expensive than other storage options because their primary motivation is to remove spent 

fuel from the reactor site, not to minimize storage costs. 

However, a user-fee system would not require utilities to 

store spent fuel at reactors. Utilities may have legitimate 

reasons for wanting to remove spent fuel from reactor sites; 

those reasons may not be reflected in the average costs of 

the alternatives. A user-fee system would enable the utility 

and the relevant public utility commission to know how 

much of a premium it was paying to remove the fuel. Information on the extent of this premium should both help the 

utility and the public utility commissions decide whether it 

is prudent and worthwhile to do so. 

C. Expense 

Making an MRS optional, it might be asserted, would 

increase costs elsewhere in the system, thus offsetting any 

savings in at-reactor costs due to enhanced efficiency. 

However, problems of this sort are easier to envision for a 

packaging MRS where failure to consolidate or to encapsulate spent fuel at an MRS in standardized canisters or waste 

disposal containers may increase costs at the repository unnecessarily. At an MRS which provides only storage and 

logistic services, such problems are less likely to arise. If 

they do, they could be offset by additional fees to be levied 

at the repository on "non-standard" fuel received from 

utilities. 

D. Economy of Scale 

It might be argued that not enough utilities may 

choose to use the services of the MRS to allow a facility of 

efficient size to be built. However, there do not appear to 

be significant economies of scale in the technology of a 

basic MRS beyond a minimum capacity of about 2,000 

metric tons uranium.' 7As the size of an MRS increases, so 

does the number of hot cells and loading/unloading facilities. Dry spent fuel storage technology, by its nature, is 

modular. A smaller capacity facility may be easier to site, 

since the larger the capacity the greater the fear may be that 

the MRS will become a de facto repository. 

81 
Section Five: Findings 

Based on the information presented here, the Commission finds: 

A. Compensating State and Local Governments or Indian Tribes 

Compensating States, localities, or Indian Tribes 

for costs they may incur if a nuclear waste facility were 

located in their jurisdiction may be politically contentious and practically difficult, but conceptually it is 

straightforward and, if correctly executed, would offset 

any unfair burden to State or local taxpayers. 

B. Stigma Effects 

Cost increases based on actual measurable impacts, however, are different from the stigma effects 

that result from the negative images widely associated 

with nuclear waste facilities. Although the costs created 

by stigma effects may result from perceived risks of nuclear waste facilities that some experts believe are overstated, the costs may impose burdens that violate 

commonly accepted principles of equity. Stigma effects 

at the local or community level may be easier to adjust 

to than stigma effects perceived at the State level, because the economic benefits of nuclear facilities are concentrated at the local level and because local individuals 

may have the option of moving, albeit with considerable 

personal sacrifice, to avoid the effects. The option to 

move is usually less practical at the State level. 

C. Regional Equity 

The concept of regional equity has played an important role in the nuclear waste disposal debate, but 

the logic behind the concept is murky. Some inequity is 

inevitable, but stigma effects are felt at the local or 

State level, not at a broad regional level such as "the 

East" or "the West." 

D. User-Fee Financing 

The ratepayers of different utility systems would 

be treated more equitably if an MRS were to be financed by user fees rather than the Nuclear Waste 

Fund and utilities would be encouraged to make more 

economically efficient choices among spent fuel storage 

alternatives. The case for user financing is stronger the 

more limited the MRS's capacity and the range of services it performs since the benefits are less widespread. 

82 

7 0 0 1 
Chapter Seven Notes 

1.U.S. Congress, Hearings before the Committee on Energy 

and Natural Resources United States Senate on S. 839, Part 3, 

100th Cong., 1st Sess., April 29 and May 7, 1987, pp. 1-15. 

2. 42 U.S.C. § 10174(a). 

3. Department of Energy, "Analysis of the Total-Systems 

Life-Cycle Cost for the Civilian Radioactive Waste Management 

Program," DOE/RW-0236, 1988, p. 7-2. 

4. Isaacs, Thomas H., Associate Director, External Relations 

and Policy, Office of Civilian Radioactive Waste Management, 

Department of Energy, "DOE Position on the Monitored Retrievable Storage Facility," Prepared Remarks before the Monitored 

Retrievable Storage Review Commission, May 25, 1989, p. 5. 

5. The Tennessee Valley Authority implemented formal mitigation programs for nuclear construction projects at Phipps Bend 

and Hartsville, Tennessee, and Yellow Creek, Mississippi, as have 

other utilities. Such programs are routinely included in large public works programs funded by international lending organizations. 

6. See Kasperson, Roger, et al., "The Social Amplification 

of Risk: A Conceptual Framework," Risk Analysis, Volume 8, 

Number 1, 1988, for a discussion of the perceptions of risk and 

the societal response mechanism. 

7. Statement of Tennessee Governor Lamar Alexander, news 

release, January 21, 1986. 

8. Fox, William, An Economic Analysis of a Monitored Retrievable Storage Site for Tennessee, Knoxville: Center for Business and Economic Research, the University of Tennessee, 1985 

(Hereafter cited as Fox, Economic Analysis of MRS), pp. 27— 

40. 

9. Slovic, Paul, "Perceived Risk, Stigma, and Potential Economic Impacts of a High-Level Nuclear Waste Repository in Nevada," Presented at Waste Management '89, Tucson, Arizona, February 27, 1989. 

10.Fox, Economic Analysis of MRS, p. 11. 

11.Clinch River MRS Task Force, Position on the Proposed 

Monitored Retrievable Storage Facility, 1985. 

12.Clarke, James McClure, U.S. House of Representatives, 

11th District, North Carolina, Prepared Remarks, presented at the 

MRS Review Commission Public Hearings, February 17, 1989. 

13.Musgrave, Richard A., The Theory of Public Finance, 

McGraw Hill: New York, 1959, Chapter 8. 

14.See Chapter Six for a discussion of the inefficiency of the 

oldest fuel first pick-up rule and Pacific Northwest Laboratory, 

"MRS Systems Study Task G Report," PNL-6876, pp. 3.29-3.30. 

15.Even utilities which do not expect to need the services of 

an MRS because, for example, they have adequate in-pool storage, would have little incentive to oppose an MRS. While availability of an MRS would not reduce their costs, their opposition to 

an MRS might have negatively affected their relationship with 

other utilities. 

16.Willis, William, Executive Vice President and Chief Operating Officer, Tennessee Valley Authority, Transcript of Monitored Retrievable Storage Review Commission Public Hearings, 

January 17, 1989, pp. 177-179, 181-182. 

17.See E. R. Johnson, Associates, for Pacific Northwest 

Laboratory, "1988 Federal Interim Storage Fee Study: A Technical and Economic Analysis," PNL-6727, November 1988, pp. 

4.1-4.3, for a discussion of the costs of various sized storage facilities up to about 2,000 MTU. 

83 
Chapter Eight 

Policy Issues 

In the preceding chapters, the MRS Review Commission made important findings regarding the need for an 

MRS facility as part of the Nation's commercial spent fuel 

management program. Some of these findings are summarized as follows: 

• Health, safety, and environmental effects are expected to be small and within appropriate regulatory limits whether spent fuel is stored at an MRS 

facility or at reactor sites. 

• Radiological and non-radiological risks arising 

from transporting spent fuel, regardless of transport mode or method, are expected to be small and 

within regulatory limits, whether fuel is transported to and from an MRS facility or directly 

from reactors to a repository. 

• If the repository were to begin operation in the 

year 2003 according to current U.S. Department of 

Energy (DOE) schedules, adding an MRS facility 

in the year 2000 would increase the undiscounted 

costs of the spent fuel management and disposal 

system. If the repository were to be delayed to the 

year 2013, the undiscounted costs of a system 

without an MRS facility would be slightly lower 

than those of a system that included an MRS that 

was available in the year 2000. If the opening of 

the repository were to be delayed until the year 

2023, a system that included an MRS facility that 

was available in the year 2000 would be less expensive in undiscounted costs than one that did 

not. If the costs were discounted and expressed as 

present values, assuming a 4 percent rate of discount, the No-MRS case would remain less expensive than the MRS case even if the repository were 

delayed to 2023. 

• The principal reason the economics of an MRS 

become more favorable if the opening of the repository were delayed beyond the year 2013 is 

that after that time there will be a sharp increase in 

the number of nuclear power plants whose current 

licenses will expire. If neither an MRS nor a repository is available, total costs of a No-MRS case 

increase substantially because of the costs of delaying the removal of spent fuel from shutdown 

reactors. 

• The cost-related conclusions just summarized apply only to comparisons between a system without 

an MRS and a system with an unlinked MRS. A 

waste management system with an MRS subject to 

the current statutory linkages is more expensive 

than a No-MRS system in all cases. 

• Distributional consequences and equity issues 

need to be addressed if an MRS facility is built, 

but are not discriminating factors in deciding between an MRS facility and at-reactor storage. 

• If a non-integral storage-only MRS is built with a 

limited capacity, it would be more equitable to 

ratepayers if it were user-funded rather than financed from the Nuclear Waste Fund. 

Chapters Four through Seven examined, quantitatively, ways that having or not having an MRS would 

affect health, safety, the environment, cost and equity. 

Chapter Eight examines the less quantifiable ways the two 

alternatives would affect spent fuel management goals: to 

protect health, safety, and the environment and foster economy, equity, flexibility, and stability in the spent fuel management system. 

During the Commission's deliberations, DOE and the 

State of Tennessee presented testimony on the advantages 

and disadvantages of an MRS which discussed these less 

quantifiable policy issues extensively. 1Recent studies by 

the State of Tennessee and DOE make findings similar to 

those in previous chapters about health, safety, and environmental effects—that is, the differences between the NoMRS and MRS alternatives are small. Although the studies 

agree that the transportation impacts are small in any case, 

the Tennessee studies assert that Tennessee's Integrated 

No-MRS option has the lowest impacts. The DOE and Tennessee studies conclude that a system with an MRS will be 

more costly than a system without an MRS, although none 

of the studies includes the costs of delaying the removal of 

spent fuel from shutdown reactors. 2They do not agree on 

the amount of the cost increase with an MRS in the system, 

and they differ significantly on the nature and extent of the 

85 
■■■ 

benefits to be realized by building an MRS facility. The 

Tennessee study assumed availability of a dual-purpose 

cask not licensed at this time in the United States. 

Section One of this chapter presents the DOE and 

Tennessee public policy arguments for and against an MRS 

facility and the MRS Review Commission's analysis of the 

major points. The chapter focuses on the DOE and Tennessee arguments because Congress directed the Commission 

1■1 

to evaluate DOE's proposal, and Tennessee has presented 

the most comprehensive arguments against an MRS. Section Two of this chapter presents the Commission's own 

summary of the advantages and disadvantages of building 

an MRS facility as part of the Nation's nuclear waste program, drawing on the DOE and Tennessee studies as well 

as on its own studies and other material gathered during the 

course of its evaluation. 

Section One: Public Policy Views on the Need for an MRS Facility 

A. Statement of DOE's Position 

The Department of Energy wants to build an MRS facility as soon as possible. The MRS, as envisioned by 

DOE, would provide an opportunity to develop the nuclear 

waste management system in stages. Initially, the facility 

would receive and store shipments of intact spent fuel. 

When the repository is ready to accept waste, the MRS will 

serve as a transportation staging area for shipments to the 

repository. The facility could be expanded later to perform 

additional functions, such as rod consolidation or encapsulation, that might be regarded as beneficial as the system 

matures. 

The Department of Energy supports an integral MRS 

because it believes the facility would better enable the department to meet its four strategic objectives of timely disposal, timely and adequate waste acceptance, schedule 

confidence, and system flexibility. 

According to DOE, an integral MRS facility would facilitate timely disposal because the department would gain 

institutional and regulatory experience in siting and licensing that could be used in the repository program. An MRS 

could also provide experience in negotiating with a potential host State or Indian Tribe that could prove helpful in 

the repository program. 

DOE believes the waste management system would 

benefit from timely acceptance of the waste. The asserted 

benefits include: a reduction in the number of reactor sites 

requiring additional out-of-pool storage; less likelihood that 

continued on-site storage would interfere with reactor operations or delay decommissioning; and improved system 

compatibility in the face of uncertain technological developments. 

DOE asserts that an MRS facility would also provide 

schedule confidence because it would demonstrate the department's ability to accept, transport, and handle spent 

fuel at high annual rates. DOE states, "A firm Federal 

commitment to proceed with an MRS facility would enhance confidence that the Federal government is using all 

available means to ensure timely assumption of the Federal 

responsibility to accept spent fuel for disposal." 3 

DOE argues that an MRS facility would provide system flexibility. DOE defines flexibility as "the ability of 

the system to perform its mission when decisions must be 

made in the face of uncertainty or incomplete information...and the ability to redirect a project in response to 

changing circumstances in an effective way while still 

achieving the objectives." 4 

With this definition in mind, DOE reasons an MRS facility would provide insurance against future uncertainties. 

Should difficulties develop in the repository program, DOE 

could still accept waste from reactors. Furthermore, DOE 

argues, an MRS would add flexibility to the repository development schedule. The MRS would relieve some of the 

pressure to achieve milestones in the repository program in 

the face of technical and regulatory complexities and uncertainties and provide more time to resolve unanticipated 

problems. In addition, DOE states that an MRS built in 

stages would preserve the option of adding functions to 

minimize operations at the repository. Finally, DOE states 

that an MRS would permit management of spent fuel shipments according to technical requirements (e.g., to achieve 

a certain temperature distribution in the repository). If the 

MRS capacity were increased, spent fuel could be aged before emplacement in the repository, an option chosen by 

most European countries. 

While DOE would prefer to build an integral MRS facility with less stringent alternative linkages, the department also sees benefits in building an integral MRS facility 

linked under current law to the repository schedule and 

limited in capacity. The department would prefer that the 

Nuclear Waste Negotiator site the MRS in recognition of 

the difficulties the department would face in undertaking 

such a process. In testimony before the Commission DOE 

stated that, "it is possible that a State or an Indian Tribe 

might negotiate an agreement that would allow the construction—and perhaps even operation—of the MRS 

86 

7 0 0 
facility to proceed at a faster pace than allowed by current 

linkages in the Amendments Act." 5 

B. MRS Review Commission's Analysis of 

DOE's Position 

The Commission finds there is merit to many of the 

Department of Energy's arguments that an MRS facility 

would benefit the waste management system. However, the 

Commission believes some of the benefits would be less 

than DOE asserts, and there are disadvantages associated 

with an MRS as well. 

1. Timely Disposal of Nuclear Waste 

DOE believes an MRS facility would promote timely 

disposal of waste by providing siting and licensing experience transferable to the repository program. The repository 

program may benefit from siting an MRS facility to some 

degree, especially if another repository site must be found. 

The technical issues associated with siting an MRS are different than the technical issues involved in siting the repository. However, DOE experience in negotiating with a 

potential host State over permissible site investigation activities for an MRS and negotiating a benefits agreement 

with a potential MRS host State could prove useful should 

similar efforts be required in the repository program. This 

experience could be useful whether the MRS is sited by 

DOE or by the Negotiator. 

The repository program is less likely to benefit from 

DOE experience in licensing an MRS than it would from 

siting one. Although some benefits through institutional experience in a structured licensing process could be obtained 

if the MRS is licensed in advance of the repository, licensing the repository will be different than licensing an MRS 

facility. The storage-only MRS currently favored by DOE 

relies on known technology and is a relatively simple, passive system. The repository is a far more complex facility. 

Its licensing will depend upon resolution of geologic uncertainties and will be dominated by questions such as, "What 

will happen to spent fuel many centuries after the repository is sealed?" The repository licensing regulations are, 

therefore, quite different from those that apply to an MRS 

facility. 

Any institutional experience from siting and licensing 

a repository would be significantly reduced if the schedules 

for siting and licensing of the repository and the MRS 

overlap, as would be the case under the current statutory 

schedule linkages. 

The Commission finds institutional experience in 

siting and licensing an MRS could be beneficial in the 

repository program, but would be less beneficial if the 

schedules overlap as they would under the current statutory linkages. 

2. Timely Waste Acceptance 

DOE ascribes four specific benefits to timely and adequate waste acceptance: avoidance of additional at-reactor 

storage; reduction in impact on reactor operations; avoidance of delays in decommissioning; and enhancement of 

compatibility with the waste management system. 

a. Avoidance of Additional At-reactor Storage 

Under the Nuclear Waste Policy Act, DOE has signed 

contracts with nuclear utilities which state that DOE is to 

accept title to the spent fuel, transport it, and dispose of it 

in a repository. The contracts specify that these services are 

to "begin, after commencement of facility operations, not 

later than January 31, 1998, and shall continue" until all 

spent fuel is disposed of. 6The Nuclear Waste Policy Act of 

1982 required the January 31, 1998, date to be included in 

the contracts in exchange for the payment of a 1 mill per 

net kilowatt hour fee to be paid by the utilities. Therefore, 

DOE wants to accept waste as early as possible to initiate 

fulfillment of the Federal responsibility to remove spent 

fuel from the reactor sites. 

The Commission has not sought to determine the precise nature of DOE's legal obligation under the contract. 

Rather, it has assumed the statute and the contracts created 

the expectation that DOE would begin accepting title to the 

spent fuel, remove it from the reactor sites as soon as practicable after January 31, 1998, and continue to accept the 

waste on a reliable schedule until all of it is placed in a 

Federal repository. 

The repository currently is scheduled to begin operation in the year 2003. 7Unless an MRS can be available 

sooner, DOE will not be able to begin accepting waste by 

1998. The Nuclear Waste Policy Amendments Act 

(NWPAA), however, links MRS development to the repository schedule; DOE cannot begin constructing an MRS until the Nuclear Regulatory Commission (NRC) authorizes 

repository construction, which is not expected until 1998. 8 

Assuming MRS construction would take at least two years, 

a linked MRS could begin accepting waste in the year 2000 

at the earliest. Repository schedule delays would further 

postpone construction of a linked MRS and, thus, delay the 

date when DOE will accept spent fuel. 

DOE believes that if the statutory linkages to the repository schedule are removed, an MRS can be operable by 

1998.9This belief assumes that the Negotiator will find a 

site for an unlinked MRS and that licensing and construction will not be delayed by technical or political difficulties. If these assumptions prove valid, DOE could begin 

accepting waste at an unlinked MRS in 1998. 

Early acceptance of spent fuel at a repository or an 

MRS provides significant benefits to the utilities by reducing their need to expand storage capacity at reactors. 

87 

7 9 
RedUctiOriiin,At-,reaefOi. : StOagetteede.withlahM 

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. ,, ......: . ' • • •• •• - - - , 

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(2090)' 

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The economic benefit to the utilities of an unlinked 

MRS, in comparison to the No-MRS alternative, would increase if the repository were delayed. For example, an unlinked (or linked) MRS in the year 2000 with the repository 

in 2003 would reduce by about 4,000 MTU the need for 

storage at reactors and by 12 the number of reactors requiring additional storage.' 0(For this scenario the numbers are 

the same for the linked and unlinked cases.) If the repository were delayed until the year 2013, an unlinked MRS 

available in the year 2000 would eliminate the need for 

about 17,000 MTU of dry storage and would reduce the 

number of sites requiring dry storage from 62 to 34, a difnp 

88 

7 0 2 J. 0 2 
ference of 28. These and other examples are summarized in 

Table 8.1.' 

The schedule and capacity limits in the current law reduce substantially the benefits of early acceptance. DOE 

can only accept spent fuel at an MRS under the current 

linkages until the capacity limits specified in the NWPAA 

are reached. The statute limits the amount of waste at an 

MRS to 10,000 MTU until the repository begins to accept 

waste and to 15,000 MTU at any one time. As can be seen 

in Table 8.1, if the repository is delayed to 2013, a linked 

MRS would only reduce the number of MTU in dry storage 

by 6,000 MTU compared to about 17,000 MTU for an unlinked MRS, and would reduce the number of sites requiring dry storage from 62 to 58, a difference of 4, compared 

to a difference of 28 for an unlinked MRS. Thus, in the 

event the repository is delayed to 2013, the benefits of early acceptance would be significantly reduced by an MRS 

limited by the current capacity limits even if there were no 

schedule linkages. Far fewer utilities would benefit from 

such an MRS. 

The Commission finds building an MRS linked to 

the repository schedule would not allow DOE to accept 

spent fuel by 1998, and utilities would be required to expand at-reactor storage. An unlinked MRS, however, 

could allow DOE to begin to accept spent fuel at an earlier date than a linked MRS and could reduce utilities' 

needs for additional at-reactor storage. 

b. Interference with Reactor Operations 

DOE believes the earlier the Federal government begins to accept waste, the less likely at-reactor storage could 

interfere with reactor operations. While this may be true, 

the Commission has not found that interference with reactor operations has been a significant problem to date. The 

utilities have been routinely handling spent fuel and storing 

it on-site in spent fuel pools for many years without difficulty. It is likely they can continue to do so in the future. 

Technology for dry storage has been developed and is being used at two sites and its use is expected to increase in 

the future. The NRC believes dry storage can be done safely. The Nuclear Regulatory Commission has stated spent 

fuel can be stored safely on-site throughout the operating 

life of a facility, and for at least 30 years following reactor 

shutdown, even assuming a 30-year extension of the original license. 12 

It is possible, however, that some utilities will be unable to store spent fuel on-site in dry storage because of 

technical obstacles (such as lack of suitable land) or institutional problems associated with obtaining licenses for additional on-site storage." Repeated delays in the repository 

program and mounting spent fuel inventories at reactor 

sites could result in resistance to utility efforts to expand 

on-site storage capacity. At some point, opposition to continued on-site storage could disrupt the orderly operation of 

some reactors. 

It is also possible to postulate situations in which it 

would be desirable, as a result of an operational emergency, to remove spent fuel from a reactor site. For example, an accident at a nuclear power plant could make it 

advantageous to have the plant's spent fuel pool available 

to assist with decontamination of the reactor and to store 

debris. It would be desirable to have a facility available to 

accept spent fuel in the event of such an emergency and 

also to prevent the shut down of otherwise satisfactorily 

operating nuclear power plants because of lack of storage 

capacity for spent fuel. 

Possible interference with reactor operations was addressed in 1982 when the Nuclear Waste Policy Act was 

being developed. To prevent the disruption of reactor operations by the inability to provide on-site storage, Congress 

provided for limited Federal interim storage to "...prevent 

disruptions in the orderly operation of any civilian nuclear 

power reactor that cannot reasonably provide adequate 

spent nuclear fuel storage capacity at the site of such reactor when needed." 14The Federal government was authorized to provide up to 1,900 MTU of Federal interim 

storage to be funded by user fees collected from the utilities that sought to use the facilities. The utilities were required to identify the need for such facilities by January 1, 

1990. 

No utility has indicated an interest in obtaining such 

services and the opportunity to do so is to expire at the end 

of 1989. One possible reason no utility expressed an interest in Federal interim storage is that situations of the sort 

contemplated by the statute in which the utility cannot provide on-site storage are difficult to predict in advance. In 

addition, problems are more likely to surface as more reactors run out of pool storage capacity. Only a few reactors 

were expected to do so before January 1, 1990. Furthermore, the statute as written did not provide backup storage 

for operational emergencies on-site or for unexpected reactor shutdowns that were not related to expanding on-site 

storage capacity. 

An unlinked MRS could provide this backup capability. A linked MRS, which would be available later than 

an unlinked MRS, could provide the same backup capability but would not be available until about three years before the repository. The longer the repository is delayed, 

the longer the availability of the backup capacity would be 

delayed. 

The Commission finds the difficulty in providing 

sufficient on-site storage could, in some instances, interfere with reactor operations. An MRS could serve as a 

backup facility in such instances and could be useful 

89 

7 0 
during emergencies that require expeditious removal of 

spent fuel from reactor pools. These benefits could be 

provided by a linked MRS but, under current law, a 

linked MRS would not be available until three years before the repository is scheduled to begin to accept waste. 

c. Decommissioning Delays 

DOE asserts that early waste acceptance could prevent 

delays in decommissioning by relieving the need to store 

spent fuel on-site. DOE does not elaborate on this argument, but the Commission has examined this argument in 

some detail. 

Decommissioning activities are covered by the NRC's 

regulations for the licensing of nuclear power plants. 15Decommissioning cannot be completed until all spent fuel is 

removed from the site and the site is decontaminated. 16 

However, under DOE's current contracts, spent fuel will 

not be transported off-site until at least five years after it is 

discharged from the reactor. The NRC's decommissioning 

regulations provide two options: (1) after the spent fuel is 

removed from the site, the facility and equipment can be 

decontaminated to a level that permits release of the property for unrestricted use shortly after reactor operations 

cease; or (2) after the fuel is removed from the reactor's 

pressure vessel, the facility can be maintained in a condition that allows safe storage for up to 60 years following 

reactor shutdown and then decontaminated and decommissioned. Some utilities may choose the second option because it allows the radioactive contaminants to decay prior 

to decommissioning and thereby reduces both the amount 

of radioactive waste to be disposed of and the occupational 

exposures during decontamination and dismantling. If a 

utility chooses the second option, failure to remove spent 

fuel from the site is unlikely to delay final decommissioning. If a utility chooses the first option, failure to remove 

the spent fuel within five years could delay decommissioning. 

However, failure to remove the spent fuel from the 

site after reactor shutdown is not without consequence, 

even if the utility elects to defer final decommissioning. 

After a reactor shuts down and the NRC converts the facility operating license to a possession-only license, the extensive crew of licensed reactor operators, health physicists, 

and managers will no longer be needed to manage the reactor. The trained and experienced crew will likely disband 

and only the minimum number of personnel required to 

maintain the pool and site security will remain. Although 

the licensing requirements are less stringent after shutdown 

than during operations, they are more stringent and costly 

to implement than if the fuel has been removed from the 

site. Maintaining spent fuel at a reactor after shutdown is 

expected to cost between $2 million to $3 million more per 

site per year than if all spent fuel were removed." 

The staff at an MRS—trained and experienced fuel 

handlers, health physicists, and security staff—would be 

available at all times to manage the spent fuel. Providing 

the necessary personnel at a single site rather than at individual utilities would be more efficient and would result in 

cost savings to the utilities and ratepayers. Workers at an 

MRS will be better equipped to perform the routine spent 

fuel handling operations that would occur only infrequently 

at a shutdown reactor and they would be more able to handle emergencies that might occur. 

As Figure 8.1 shows, only a limited amount—about 

1,200 MTU—of storage capacity at a central facility would 

be required to take care of spent fuel five years old or older 

from shutdown reactors at sites with no other operating reactors until the year 2010. 

The Commission finds that although spent fuel can 

be safely stored at reactor sites after reactor shutdown, 

there is some benefit to providing a central storage facility for spent fuel from shutdown reactors. 

d. Improved System Compatibility 

According to DOE, early acceptance of the waste also 

promotes greater standardization in the Federal waste management system. Standardizing spent fuel forms and waste 

package types would facilitate transportation and handling, 

reduce costs, and increase reliability. Conversely, the proliferation of waste forms and packages could increase total 

costs and reduce the reliability of the waste management 

system. 

Unless a standardized storage form or package is required by DOE or NRC, utilities will respond to their interim storage needs on an individual, cost-effective basis. 

Some may consolidate; others may opt for dry storage 

using a variety of available technologies. Spent fuel currently is stored in two different types of dry storage facilities (metal casks and concrete bunkers) and several utilities 

are actively exploring options for additional types of dry 

spent fuel storage. (For example, Duke Power Company 

has submitted to the NRC a license application for a concrete bunker type of storage facility that will hold 24 pressurized water reactor (PWR) assemblies in each canister. 

DOE does not currently have a transportation cask that will 

handle such a large canister.) 

Contracts between DOE and the utilities include specifications for "standard fuel." Fuel that has been consolidated or that exceeds certain limits for length and crosssection dimensions is considered "nonstandard" under the 

contract specifications. 18Though obligated to accept nonstandard spent fuel, DOE may accept nonstandard fuel on a 

90 

7 0 2 2 1 
Figure 8.1 Spent Fuel in Dry Storage and at Shutdown Sites 

without MRS or Repository 

Thousands of MTU at Least Five Years Old 

16 

Shutdown Sites 

—9— Dry, Operating Sites 

Source WACUM Simulator 

12 

10 

12.548 

10.1 

1.03 t.-118 1.118 

2007 

I I 

2011 2013 

8.019 

6.12 

4.418 

1.975 

1.286 

0.722• 0.722 

0.13 0.162 0.163 

1995 1999 2003 

13.924 

different schedule than standard fue1. 19DOE also may require utilities to repackage nonstandard spent fuel in a 

package compatible with DOE's transportation system. If 

the utilities are not required to repackage, DOE will have 

to provide a fleet of transportation casks capable of handling consolidated and unconsolidated fuel and a wide variety of packages. 

Standardization of the waste management system 

could be improved in at least three ways: 

(1)DOE or NRC could specify standard requirements 

for the waste form or package that will be accepted 

from the utilities to fit the shipping casks that will 

be used for transportation. 

(2)DOE could develop and provide to the utilities, or 

require utilities to purchase, a fleet of standardized 

dual-purpose casks and develop a transportation 

system to accommodate them as the Tennessee 

studies suggest. 20 

(3)An MRS could be built early, thereby reducing the 

number of utilities that will need to provide additional at-reactor storage with a variety of fuel 

forms and packages. 

Before DOE or NRC can specify either the waste form 

(consolidated or unconsolidated) or the package that should 

be adopted, several technical questions need to be 

answered: 

(1) In what geologic medium will the waste be placed 

91 
for disposal? (This is necessary to describe the final disposal package and to determine whether rod 

consolidation would be desirable with regard to repository loading or to minimize the number of 

waste packages.) 

(2)What constitutes an optimum transport cask for 

rail and for truck? 

(3)Will an economically viable dual-purpose cask be 

developed and made available in the near future? 

Until these questions are answered, it is unlikely either 

DOE or NRC can specify a preferred waste form or package. These questions are not likely to be answered soon. 

Having a family of standardized dual-purpose casks 

available early would enhance standardization. Whether a 

dual-purpose cask can be designed and licensed within a 

reasonable time remains to be seen, and the effects of having non-standardized waste forms or packages will be felt 

on transportation from the reactor either to an MRS or a repository. These effects will increase the longer DOE delays 

taking the spent fuel from the utilities. 

Whether an MRS could be made available early is 

also uncertain. However, if an MRS were available in 

1998, it is likely DOE would have less variety of spent fuel 

forms and packages than if one were to be available at a 

later date. 

The Commission finds that if standardization is not 

mandated by the Federal government, an MRS facility 

that accepts waste early could promote standardization 

by reducing the variety of spent fuel forms and packages to be handled and could limit the number of 

reactors providing storage for other than intact, unpackaged spent fuel. 

3. Schedule Confidence 

DOE asserts that a Federal commitment to proceed 

with an MRS would increase confidence that the Federal 

government is using all available means to ensure timely 

assumption of its responsibility to accept spent fuel for disposal. To achieve this schedule confidence, the DOE wants 

to demonstrate the government's ability to accept and handle large quantities of spent fuel at high annual rates. The 

Commission agrees this is one way to increase confidence 

in the waste management program but suggests another 

way is for DOE to demonstrate progress towards developing a repository. These two means of achieving confidence 

are not incompatible as long as the MRS does not divert 

DOE's resources from the repository program. If the MRS 

could be built and licensed in advance of repository construction and licensing, it would be unlikely to divert DOE 

resources from the repository program and could enhance 

confidence that the Federal government is using all available means to ensure timely assumption of its responsibility to accept spent fuel for disposal. 

If, however, the MRS schedule is linked to that of the 

repository, the MRS could be delayed and its schedule will 

be subject to the same uncertainties as the repository schedule. It is also more likely that the MRS could divert resources from the repository program if DOE attempts to 

site, construct, and license the facilities simultaneously as it 

would be required to do under the existing schedule linkages. Thus, a linked MRS will not serve to increase schedule confidence. 

Uncertainties about DOE's ability to site an MRS 

within a reasonable time also must be considered. Siting 

any waste management facility in the United States provokes controversy. An MRS siting process could be protracted and traumatic and could divert DOE's attention 

from the repository program. If efforts to site an MRS facility became bogged down in controversy, then confidence 

in DOE's ability to manage the repository program could 

also be questioned. These problems could be reduced to 

some degree if the Nuclear Waste Negotiator sited the 

MRS. Controversy also may be reduced if MRS functions 

and schedule were constrained in such a way as to dispel 

the public's fears the site would become a de facto repository. However, these concerns about siting an MRS make 

the MRS schedule almost as uncertain as the repository 

schedule and severely limit any benefits associated with 

schedule confidence. 

The Commission finds an MRS facility would assist 

utilities to plan for waste disposal if an MRS would be 

available by a certain date. However, concerns about 

siting an MRS make the MRS schedule almost as uncertain as the repository schedule and severely limit any 

benefits associated with schedule confidence. 

4. Flexibility 

DOE advocates the need for flexibility in the nuclear 

waste system during the development and operation of the 

repository. According to DOE, an MRS facility would help 

stabilize the waste program by relieving pressure on the repository program to meet specific deadlines. Unexpected 

difficulties could then be resolved during the site characterization process without the pressure of time deadlines. If 

a more deliberative approach were taken to building the 

repository, then DOE would have more time to take a 

sound scientific approach towards resolving technical 

uncertainties. 

Many of the DOE's arguments in support of putting 

flexibility in the system attempt to build redundancy into 

the system to prevent a "worst case scenario." From an 

engineering perspective, redundancy in designing such a 

92 

7 0 3 
system is essential to prepare for the unexpected and 

unforeseen. Storing spent fuel in a central location would 

provide redundancy by providing surge capacity before and 

after the repository is in operation. An MRS facility might 

also supplement repository operations by simplifying waste 

preparation and transport. This could be beneficial, particularly if the repository were significantly delayed. 

The Commission finds that an MRS facility would 

provide overall system backup to repository operations. 

However, this flexibility would be significantly reduced 

by the current statutory linkages because the MRS 

would not be available until shortly before the repository is available. 

C. Tennessee Studies on the Need for an MRS 

Facility 

The State of Tennessee maintains an MRS facility is 

not needed and is too expensive; Tennessee advocates an 

Integrated No-MRS (I-No-MRS) system. According to the 

State, an Integrated No-MRS system "is by far the most 

preferred system, taking into account all public policy issues, including technical feasibility, institutional feasibility, 

cost, risks and impacts." 21 

Tennessee's concept of an Integrated No-MRS originated in response to the Department of Energy's 1985 proposal to build an MRS facility near Oak Ridge, Tennessee. 

Tennessee's concept is based on previous studies performed in 1985 and 1986 evaluating DOE's proposal and 

on two recent studies performed by the University of Tennessee. 22It also draws on the position that the Tennessee 

Valley Authority presented to the Commission during public hearings held on January 17, 1989. The I-No-MRS system relies on dual-purpose casks to store spent fuel at 

reactor sites; transport spent fuel to the repository; and provide buffer storage at the repository until the waste can be 

packaged and emplaced for disposal. One of the Tennessee 

studies suggests the casks could be purchased by DOE and 

leased to the utilities. 23Tennessee urges DOE to work with 

utilities to upgrade their cask handling facilities to accommodate dual-purpose casks with as large a capacity as possible, and Tennessee asserts that, if the technology proves 

feasible, utilities might consider on-site consolidation of 

spent fuel to further increase cask capacities. Under the 

I-No-MRS system, spent fuel from the reactor sites would 

be shipped almost entirely by rail. For reactors without direct rail access, the spent fuel would be shipped by barge or 

heavy haul truck to the nearest railhead. 

The State and its supporting studies contend a system 

without an MRS facility has numerous advantages: (1) deleterious transportation effects are minimized based on an 

evaluation of four proxy measures: number of casks 

shipped, trip-miles, ton-miles, and cask-days; 24(2) a comparison of nominal system costs (of the I-No-MRS, DOE's 

No-MRS, and DOE's Integrated or I-MRS system) revealed dramatic cost savings with the I-No-MRS system; 25 

(3) an I-No-MRS system provides great flexibility in the 

waste management system because managing spent fuel 

safely would not be dependent on meeting the repository 

schedule or keeping the repository open; 26(4) the focus of 

the program would remain on the primary goal of deep 

geologic disposal of nuclear waste if an MRS facility were 

not built; 27(5) reliability in the system would be retained 

without an MRS facility. If an integral MRS facility were 

built and all the pools at reactors were filled, any problem 

in the system—shipment failures, equipment malfunctions, 

safety questions, licensing difficulties—would bring the 

system to a "screeching halt"; 28(6) principal reliance on 

at-reactor storage, with Federal interim storage available if 

utilities need it, is consistent with the Nuclear Waste Policy 

Act of 1982. 29 

The State of Tennessee does not support an MRS but 

urges a number of requirements be mandated in law if the 

MRS Review Commission recommends an MRS facility be 

built. The State wants a negotiated siting approach, whereby the MRS is located in a State if and only if the host 

State finds it acceptable and agrees through a signed and 

legally enforceable agreement with the Federal government. Tennessee also advocates that any MRS should be 

user-funded—that is, paid for only by the utilities that use 

it. Last, the State recommends retaining the statutory linkages in the Nuclear Waste Policy Amendments Act of 

1987.3° 

D. MRS Review Commission's Analysis of 

Tennessee Studies 

The State of Tennessee draws on a variety of studies 

and the views of the Tennessee Valley Authority to build its 

case against an MRS facility. The Commission believes 

Tennessee makes a number of valid arguments. However, 

there are some important weaknesses in Tennessee's arguments, as there were in DOE's. 

Tennessee's proposed I-No-MRS system relies in 

large part on the development and use of dual-purpose 

casks. Certain assumptions are made about their availability and costs. As the analysis in Chapter Four indicates, 

such casks may become available in the next few years, but 

there are uncertainties regarding when they will become 

available and whether they will eliminate the need for extra 

handling of the spent fuel. If an economical cask were developed that could be used for transportation after a period 

of prolonged storage without the need to reopen the cask or 

handle the spent fuel, it would provide many benefits to the 

waste management system. Whether or when such a cask 

93 
providing all of the postulated benefits would be available 

is uncertain. 

1. Transportation Impacts 

The State believes the transportation impacts of the 

I-No-MRS system would be less than an MRS system according to four proxy measures: number of casks shipped; 

trip-miles; ton-miles; and cask-days. The reason the I-NoMRS system shows less impacts with regard to these proxy 

measures is because the Tennessee studies assume large 

cask capacities, and that 87 percent of all spent fuel shipments from the reactors will be by rail. (See Chapter Five.) 

Even though the Commission has found that the risks 

from transportation of spent fuel are expected to be small, 

whether or not an MRS is built, these risks are perceived 

by many to be quite large. Therefore, improvements in the 

transportation system from the reactors that could reduce 

the numbers of shipments and people affected by the shipments might be beneficial with or without an MRS in the 

system. The Commission agrees that DOE should explore 

ways of increasing the efficiency of the transportation system from the reactors to the extent practicable and economically justifiable. As Tennessee recognizes, DOE is 

gathering data on cask handling and transportation capabilities in its Facility Interface Capability Assessment 

(FICA) that will enable it to explore these options. However, whether the transportation system from the reactors 

could or should be upgraded to the extent postulated by 

Tennessee remains to be seen. 

Even if the changes recommended by Tennessee were 

possible, transportation impacts alone do not justify acceptance or rejection of an MRS. As the analysis in Chapter 

Five shows, radiological and non-radiological risks associated with the various transportation alternatives are small 

and within regulatory limits under all of the options evaluated. Thus, transportation risk does not provide a basis for 

choosing between the No-MRS and MRS alternatives. 

2. System Costs and Financing 

The principal differences in cost between the University of Tennessee study and DOE's studies are attributable 

to Tennessee's assumptions of major cost increases, similar 

to those observed with other nuclear facilities, for the MRS 

and repository in the waste management system, and favorable assumptions regarding the costs of activities performed at reactors, including dual-purpose cask costs. 

DOE's studies rely on engineering estimates of the costs of 

these activities which are generally lower than Tennessee's 

probabilistic estimates. This Commission's analysis used a 

methodology and cost assumptions that were similar to 

Tennessee's and, at least in the early years, show the NoMRS system to be substantially less expensive than the 

MRS system. However, the Commission's analysis shows 

that if there were extensive delays in opening the repository, and if the costs of delaying the removal of spent fuel 

from shutdown reactors were included as a component of 

total system costs, systems that include an unlinked MRS 

(if available early) would have a lower undiscounted net 

cost than waste systems that do not. If costs were discounted and expressed as present value, the No-MRS system would retain its cost advantage, but the advantage 

would narrow if the repository were delayed to 2023. 

There are great uncertainties associated with all of the 

cost estimates, but the cost differences between the MRS 

and No-MRS options are likely to be less than the Tennessee studies indicated. More importantly, these uncertainties 

in the cost estimates make it difficult and perhaps unwise 

to use cost as the sole or primary reason for determining 

the need for an MRS. 

As described more fully in Chapter Seven, the Commission agrees with the State of Tennessee's arguments that 

if an MRS is built, it would be more equitable if the costs 

attributable to the MRS were borne by the utilities using 

the facility. In this way, there will be a better correlation 

between ratepayers who actually benefit from the facility 

and those who will pay the associated costs. Furthermore, a 

user-fee system would be more efficient because it would 

encourage utilities to choose the most efficient storage alternative. 

3. System Flexibility 

Tennessee asserts the Integrated-No-MRS system provides great flexibility in the waste management system because managing spent fuel safely would not be dependent 

on meeting the repository schedule or keeping the repository open. Tennessee believes at-reactor storage would not 

affect reactor operations or delay decommissioning. According to the Tennessee studies, spent fuel could be safely 

stored in dual-purpose casks at the reactors until the repository is available to accept the waste. 31Spent fuel pools 

could be dismantled after reactor shutdown because the 

casks could be transported without returning them to the 

pools.32Hoskins asserts that if it were desirable to move all 

spent fuel from the sites of shutdown reactors, the dualpurpose casks could be moved to an MRS and stored there 

until a repository was available. 33However, according to 

Hoskins, this would not be necessary, unless the repository 

is delayed beyond the year 2020 when decommissioning 

could become a pressing problem. He also asserts that it is 

unnecessary to make a decision on whether this type of 

MRS is needed until after the year 2000 when better information on the prospects for repository operation will be 

available. 34The Tennessee studies suggest dual-purpose 

casks could also be used for buffer storage at the repository 

94 

0 2 7 
to provide flexibility in packaging operations and decouple 

shipments from the reactors from possible disruptions in 

repository operations. 35 

If the Commission were certain that a dual-purpose 

cask could be developed that could be used for prolonged 

storage and then transported without having to be returned 

to a spent fuel pool or opened, then it might conclude that 

the I-No-MRS system would provide a great deal of flexibility. However, it is not clear that such a cask can or will 

be developed. In any event, it is not prudent to drain the 

spent fuel pools while fuel remains on-site. If a cask developed a problem and it became necessary to transfer the 

spent fuel to another cask, the pool would be needed. 

Therefore, a waste management system with an MRS 

which would allow removal of the spent fuel from the sites 

would be more flexible than the No-MRS option. 

4. De Facto Repository and the Need for Linkages 

The State of Tennessee and the Tennessee Valley Authority, among others, assert that the Nation's focus should 

remain on the primary goal of deep geologic disposal. Hoskins states that the I-No-MRS system favors scheduling 

disposal at the earliest possible time because it keeps the 

pressure on DOE, the utilities, and everyone involved to 

press on with the repository program. It also avoids the 

distraction and diversion of resources from the repository 

program. 36In its Final Comments to the Commission, 

Tennessee states, "Moreover, Tennessee would consider interim storage at an MRS as an indication that DOE is not 

effectively dealing with the disposal problem and that such 

actions are a prelude for allowing the MRS to become a defacto [sic] repository." 37Tennessee asserts that the linkages were included in the NWPAA to ensure that building 

the MRS would not reduce the Federal government's commitment to developing a permanent repository. 38According to Tennessee, the linkages were made especially 

stringent to compensate for the fact that the repository program was focused on characterizing a single site rather than 

three sites. 39 

The Commission disagrees that interim storage at an 

MRS would be an indication that DOE is not effectively 

dealing with the disposal problem. One of Tennessee's own 

studies recognizes "a considerable period of time will be 

necessary to evaluate a repository site, and that a more experimental, evolutionary, flexible, and cheaper approach to 

site investigation, with less pressure from a rigid schedule, 

would be beneficial and, perhaps, avoid a perceived failure 

of the program in the mid-1990s." 4° Dr. E. William 

Colglazier, the author of the study, supports the I-No-MRS 

option, but he also states, 

Even though it is technically feasible and cost effective to store on-site at reactors for the foreseeable future, as assumed in the Integrated NoMRS case, the pressure for government acceptance of utility spent fuel may increase in the 

1990's, especially if the repository program begins to falter. This pressure for early federal acceptance of spent fuel is one of the reasons for 

the rigid repository development schedule in the 

NWPA. How to deal with this pressure is, for me, 

one of the major problems with the Integrated 

No-MRS option.'" 

The Commission agrees a balance must be struck between providing enough flexibility for a sound repository 

development schedule and maintaining sufficient pressure 

to move forward with the repository program. The existing 

linkages, particularly those that tie the MRS schedule to 

that of the repository, keep pressure on the repository program but severely limit the flexibility of the waste management system. 

The State of Tennessee asserted that progress on the 

MRS should remain linked to the repository schedule as 

mandated in the NWPAA. As the foregoing analysis of 

DOE's postulated benefits shows, the existing statutory 

linkages significantly reduce the benefits associated with 

an MRS. However, the Commission observes that Congress, for many years, has also expressed concern that an 

unlinked MRS might be regarded as a de facto repository 

and could reduce the impetus for proceeding with permanent geologic disposal. The Commission recognizes this 

expression of congressional will, Tennessee's sentiments, 

and the concerns others voiced during the Commission's 

hearings. 

Although the Commission does not believe there is 

a technical basis for the linkages, the Commission finds 

that, in light of congressional and other concerns, some 

linkages are justified. 

5. System Reliability 

Tennessee asserts the I-No-MRS system is more reliable than the MRS system. The State argues that once spent 

fuel pools at the reactors are filled, the breaking of any link 

in the MRS chain—shipment to the MRS, equipment malfunction, safety questions, licensing difficulties—could 

bring the waste management system, and eventually nuclear plants, to a halt. 42Hoskins and Colglazier strongly criticize the MRS option because the controversy over siting 

and licensing an MRS makes its availability uncertain. 43 

Colglazier questions whether Congress would be willing to 

impose an MRS on a State considering his view that an 

MRS is not absolutely necessary." 

The Commission agrees that if all spent fuel is to be 

shipped through an MRS, it could indeed become a bot95 
tleneck in the system if a disruption in its operations were 

to occur. Furthermore, the ability to site an MRS successfully is far from assured. However, if an MRS were to 

be used as a storage-only facility through which only some 

spent fuel would flow, it would be less likely to become the 

bottleneck Tennessee suggests. 

Furthermore, the No-MRS option is also somewhat 

unreliable. Whether utilities will be able to expand on-site 

storage capacitY in all cases is questionable. Having a 

backup storage facility in the system would provide redundancy that could be useful either to remove the spent fuel 

from the sites or to prevent disruptions in the orderly operation of reactors if utilities were unable to expand their onsite storage facilities. 

6. Intent of Congress 

Tennessee asserts that principal reliance on at-reactor 

storage until a repository becomes available, with Federal 

interim storage available if utilities need it, is consistent 

with the Nuclear Waste Policy Act of 1982. As Tennessee 

indicates, interim storage of spent fuel at reactor sites and 

the provision of 1,900 MTU storage capacity by the Federal government is consistent with the NWPA. However, the 

ability to apply for Federal interim storage expires on January 1, 1990 and the statutory scheme in the Nuclear Waste 

Policy Act was premised on the expectation that a repository would be available to accept spent fuel by January 31, 

1998. 

In the 1987 amendments to the Nuclear Waste Policy 

Act, Congress authorized an MRS and created this Commission to determine whether an MRS should be built. 

Therefore, the Commission cannot determine from the Nuclear Waste Policy Act, as amended, a clear congressional 

intent to rely solely on at-reactor storage, particularly if the 

repository is significantly delayed. 

Tennessee criticizes DOE for elevating early spent 

fuel acceptance by the government to an equal or superior 

role to that of disposal in its mission, and asserts this policy 

is contrary to the NWPA, as amended. 45Tennessee claims 

that DOE uses the MRS to provide increased confidence in 

the government's ability to accept spent fuel from the utilities on a timely basis when the only step that will build 

confidence in the DOE program is orderly progress in development of the repository. Tennessee states, "DOE's 

analysis appears to be positioning the MRS to accommodate an extended delay in the repository program, which 

would decrease rather than increase confidence in the program." 46As the Commission stated in Part B.1 of this section, both early acceptance of spent fuel and demonstrating 

progress towards disposal of spent fuel would enhance confidence in the waste management program and these two 

means of achieving confidence are not necessarily 

incompatible. 

7. A Negotiated Approach 

The Commission agrees that a negotiated approach is 

preferable since, according to the NWPAA, such an approach would directly involve the State or Indian Tribe in 

delineating the terms and conditions under which an MRS 

would be acceptable, and would preserve the State or Indian Tribe's right to disapprove. However, if it is determined that an MRS would provide significant benefits, the 

option of DOE siting should be preserved. 

Section Two: MRS Review Commission's 

Summary of Advantages and Disadvantages of an MRS 

After reviewing the extensive work undertaken by the 

Department of Energy and the State of Tennessee, other 

views expressed to the Commission, and the Commission's 

own studies, the Commission summarized the following 

advantages and disadvantages of having an MRS: 

A. Advantages 

The most important advantages that could be realized 

by building an MRS facility are: 

1. An MRS could serve as a backup facility to prevent 

situations in which inability to expand on-site storage could interfere with reactor operations or to 

handle operational emergencies that require expeditious removal of the spent fuel from the reactor 

pool. 

2. An MRS facility would provide for timely removal 

of spent fuel from decommissioned reactors. Although the waste could be stored at reactor sites 

safely for up to 100 years, the fuel could be stored 

more efficiently and safely at a central facility. 

3. An MRS facility would provide overall system 

backup to repository operations. From an engineering perspective, redundancy in designing such a 

system is essential in the event the unexpected and 

96 

7 0 2 0 9 
unforeseen happens. An MRS facility would provide surge capacity before and after the repository 

opens. 

4. Utility requirements for on-site storage after 1998 

would be reduced and fulfillment of the Federal responsibility to begin to remove spent fuel from the 

reactor sites would be initiated at the earliest possible time. 

5. Institutional experience in siting and licensing an 

MRS could be beneficial to the repository program. 

6. If standardization is not mandated by the Federal 

government, then an MRS facility that accepts 

waste early could promote standardization by reducing the variety of spent fuel forms and packages 

to be handled and limiting the number of reactors 

providing storage for other than intact, unpackaged 

spent fuel. 

The benefits of providing backup to on-site storage or 

for operational emergencies, surge capacity, early waste acceptance, institutional experience in siting and licensing, 

and standardization would be significantly reduced by the 

capacity and schedule linkages currently contained in the 

NWPA, as amended. The benefits of removing spent fuel 

from shutdown reactors would also be reduced by the linkages if the repository is delayed beyond 2013. 

Some of the advantages of building an MRS facility 

enumerated above would be significantly reduced if the repository is available early. Institutional lessons learned in 

licensing an MRS facility would not be of much use to the 

repository program if the time frame for building both facilities overlapped. The overall cost advantages to the nuclear waste management system would diminish. The variety of spent fuel forms and packages to be handled by the 

waste management system would be less. The need to 

remove spent fuel from decommissioned reactors is small 

until after 2013. 

B. Disadvantages 

The major disadvantages in building an MRS are: 

1.An MRS facility could divert the Nation's focus 

from deep geologic disposal and become, in effect, 

a de facto repository. 

2. An MRS facility could divert Department of Energy 

resources from the repository program. 

3. Siting an MRS facility is likely to be extremely difficult, no matter what its capacity limit or location. 

4. An integral MRS facility through which all spent 

fuel must pass could create a bottleneck in the system that would disrupt reactor and repository 

operations. 

5. Unless a repository were delayed beyond 2013 and 

an unlinked MRS were built at an early date, the 

cost of a system including an MRS would exceed 

the system cost of a No-MRS option. 

• • • 

Drawing upon the quantitative analyses in Chapters 

Four through Seven and the qualitative analyses in Chapter 

Eight, the Commission's conclusions and recommendations 

are described in Chapter Nine. 

97 

7 
Chapter Eight Notes 

1.Department of Energy, System Studies, Tasks A-J; Isaacs, 

Thomas H., Associate Director, External Relations and Policy, 

Office of Civilian Radioactive Waste Management, Department of 

Energy, "DOE's Position on the Monitored Retrievable Storage 

(MRS) Facility," Prepared Remarks, Briefing Before the Monitored Retrievable Storage Review Commission, May 25, 1989, 

(Hereafter cited as Isaacs, Prepared Remarks); McWherter, 

Ned, Governor of the State of Tennessee, "Tennessee's Position 

on the MRS: Final Comments to the Monitored Retrievable Storage Review Commission by the State of Tennessee," July 1989 

(Hereafter cited as Tennessee's Final Comments); Colglazier, 

E. William, "Rethinking the MRS: Public Policy Issues Surrounding Monitored Retrievable Storage of Spent Nuclear Fuel-Final 

Report to the State of Tennessee," June 1989 (Hereafter cited as 

Colglazier, Final Report); Hoskins, Raymond E., "A Systems 

Evaluation of the High-Level Waste Management System Based 

on Integration of Dual Purpose Cask into the System as an Alternative to DOE's Proposed Monitored Retrievable Storage Facility 

as an Integral Part of the System Final Report," June 1989 (Hereafter cited as Hoskins, Final Report). 

2. DOE does not analyze cases in which the repository is delayed beyond the year 2013 and Tennessee's studies do not include scenarios extending beyond 2008. 

3. Isaacs, Prepared Remarks, p. 9. 

4. Isaacs, Prepared Remarks, pp. 11-12. 

5. Isaacs, Prepared Remarks, p. 10. 

6. 10 CFR 961.11, Article II. 

7. Isaacs, Prepared Remarks, pp. 4, 8. Department of Energy, 

"Draft 1988 Mission Plan Amendment," DOE/RW-0187, June 

1988 (Hereafter cited as DOE/RW-0187), p. 15. 

8. DOE/RW-0187, p. 15. 

9. Isaacs, Prepared Remarks, p. 4. 

10.These numbers were generated by the Nuclear WAste 

Cost Data Base and SimUlation Model (WACUM). See Appendix G. 

11.A recent study submitted to the Commission by the Edison Electric Institute shows similar effects. See Edison Electric 

Institute, Utility Nuclear Waste and Transportation Program, "An 

Evaluation of the Role of a Monitored Retrievable Storage Facility," August 1989. 

12.Waste Confidence Decision Review, 54 FR 39767 (September 28, 1989). See also, Chapter Three, Note 20. 

13.It cannot be said with certainty that every reactor can use 

dry storage to achieve life-of-plant storage. 

14.42 U.S.C. § 10151. 

15.Nuclear Regulatory Commission, "General Requirements for Decommissioning Nuclear Facilities," 53 FR 24018 

(June 27, 1988) (Hereafter cited as 53 FR 24018). 

16.53 FR 24018, 24019. 

17.Pacific Northwest Laboratory, "MRS Systems Study 

Task G Report," PNL-6876, April 1989, p. 3.19. 

18. 10 CFR 961.11, Appendix E. 

19. 10 CFR 961.11, Article VI, Section A(2)(b). 

20. Hoskins, Final Report, pp. IV-2 to IV-3 and IV-20 

to IV-21. 

21. Tennessee's Final Comments, p.1. 

22. Colglazier, Final Report; Hoskins, Final Report. 

23. Hoskins, Final Report, IV-38. 

24. Tennessee's Final Comments, p. 6. 

25. Tennessee's Final Comments, p. 6. 

26. Hoskins, Final Report, pp. IV-23 to IV-24. 

27. Tennessee's Final Comments, p. 6. 

28. Tennessee's Final Comments, p. 5. 

29. Tennessee's Final Comments, p. 5. 

30. Tennessee's Final Comments, p. 15. 

31. Hoskins, Final Report, pp. IV-21 to IV-26 and IV-35 

to IV-39. 

32. Hoskins, Final Report, pp. IV-23 and IV-25. 

33. Hoskins, Final Report, pp. IV-21 and IV-23. 

34. Hoskins, Final Report, p. IV-23. 

35. Hoskins, Final Report, pp. IV-25 to IV-26. 

36. Hoskins, Final Report, p. 1-15. 

37. Tennessee's Final Comments, p. 14. 

38. Tennessee's Final Comments, p. 16. 

39. Tennessee's Final Comments, p. 16. 

40. Colglazier, Final Report, p. 4. 

41. Colglazier, Final Report, p. 7. 

42. Tennessee's Final Comments, p. 5. 

43. Colglazier, Final Report, pp. 4-5, 6, 10; Hoskins, Final 

Report, pp. V-57 to V-58. 

44. Colglazier, Final Report, pp. 4-5. 

45. Tennessee's Final Comments, p. 13. 

46. Tennessee's Final Comments, p. 14. 

98 

7 0 i.1 2 1 
Chapter Nine 

Conclusions and Recommendations 

The issues assigned to the Monitored Retrievable 

Storage (MRS) Review Commission for study and recommendations encompass complex, contentious questions. 

Solutions to these problems are not susceptible to simple, 

unequivocal answers. Although there are many technical 

aspects to the questions, the responses require the application of judgment and policy considerations. 

The Commission has attempted to address its mandate 

as objectively as possible and has considered the issues 

submitted to it in a broad perspective. The Commission's 

recommendations are intended to be consistent with the 

primary goal of the Nation's nuclear high-level radioactive 

waste disposal program: to construct and operate a geological repository as expeditiously as possible, consistent with 

meeting necessary safety and other public interest 

considerations. 

The Commission has evaluated an MRS and other alternatives using at-reactor storage (No-MRS) as the basis 

for comparison. In doing its analyses, the Commission directed staff studies and was assisted by contractors. (See 

Appendix E.) 

The Commission evaluated an MRS on the basis of 

whether its advantages would exceed its disadvantages. Although studies by the U.S. Department of Energy (DOE) 

and others have shown that an MRS is more expensive than 

a No-MRS case, the Commission does not believe that economics alone should be the deciding factor in determining 

whether there should be an MRS. 

The Commission's task has been made more difficult 

by the many uncertainties that confront the national waste 

management program, especially the date when the repository will be in operation. 

Although site characterization activities are now focused on Yucca Mountain, no site has been selected yet, 

and it is not known when a site will be designated and licensed. Delays have already occurred in the anticipated 

date for repository operation, and it is expected that further 

schedule slippage will occur. Thus, one of the most important factors driving the Commission's recommendations 

has been an attempt to mitigate any adverse effects on the 

Nation's nuclear waste management disposal program that 

might result from uncertainty with respect to the repository's date of operation. 

Section One: Conclusions 

In light of the Commission's studies and the considerations noted above, the Commission has reached five 

conclusions: 

Conclusion No. 1. From a technical perspective, both the 

No-MRS and MRS options are safe. 

Although neither option is completely without risk, 

the risks are expected to be small and within regulatory 

limits, and the degree of difference in risks between the 

No-MRS and MRS options is so small that the magnitude 

of difference should not affect the decision whether there 

should be an MRS. 

Conclusion No. 2. The net cost of a waste management 

system that includes an MRS would be lower than previously estimated because of delays that have already occurred in the expected date of repository operation and the 

likelihood of further slippages of that date. 

As Chapter Six noted, the economics of an MRS 

would become more favorable if the repository were delayed and the MRS were to accept fuel as early as possible. 

These economic effects would be especially significant if 

the repository operation were to be delayed beyond 2013, 

when there will be a sharp increase in the number of nuclear power plants whose current licenses will expire. If a 

99 

7 0 2 1 
repository were not accepting spent fuel by that time, utilities would incur major additional costs because they 

would be unable to remove spent fuel from plants being decommissioned. The possibility of further delay in the repository opening therefore places the economic benefits of 

an MRS in a different and more favorable light than previously reported. 

If the repository were to be delayed to the year 2013, 

the undiscounted costs of a system without an MRS facility 

nevertheless would be slightly lower than those of a system 

that included an MRS available in the year 2000. If the 

costs were discounted and expressed as present values, assuming a 4 percent rate of discount, the No-MRS case 

would remain less expensive than the MRS case even if the 

repository were delayed to 2023. (See Chapter Six and Table 6.8.) 

Conclusion No. 3. There are no single discriminating 

factors that would cause the MRS alternative to be chosen in preference to the No-MRS alternative. 

However, the Commission finds that an MRS whose 

schedule of operation and capacity is not linked to the repository would serve the following purposes: 

a. Supplying storage for emergencies, such as after a 

nuclear power plant accident, when it would be advantageous to have the plant's spent fuel pool available for decontamination of affected reactor parts 

and storage of debris. 

b. Providing storage for utilities that have insufficient 

space in their spent fuel pool or on-site or that cannot obtain licenses for additional at-reactor storage, 

thus preventing the shut down of otherwise satisfactorily operating nuclear power plants. 

c. Furnishing storage for spent fuel from shutdown reactors, especially at sites where utilities no longer 

operate nuclear power plants. 

d. Creating economies in the waste management system if an MRS could be completed substantially in 

advance of the repository, especially if the repository were delayed beyond 2013 and an MRS were 

in operation by 2000. 

e. Allowing greater redundancy in the system in the 

event of unforeseen circumstances. 

f. Offering more surge capacity to facilitate the flow 

of spent fuel to the repository. 

g. Providing more flexibility in storage options and fu-

. turd waste preparation functions. 

h. Assisting in standardization. 

i. Initiating Federal responsibility for taking possession of spent fuel. 

None of these factors alone would warrant an MRS, 

but cumulatively they justify a facility not limited in capacity or linked to the repository schedule and operation. 

Conclusion No. 4. An MRS linked as provided in current law would not be justified, especially in light of uncertainties in the completion time for the repository. 

Consequently, the Commission does not recommend a 

linked MRS as required by current law and as proposed 

by DOE. 

For many years, Members of Congress have expressed 

concern that an unlinked MRS might be regarded as a de 

facto repository, thereby reducing the impetus for proceeding with permanent geologic disposal. The Commission acknowledges this expression of congressional will. During 

the Commission's public hearings, Members of Congress, 

congressional staff, environmental groups, and members of 

the public expressed concern that an MRS would become a 

de facto repository. Although the Commission does not believe there is a technical basis for the linkages, it agrees 

that, in light of congressional and other concerns about a de 

facto repository, some linkages are justified. 

However, as Chapter Eight indicated, the schedule 

linkage presently in the law (MRS construction may not 

begin until the Nuclear Regulatory Commission (NRC) issues a license for the repository's construction) would 

make it impossible for an MRS to become operational 

more than three years before the repository. Because of delays already experienced in the scheduled repository opening and continued uncertainty surrounding the repository's 

location and date of operation, the value of the MRS would 

be greatly diminished if its construction were tied to the 

schedule of the repository. Most of the need for an MRS 

would have disappeared because utilities would have had 

to make other arrangements for storage. 

As noted in Chapter Eight, the capacity and schedule 

linkages currently contained in the Nuclear Waste Policy 

Act (NWPA), as amended, would significantly reduce the 

benefits of providing backup to on-site storage or for operational emergencies, surge capacity, early waste acceptance, institutional experience in siting and licensing, and 

standardization. The benefits of removing spent fuel from 

shutdown reactors would also be reduced, especially if the 

repository opening were delayed beyond about 2013. 

Conclusion No. 5. Some interim storage facilities, substantially more limited in capacity and built under different conditions than the DOE-proposed MRS, are in 

100 

70 2 1 4 3 
the national interest to provide for emergencies and other 

contingencies. 

The Commission recognizes the need to provide certain services that would be in the national interest, but that 

could not be provided by an MRS restricted by the schedule linkages currently in the law. The Commission concludes that spent fuel storage for emergency and other 

purposes and storage necessary to prevent utilities from 

shutting down otherwise satisfactorily operating nuclear 

power plants would be in the national interest. Facilities to 

fulfill this national interest could be more limited in scope 

and could be built under different conditions than the DOEproposed MRS. 

• • • 

The Commission was directed by Congress to compare the alternative of at-reactor storage of spent fuel to 

storage at an MRS facility, taking into consideration the 

impact on "repository design and construction; waste package design, fabrication and standardization; and waste 

preparation." (Section 143(a)(2)(A-C) of the Nuclear 

Waste Policy Act, as amended.) Because no repository site 

has yet been chosen or licensed, it was not possible to 

make findings on any of these three items since their consideration depends upon the host rock of the repository. 

However, the Commission's recommendations are structured so that they will foster such consideration and will 

not negatively impact on repository design and construction; waste package design, fabrication, and standardization; and waste preparation. 

Section Two: Recommendations 

In view of the above conclusions, and in consideration 

of Section 143(a)(1)(C)(iv) of the Nuclear Waste Policy 

Act, as amended, the Commission submits three recommendations for "improving the flexibility of the repository 

development schedule, and providing temporary storage of 

spent nuclear fuel accepted for disposal": 

Recommendation No. 1. Congress should authorize 

construction of a Federal Emergency Storage (FES) 

facility with a capacity limit of 2,000 metric tons of 

uranium (MTU). 

In light of the continuing delay in building a repository, the Commission believes it would be in the national 

interest to have available a safety net of storage capacity 

for emergency purposes, such as an accident at a nuclear 

power plant, which would make it advantageous to have 

the plant's spent fuel pool available for decontamination of 

affected reactor parts and for storage of debris. 

If the facility proposed in Recommendation No. 2 

were not available, the FES also could be used for storing 

spent fuel from otherwise satisfactorily operating nuclear 

power plants that would have to be shut down because of 

insufficient on-site storage. 

Except for the fact that it would be used primarily for 

emergency purposes, the FES would be similar to the Federal Interim Storage (FIS) facility called for in Section 135 

of the Nuclear Waste Policy Act of 1982. Likewise, limitations on using the FES for reactors facing imminent shutdown due to lack of storage facilities would be the same as 

those contained in Section 135(b) of the NWPA. However, 

construction of the FES would not be contingent on utilities 

meeting a deadline for contracting for use of the FES, as is 

presently provided for the FIS in Section 136(a) of the 

NWPA. The Commission believes that the FES should be 

constructed without reference to the NWPA deadline because the facility is needed primarily for emergencies, and 

emergencies, by their very nature, are unpredictable. 

In locating the FES, consideration should be given to 

one or more Federal sites, where experience has already 

been gained in storing spent fuel or high-level nuclear 

waste. Selecting an existing Federal site would also facilitate construction and result in possible economies. 

The Commission recommends that, consistent with 

NWPA provisions, an NRC license not be required if the 

FES is located at an existing Federal site. The NRC, however, should be asked to make a finding that using a Federal site for an FES would adequately protect public health 

and safety. The Commission further recommends that an 

NRC license be required if the FES is located at a non-Federal site. 

A Commission contractor has estimated that the FES 

capital cost would range from about $300 million to $400 

million. (See Appendix I, Section One.) 

Because the FES would be designed primarily for 

101 
emergency use and hence would serve as "insurance" for 

the entire nuclear power industry, the cost of the FES 

should be paid from the Nuclear Waste Fund, and, hence, 

shared by the entire industry. However, owners of reactors 

that were shut down because of lack of storage space 

should be required to pay for their use of the FES, since 

they would do so if the storage facility proposed in Recommendation No. 2 were operational. 

Accidents at nuclear power plants that would shut 

down or require the shutdown of a reactor are not common, 

and, therefore, are difficult to predict. Likewise, it is 

impossible now to know how many utilities will have difficulty licensing additional at-reactor storage. The Commission believes that given its other recommendations, an FES 

capacity of 2,000 MTU would be adequate for the purposes 

indicated. The rationale for this limit is described in Appendix I, Section Two. 

Recommendation No. 2. Congress should authorize construction of a User-Funded Interim Storage (UFIS) facility 

with a capacity limit of 5,000 MTU. Such a facility would 

provide storage only, and would be used in addition to the 

Federal Emergency Storage facility proposed in Recommendation No. 1. 

Although spent fuel can be stored safely at reactor 

sites for as long as 100 years, some utilities may not have 

space at their reactor sites for life-of-plant storage or may 

not be able to obtain a license for additional storage. 

In view of the uncertainties regarding the date of 

availability of a repository, it would not be in the national 

interest to force utilities to shut down otherwise satisfactorily operating nuclear power plants because they lack 

storage for spent fuel. Congress recognized this problem by 

authorizing, in Section 135 of the NWPA, a Federal Interim 

Storage facility. It is the Commission's intention that the 

5,000 MTU storage facility recommended herein should 

also be available in such contingencies. 

The UFIS facility also should provide storage for: 

(a) shutdown reactors at sites where a utility no longer 

operates nuclear power plants, and (b) utilities that would 

prefer to ship spent fuel to this facility rather than retain 

it on-site. 

Although spent fuel can be stored safely on-site, the 

Commission believes there would be an added margin of 

safety in making storage available at a central facility for 

spent fuel from shutdown reactors of utilities that no longer 

operate other nuclear power plants at the same site. 

As noted in Chapters Four and Eight, after a reactor 

shuts down, the extensive crew of licensed reactor operators, health physicists, and managers will no longer be 

needed. The trained and experienced crew will likely disband and only the minimum number of personnel required 

to maintain the pool and site security will remain. Moreover, maintaining spent fuel at a shutdown reactor is expected to cost $2 million to $3 million more per site per 

year than if all the spent fuel were removed. 

A central interim storage facility would be advantageous in the circumstances described above because it 

would provide a group of trained and experienced fuel handlers, health physicists, and security staff available at all 

times. Providing the necessary personnel at a single site 

rather than at individual utilities would add a margin of 

safety, would be more efficient, and would result in substantial cost savings. 

Assuming that most plants will operate for the duration of their licenses, relatively few reactors are expected to 

shut down before the year 2010. However, experience has 

shown that some reactors, for one reason or another, will 

shut down before their operating licenses expire. To allow 

for the contingency of an early shutdown and possible delays in the repository's opening, the Commission believes 

that a User-Funded Interim Storage facility of limited capacity would be desirable. 

Inasmuch as some utilities may wish to ship fuel to a 

central facility rather than retain it on site, the storage facility would also be available for this purpose. 

If repository operation were to be delayed, the longer 

interim storage at the reactor sites or at the UFIS facility 

would reduce the heat load placed on the repository, thereby reducing some of the technical uncertainties of geologic 

disposal. This policy of longer interim storage is being followed in all other countries where nuclear power facilities 

are operating. (See Appendix D for further discussion of 

spent fuel storage activities in other countries.) 

A Commission contractor estimates that the capital 

cost of the User-Funded Interim Storage facility would 

range from about $500 million to $600 million. (See Appendix I, Section One.) 

In view of the uncertainties about when the MRS and 

repository will be in operation, many utilities with newer 

reactors have already taken steps to provide needed life-ofplant storage, while others have expressed a preference for 

providing such storage themselves rather than relying on an 

MRS. For these reasons, the Commission believes that it 

would be more equitable for the storage facility to be user 

funded, so that only those utilities that chose to use the facility would pay for it. 

User funding of this facility would also be more cost 

effective in that the cost of the facility could be compared 

with the cost which individual utilities are paying for onsite storage. Utilities, therefore, would use this facility only 

if it were more economical than on-site storage or if the ad102 

7 0 2 0 2 I 1 5 
ditional marginal cost provided benefits otherwise 

unavailable. 

It is not the Commission's role to develop the specific 

financial basis for determining the fee utilities should pay 

to use the central facility. However, because of the uncertainty about the number of users and the date a repository 

may become operational, it is important for utilities to 

know at an early date the cost of using the central facility. 

One way to accomplish this purpose would be for DOE to 

auction the rights to use the facility. If the sum of the bids 

did not exceed the cost of building and licensing the facility, it would not be built. Subsequent auctions could be held 

if warranted by delay in the repository or other factors. 

(For further details about the auction procedure, see Appendix I, Section Three.) 

Utilities may find it desirable to pay a reasonable premium to use a central facility instead of at-reactor storage, 

but the uncertainty of the cost of licensing a contentious facility of this sort may be too great to allow user funding to 

operate in its purest form. Therefore, the Commission recommends that DOE, in consultation with the NRC, establish an upper limit for licensing cost and exclude costs in 

excess of that limit from affecting the payment required to 

use the central facility. 

Because present law allows the Nuclear Waste Fund to 

pay for transportation from the reactor to the repository, the 

fund should also pay the cost of transporting spent fuel 

from the reactor to the storage facility. 

There is a question whether DOE has a legal obligation under its contract with utilities to take possession of 

spent fuel by January 31, 1998, with the Nuclear Waste 

Fund paying the storage cost. Although the Commission 

believes that Congress should take into account the expectation that DOE would begin to accept fuel by 1998 under 

the NWPA, the Commission makes no judgment as to 

whether or not a legal obligation exists. 

Questions have already been raised as to the Nuclear 

Waste Fund's adequacy for financing the repository. The 

fact that the cost of the UFIS would be paid by the utilities 

using it rather than from the Nuclear Waste Fund (as would 

be the case with the MRS) would mitigate, to some degree, 

increases in the Nuclear Waste Fund that might be needed 

for constructing the repository. 

Because it would defeat the purposes of serving in a 

timely manner the functions described above, building the 

5,000 MTU storage facility should not be linked in time to 

the repository's construction. However, the limitation on 

the facility's size would in itself be a "linkage," in that the 

facility would accommodate only about 6 percent of the 

fuel to be generated by existing nuclear power plants over 

their projected lifetime. Thus, the UFIS could not be considered a de facto repository. 

As for the facility's size, the Commission believes that 

5,000 MTU should be ample for the purposes indicated. 

The Commission estimates that by 2006 operating and 

shutdown reactors will require about 9,000 MTU of dry 

storage. Assuming that utilities desired to store in the central facility as much as half of their spent fuel from operating and shutdown reactors, 5,000 MTU should be sufficient 

to provide for such requirements at least until 2006. 

Recommendation No. 3. Congress should reconsider the 

subject of interim storage by the year 2000 to: 

(a) take into account uncertainties that exist today and that 

might be resolved or clarified within ten years, (b) consider 

developments that cannot be anticipated today, and (c) 

evaluate the experience with the two facilities recommended above. 

As has been indicated throughout this report, there are 

many uncertainties which make it extremely difficult to 

plan for long-term interim storage of spent fuel. Although 

the date of opening a permanent repository is the most notable uncertainty, many other questions, such as those 

noted below, also remain unresolved. 

The Commission believes that the actions recommended above should adequately take care of the needs of 

interim storage at least until 2006. The Commission arrived 

at this conclusion after considering the schedule of cumulative need for spent fuel storage, the option of at-reactor 

storage, and the fact that the need for storage will become 

acute only after a significant number of reactors shut down 

and if neither an MRS nor a repository is available. 

However, by the year 2000, Congress should reconsider the question of interim storage of spent fuel, taking 

into account, among other things, the following factors: 

a. Status of the repository; 

b. Status of nuclear power plants, i.e., number that 

shut down early, license extensions, utilization of 

extended burnup, etc.; 

c. Availability of at-reactor storage; 

d. Utilization and adequacy of the 2,000 MTU Federal 

Emergency Storage facility; 

e. Utilization and adequacy of the 5,000 MTU UserFunded Interim Storage facility; 

f. Status of rod consolidation, dual-purpose casks, and 

other technological developments in spent fuel 

storage; 

103 

7 0 2 I 4 
g. System optimization; and 

h. The fee schedule established for the user-funded 

facility. 

• • • 

The Monitored Retrievable Storage Review Commission believes that these recommendations, together with 

analyses contained in other sections of this report, carry out 

the Commission's mandate from Congress. If implemented, 

the recommendations would provide safe interim storage of 

spent nuclear fuel, would be consistent with the goals of 

the national nuclear waste management system, and would 

provide for flexibility and unforeseen contingencies. 

The Commission urges Congress, whatever its decision, to act as promptly as possible with regard to interim 

spent fuel storage, so that DOE, utilities, and other affected 

parties can plan accordingly. 

104 

7 0 2 `J 0 2 f 4 7 
Appendix A 

Public Hearings: People Appearing Before the Commission 

Washington, D.C. 

December 1-2, 1988 

Scheduled Witnesses: 

1.Mr. William W. Berry, Chairman of the Boards of 

Dominion Resources and Virginia Power, and Chairman of 

the American Committee on Radioactive Waste Disposal, 

Edison Electric Institute, Washington, D.C.; accompanied 

by Mr. Steven Kraft, Director, Nuclear Waste and Transportation Program, Edison Electric Institute, Washington, 

D.C. 

2. Mr. Paul Childress, Project Manager, Nuclear Power Division, Babcock and Wilcox, Lynchburg, Virginia, and 

High-Level Radioactive Waste Committee of the American 

Society of Mechanical Engineers 

3. Mr. Anton Fuierer, Director, Special Projects, 

Rochester Gas and Electric Company, Rochester, New 

York 

4. Mr. William Hamilton, Manager, Nuclear Waste 

Department, Westinghouse Electric Corporation, Pittsburgh, Pennsylvania 

5. Ms. Judith Johnsrud, Ph.D., Director, Environmental Coalition on Nuclear Power, State College, Pennsylvania, and Research Director, Food and Water Inc., Denville, 

New Jersey 

6. Mr. Leon Lowery, Legislative Representative, Environmental Action, Washington, D.C. 

7. Mr. Dick Nelson, Chair, Energy and Utilities Committee, House of Representatives, State of Washington, 

Olympia, Washington 

8. Mr. Karl J. Notz, Chairman, MRS Information 

Group, Oak Ridge, Tennessee 

9. Ms. Caroline Petti, Legislative Director, Southwest 

Research and Information Center, Washington, D.C. 

10.Reverend Margaret Schmitz, Pastor, Maybeury, 

West Virginia 

11.Mr. Ben L. Smith, Executive Administrative Assistant III, Tennessee State Planning Office, Nashville, 

Tennessee 

12.Mr. David Snedecker, Consultant, Pullyaup, 

Washington 

13.Mr. Michael McK. Wilson, Commissioner, Florida 

Public Service Commission, and Chairman, NARUC Subcommittee on Nuclear Waste Disposal, Tallahassee, Florida 

Walk-In Testimony; 

14.Mr. Raymond E. Hoskins, Spent Nuclear Fuel 

Management Consultant, Chattanooga, Tennessee 

Denver, Colorado 

January 5, 1989 

Scheduled Witnesses: 

15. Mr. Jeff Everitt, Technological Hazards Officer, 

State Department of Emergency Services, Golden, 

Colorado 

16.Mr. Timothy Holeman, Policy Advisor to Governor Roy Romer of Colorado, on behalf of the Western Interstate Energy Board's High-Level Radioactive Waste 

Committee, Denver, Colorado 

17.Mr. Kirkland Jones, Deputy Director, Environmental Improvement Division, Santa Fe, New Mexico 

18: Ms. Melinda Kassen, Senior Attorney, Environmental Defense Fund, Boulder, Colorado 

19.Mr. Tony Massaro, Director of Environmental 

Affairs, City and County of Denver, Colorado 

20.Mr. Rex J. Massey, Associate, Intertech Consultants, Inc., Carson City, Nevada, on behalf of Lincoln 

County and the City of Caliente, Nevada 

Walk-in Testimony: 

21.Mr. George Durkop, Coordinator, Douglas County 

Emergency Services, Douglas County, Colorado 

22.Mr. Wyatt M. Rogers, Jr., Nuclear Projects Manager, Council of Energy Resource Tribes, Denver, Colorado 

San Francisco, California 

January 9, 1989 

Scheduled Witnesses: 

23.Mr. Dennis Bechtel, Coordinator, Clark County 

Comprehensive Planning Department, on behalf of Clark 

County, Nevada 

24.Mr. Wallace Behnke, Vice Chairman, Commonwealth Edison Company, Chicago, Illinois 

A-1 
25.Mr. Leonard Conly, Secretary, Nuclear-Free 

Berkeley Committee, Berkeley, California 

26.Dr. Richard Ferguson, Regional Vice President for 

Southern California/Nevada Sierra Club, Creston, 

California 

27.Mr. Steve Frishman, Technical Policy Coordinator, 

Nevada Agency for Nuclear Projects, Carson City, Nevada 

28.Mr. Roger Herried, Staff Person, Abalone Alliance, San Francisco, California 

29.Mr. Donald W. Mazur, Managing Director, Washington Public Power System, Richland, Washington 

30.Mr. Max S. Power, Program Director, Office of 

Nuclear and Mixed Waste, Washington Department of 

Ecology, on behalf of the Washington State Nuclear Waste 

Board and Nuclear Waste Advisory Council, Olympia, 

Washington 

31.Mr. James D. Shiffer, Vice President of Nuclear 

Power Generation, Pacific Gas and Electric Company, San 

Francisco, California 

Walk-In Testimony: 

32.Mr. Andy Colonna, Private Citizen, Arcata, 

California 

33.Mr. Don Eichelberger, Staff Person, Abalone Alliance, San Francisco, California 

34.Mr. Bob Fulkerson, Executive Director, Citizen 

Alert, Las Vegas, Nevada 

35.Ms. Helen Hubbard, President, and Ms. Diane 

Hughes, Vice President, Citizens for Total Energy, Sunol, 

California 

36.Mr. Richard G. McPherson, Senior Executive Officer, The McPherson Group, Inc., Costa Mesa, California 

37.Ms. Wendy Oser, Private Citizen, Berkeley, 

California 

Atlanta, Georgia 

January 17-18, 1989 

Scheduled Witnesses: 

38.Mr. Robert Anderson, Executive Director of Engineering, Chem-Nuclear Systems, Inc., Columbia, South 

Carolina 

39.Mr. John Barber, County Manager, Davie County, 

Mocksville, North Carolina 

40. Mr. Jeffrey J. Broughton, City Manager, on behalf 

of the Honorable Roy Pruett, Mayor of Oak Ridge, Tennessee; accompanied by Mr. William D. Harris, Fire Chief, 

Oak Ridge, Tennessee 

41. Mr. Tom Clements, Private Citizen, Atlanta, 

Georgia 

42. Dr. David Corcoran, Publisher of the Welch Daily 

News, and Chair of the MRS Task Force, Welch, West 

Virginia 

43. Mr. W.G. (Bill) Counsil, Vice Chairman, Texas 

Utilities Electric, Dallas, Texas 

44. Mr. Wells Eddleman, Staff Scientist, North Carolina Citizens Research Group, Durham, North Carolina 

45. Ms. Louise Gorenflo, Rural Cumberland Resources, Crossville, Tennessee 

46. Mr. Dennis Hoffarth, Private Citizen, Atlanta, 

Georgia 

47. Ms. Carol Jackson, MRS Coordinator, West Virginia Citizens for a Clean Environment, Brooks, West 

Virginia 

48.Mr. Tim Johnson, Co-Director, Campaign for a 

Prosperous Georgia, Atlanta, Georgia 

49. Mr. Andrew Maier, President, Save Our Mountains, Hinton, West Virginia 

50.Mr. T.C. McMeekin, Vice President, Design Engineering, Duke Power Company, Charlotte, North Carolina; 

accompanied by Mr. Gregory Snipes, Nuclear Fuel Supervisor, Duke Power Company, Charlotte, North Carolina 

51.The Honorable Mike Parker, U.S. House of Representatives, 4th District, State of Mississippi 

52.Dr. Lamar Priester, Chairman, South Carolina Nuclear Waste Consultation Committee, and Representative 

Harriet Keyserling, South Carolina Nuclear Waste Consultation Committee, on behalf of the State of South Carolina 

53. Mr. Ben L. Smith, Executive Administrative Assistant III, Tennessee State Planning Office, Nashville, 

Tennessee 

54.Mr. J.D. Stephens, President, Oil, Chemical and 

Atomic Workers International Union 3-288, Oak Ridge, 

Tennessee 

55.Ms. Carol Thorup, Senior Vice President, Nuclear 

Assurance Corporation, Norcross, Georgia 

56.Mr. Joe Wilder, Board Member, Lower Savannah 

Council of Governments, Aiken, South Carolina; accompanied by Mr. Wesley Smith, Attorney at Law, Aiken, 

South Carolina 

57.Mr. William Willis, Executive Vice President and 

Chief Operating Officer, Tennessee Valley Authority, 

Knoxville, Tennessee; accompanied by Mr. David L. Dunn, 

Project Manager, Division of Nuclear Services, Tennessee 

Valley Authority, Chattanooga, Tennessee 

Walk-In Testimony: 

58.Dr. John Croom, on behalf of Frances Close Hart, 

Chairwoman, Energy Research Foundation, Columbia, 

South Carolina 

59.Ms. Glenn Carroll, Private Citizen, Decatur, 

Georgia 

60.Dr. Geoffrey G. Eichholz, Regents Professor, Nuclear Engineering and Health Physics Program, Georgia Institute of Technology, Atlanta, Georgia 

A-2 

7 U 0 1 4 9 
61.Ms. Carol Ford, Member, Save Our Cumberland 

Mountains, Jacksboro, Tennessee 

62.Mr. Michael F. Lowe, Private Citizen, Columbia, 

South Carolina 

63.Mr. Leon Lowery, Legislative Representative, Environmental Action, Washington, D.C. 

64.Dr. Edward Passerini, Associate Professor, New 

College, University of Alabama, Tuscaloosa, Alabama 

65.The Honorable Doug Teper, State Representative, 

46th District, Atlanta, Georgia 

Atlanta, Georgia 

February 16-17, 1989 

Scheduled Witnesses: 

66.Mr. Ralph Beedle, Vice President, Nuclear Support Systems, New York Power Authority, White Plains, 

New York 

67.Mr. John Blackburn, Legislative Assistant, on behalf of the Honorable Terry Sanford, U.S. Senate, State of 

North Carolina 

68.Mr. John T. Brock, Davie County Attorney, 

Mocksville, North Carolina 

69.Dr. E. William Coglazier, Jr., Director, Energy, 

Environment and Resources Center, University of Tennessee, Knoxville, Tennessee 

70.Ms. Claudine Cremer, District Assistant, on behalf 

of the Honorable James McClure Clarke, U.S. House of 

Representatives, 11th District, State of North Carolina 

71.Mr. Donald A. Downs, President, Davie Opposes 

Nuclear Trash, Advance, North Carolina 

72.Ms. Martha Drake, Board Member, Conservation 

Council of North Carolina, Chapel Hill, North Carolina 

73.Ms. Laura Drey, News Editor, Coalition for Alternatives to Shearon Harris, Durham, North Carolina 

74.Mr. Raymond E. Hoskins, Spent Nuclear Fuel 

Management Consultant, Chattanooga, Tennessee 

75.Ms. Janet Hoyle, President, Blue Ridge Environmental Defense League, Glendale Springs, North Carolina 

76.Mr. J. Michael Martinez, Assistant Director, Policy Analysis, Southern States Energy Board, Norcross, 

Georgia 

77.Mr. Bill McEwen, Administrative Assistant, on 

behalf of the Honorable W.G. (Bill) Hefner, U.S. House of 

Representatives, 8th District, State of North Carolina 

78.Ms. Elizabeth Peelle, Consultant, Socio Economic 

Study Group, MRS Task Force, Oak Ridge, Tennessee 

79.Mr. Jesse L. Riley, Chairman of the Nuclear Subcommittee, Sierra Club National Energy Committee, Charlotte, North Carolina 

80.Ms. Jane Sharp, Board Member, Conservation 

Council of North Carolina, Chapel Hill, North Carolina 

81.Mr. Harrison M. Wadsworth, III, Staff Member, on 

behalf of the Honorable Bart Gordon, U.S. House of Representatives, 6th District, State of Tennessee 

82.Mr. Louis Zeller, Secretary, Elk River Coalition, 

Marshall, North Carolina 

Walk-in Testimony: 

83.Mr. Robert Morgan, Private Citizen, Aiken, South 

Carolina 

84.Dr. Edward Passerini, Associate Professor, New 

College, University of Alabama, Tuscaloosa, Alabama 

A-3 
Appendix B 

Statements Submitted For the Record 

The following people have submitted written statements for the record in lieu of appearing during a hearing 

before the Commission. The names appear in alphabetical 

order. 

James Adams, Redwood Alliance, Arcata, California 

Debby Beaver, Concerned Citizen, Red Boiling Springs, 

Tennessee 

Patricia Birnie, Co-Director, Maryland Safe Energy Coalition, Columbia, Maryland 

David A. Boggs, General Manager, Sacramento Municipal 

Utility District, Sacramento, California 

J. M. Buchheit, Senior Nuclear Fuels Engineer, Yankee 

Atomic Electric Company, Boston, Massachusetts 

Emily B. Calhoun, Concerned Citizen, Atlanta, Georgia 

Gaston Caperton, Governor, State of West Virginia, 

Charleston, West Virginia 

William W Cobey, Jr., Secretary, North Carolina 

Department of Natural Resources and Community 

Development, Raleigh, North Carolina 

Michael Cohen, Concerned Citizen, Gaithersburg, 

Maryland 

Mary Lula Cook, Concerned Citizen, Advance, North 

Carolina 

Dorothy Cope, Concerned Citizen, Spencer, Tennessee 

Diane D'Arrigo, Nuclear Information and Resource Service, Washington, D.C. 

Joan Edwards, Energy Chair, Sierra Club Cascade Chapter, 

Bellevue, Washington 

Helen Everett, Concerned Citizen, Hinton, West Virginia 

Jean Ewing, Peach Bottom Alliance, Darlington, Maryland 

The Honorable Albert Gore, Jr., U.S. Senate, State of 

Tennessee 

William J. Hafner, Concerned Citizen, Mastic, New York 

Judge Peter W. Hairston and Lucy D. Hairston, 

Concerned Citizens, The Cooleemee Plantation, Advance, North Carolina 

Shirley P. Hendrix, Chairman, Transportation Study 

Group, MRS Clinch River Task Force, Oak Ridge, 

Tennessee 

Victor H. Hoffman, High Rock Lake Association, Southmont, North Carolina 

Jacqueline D. Hubbs, Concerned Citizen, Cookeville, 

Tennessee 

William G. Jasen, Concerned Citizen, West Richland, 

Washington 

Susan Jata, Concerned Citizen, Nashville, Tennessee 

Cheryl D. Jay, Concerned Citizen, Savannah, Georgia 

Andrew Jenkins, Department of Energy & Transportation, 

Jackson, Mississippi 

Judith H. Johnsrud, Ph.D., Environmental Coalition on Nuclear Power, State College, Pennsylvania 

Eva R. Jurgensen, Concerned Citizen, Advance, North 

Carolina 

Donald B. Kamer, Executive Vice President, Arizona 

Nuclear Power Project, Phoenix, Arizona 

Leah R. Karpen, Concerned Citizen, Weaverville, North 

Carolina 

Joan 0. King, Concerned Citizen, Sautee, Georgia (Ms. 

King submitted two statements for the record.) 

Susan Lange, Concerned Citizen, Rock Cave, West 

Virginia 

Drew Langsner, Concerned Citizen, Marshall, North 

Carolina 

Marvin I. Lewis, Concerned Citizen, Philadelphia, 

Pennsylvania 

William S. Lewis, Attorney at Law, Savannah, Georgia 

Patricia Link, Co-Chairperson, Rowan Environmental Action Partners, Salisbury, North Carolina 

Noel P. McJunkin, Concerned Citizen, Tellico Plains, 

Tennessee 

Douglas Moore, Concerned Citizen, Cookeville, Tennessee 

Carl Mortenson, Concerned Farmer, Natty Locks Farm, 

Moyers, West Virginia 

The Honorable Stephen L. Neal, U.S. House of Representatives, 5th District, State of North Carolina 

Robert Jack Neff, Chairman, MRS Study Committee of the 

Tennessee Chapter of the Sierra Club, Nashville, 

Tennessee 

L.T. Papay, Senior Vice President, Southern California 

Edison Company, Rosemead, California 

Robert Peelle, Commissioner, 4th District, Roane County, 

Oak Ridge, Tennessee 
Jeff Poppen, Concerned Farmer, Long Hungry Creek Nursery, Red Boiling Springs, Tennessee 

The Honorable John D. Rockefeller, U.S. Senate, State of 

West Virginia 

William Alan Ross, Concerned Songwriter, Nashville, 

Tennessee 

The Honorable Jim Sasser, U.S. Senate, State of Tennessee 

The Honorable Jim Sasser and The Honorable Albert Gore, 

Jr., U.S. Senate, State of Tennessee 

Betty Schroeder, GE Stockholders' Alliance, Columbia, 

Maryland 

James M. Sconyers, Concerned Citizen, Terra Alta, West 

Virginia 

Steven Gerry Scudder, Concerned Citizen, Murfreesboro, 

Tennessee 

Sierra Club, West Virginia Chapter, Morgantown, West 

Virginia 

Valerie Slogick, Teacher, and students in her 6th grade 

class, William R. Davie Elementary School, Mocksville, 

North Carolina 

Nan Smyth, President, League of Women Voters of South 

Carolina, Columbia, South Carolina 

Rick Spry, Concerned Citizen, Mocksville, North Carolina 

J. Thomas Tidd, Vice President and General Counsel, Association of American Railroads, Washington, D.C. 

Marshall E. Tyler, Concerned Citizen, Mocksville, North 

Carolina 

Susan M. White, Concerned Citizen, Whitleyville, 

Tennessee 

Ken Yager, County Executive, Office of the County Executive, Roane County Courthouse, Kingston, Tennessee 

Sally Yancey, Conceined Citizen, Pleasant Shade, 

Tennessee 

Steven Yancey, Concerned Citizen, Pleasant Shade, 

Tennessee 

B-2 

7 0 2 .3 0 2 I-S 
Appendix C 

Public Briefings: People Appearing Before the Commission 

Briefing on History and Background of MRS 

Program 

July 25, 1988: 

In Order of Appearance: 

1.Mr. Thomas H. Isaacs, Acting Associate Director, 

Office of External Relations and Policy, Office of Civilian 

Radioactive Waste Management, Department of Energy, 

Washington, D.C. 

2. Mr. James Carlson, Chief, Program Relations 

Branch, Office of External Relations and Policy, Office of 

Civilian Radioactive Waste Management, Department of 

Energy, Washington, D.C. 

3. Mr. Keith A. Klein, Deputy Associate Director for 

Systems Integration and Regulation, Office of Civilian Radioactive Waste Management, Department of Energy, 

Washington, D.C. 

4. Mr. Robert Bernero, Director, Office of Nuclear 

Material Safety and Safeguards, Nuclear Regulatory Commission, Washington, D.C. 

5. Mr. Leland C. Rouse, Chief, Fuel Cycle Safety 

Branch, Division of Industrial and Medical Safety, Office 

of Nuclear Material Safety and Safeguards, Nuclear Regulatory Commission, Washington, D.C. 

6. Mr. A. Thomas Clark, Senior Chemical Engineer, 

Fuel Cycle Safety Branch, Division of Industrial and 'Medical Safety, Office of Nuclear Material Safety and Safeguards, Nuclear Regulatory Commission, Washington, D.C. 

7. Mr. Benjamin Cooper, Professional Staff Member, 

Committee on Energy and Natural Resources, U.S. Senate, 

Washington, D.C. 

8. Mr. Dan M. Berkovitz, Counsel, Committee on Environment and Public Works, U.S. Senate, Washington, 

D.C. 

9. Mr. Sam E. Fowler, Counsel, Subcommittee on Energy and the Environment, Committee on Interior and Insular Affairs, U.S. House of Representatives, Washington, 

D.C. 

10.Mr. David Schooler, Professional Staff Member, 

Subcommittee on Energy and Power, Committee on Energy 

and Commerce, U.S. House of Representatives, Washington, D.C. 

11.Mr. Louis Ventre, Counsel, Subcommittee on Energy Research and Development, Committee on Science, 

Space, and Technology, U.S. House of Representatives, 

Washington, D.C. 

July 26, 1988: 

In Order of Appearance: 

1.Mr. Ben L. Smith, Executive Administrative Assistant III, Tennessee State Planning Office, Nashville, 

Tennessee 

2. Dr. E. William Coglazier, Jr., Director, Energy, Environment and Resources Center, University of Tennessee, 

Knoxville, Tennessee 

3. Mr. Raymond E. Hoskins, Spent Nuclear Fuel Management Consultant, Chattanooga, Tennessee 

4. Dr. Ruth Neff, Tennessee State Planning Office, 

Tennessee Department of Health and Environment, 

Nashville, Tennessee 

5. The Honorable Bart Gordon, U.S. House of Representatives, 6th District, State of Tennessee 

6. Mr. Keith Fultz, Senior Associate Director, Resources, Community and Economic Development Division, 

General Accounting Office, Washington, D.C. 

7. Mr. Dwayne Weigel, Group Director, Resources, 

Community and Economic Development Division, General 

Accounting Office, Washington, D.C. 

8. Mr. Vincent Price, Evaluator, Resources, Community and Economic Development Division, General Accounting Office, Washington, D.C. 

July 27, 1988: 

In Order of Appearance: 

1.Mr. Richard C. Hannon, Chief, Policy Development 

and Information Systems Division, Research and Special 

Programs Administration, Department of Transportation, 

Washington, D.C. 

2. Mr. Michael E. Wangler, Chief, Radioactive Materials Branch, Technical Division, Research and Special 

Programs Administration, Department of Transportation, 

Washington, D.C. 

C-1 

7 0 2 0 2 1 5 
3. Mr. Larry Bruno, Senior Policy Analyst, Policy Development and Information Systems Division, Research 

and Special Programs Administration, Department of 

Transportation, Washington, D.C. 

4. Dr. Richard W. Lynch, Director of Nuclear Waste 

Management and Transportation, Sandia Laboratories, Albuquerque, New Mexico 

5. Mr. Joseph E. Stiegler, Manager, Transportation 

System Development Department, Sandia Laboratories, Albuquerque, New Mexico 

6. Dr. George C. Allen, Jr., Supervisor, Transportation 

Systems Technology Division, Sandia Laboratories, Albuquerque, New Mexico 

7. Dr. Robert E. Luna, Supervisor, Risk Assessment 

and Transportation System Analysis Division, Sandia Laboratories, Albuquerque, New Mexico 

8. Mr. Loring Mills, Vice President, Nuclear Activities, Edison Electric Institute, Washington, D.C. 

9. Mr. John Kaufmann, Executive Vice President, 

Pennsylvania Power & Light Company, Allentown, 

Pennsylvania 

10.Mr. D.A. Brodnick, Senior Licensing Specialist, 

Florida Power and Light Company, Miami, Florida 

11.Mr. Steven Kraft, Director, Nuclear Waste and 

Transportation Group, Edison Electric Institute, Washington, D.C. 

12.Mr. Daniel Reicher, Senior Project Attorney, Natural Resources Defense Council, Washington, D.C. 

13.Ms. Caroline Petti, Legislative Director, Southwest Research and Information Center, Washington, D.C. 

Briefing by the Nuclear Regulatory 

Commission Staff 

Cask Certification and NRC Licensing of ISFSI 

September 22, 1988: 

1.Mr. Charles E. McDonald, Chief, Transportation 

Branch, Division of Safeguards and Transportation, Office 

of Nuclear Material Safety and Safeguards, Nuclear Regulatory Commission, Washington, D.C. 

2. Mr. Leland C. Rouse, Chief, Fuel Cycle Safety 

Branch, Division of Industrial and Medical Nuclear Safety, 

Office of Nuclear Material Safety and Safeguards, Nuclear 

Regulatory Commission, Washington, D.C. 

3. Mr. John Roberts, Section Leader, Irradiated Fuel 

Section, Division of Industrial and Medical Nuclear Safety, 

Office of Nuclear Material Safety and Safeguards, Nuclear 

Regulatory Commission, Washington, D.C. 

4. Mr. John W. Craig, Chief, Plant Systems Branch, 

Division of Engineering and Technology, Office of Nuclear 

Reactor Regulation, Nuclear Regulatory Commission, 

Washington, D.C. 

Briefing by the Department of Energy 

Engineering Studies, Rod Consolidation, Cask 

Development 

September 23, 1988: 

1.Mr. Thomas H. Isaacs, Acting Associate Director, 

Office of External Relations and Policy, Office of Civilian 

Radioactive Waste Management, Department of Energy, 

Washington, D.C. 

2. Mr. Ralph Stein, Acting Associate Director, Office 

of Systems Integration and Regulations, Office of Civilian 

Radioactive Waste Management, Department of Energy, 

Washington, D.C. 

Briefing by the Department of Energy 

Permanent Repository Program 

December 15, 1988: 

1.Mr. Sam Rousso, Acting Director, Office of Civilian Radioactive Waste Management, Department of 

Energy, Washington, D.C. 

2. Mr. Thomas H. Isaacs, Associate Director, Office of 

External Relations and Policy, Office of Civilian Radioactive Waste Management, Department of Energy, Washington, D.C. 

3. Mr. Carl Gertz, Project Manager, Yucca Mountain 

Project Office, Department of Energy Nevada Operations 

Office, Las Vegas, Nevada 

4. Mr. Jerome D. Saltzman, Acting Deputy Associate 

Director, Office of Facilities, Siting and Development, Department of Energy, Washington, D.C. 

Briefing by the Department of Energy 

Preliminary Results of Systems Studies 

March 16, 1989: 

1.Mr. Thomas H. Isaacs, Associate Director, External 

Relations and Policy, Office of Civilian Radioactive Waste 

Management, Department of Energy, Washington, D.C. 

2. Mr. Ralph Stein, Associate Director, Office of Systems Integration and Regulations, Office of Civilian Radioactive Waste Management, Department of Energy, 

Washington, D.C. 

Briefing by the Department of Energy 

Position on Need for an MRS Facility 

May 25, 1989: 

1. Mr. Thomas H. Isaacs, Associate Director, External 

Relations and Policy, Office of Civilian Radioactive Waste 

Management, Department of Energy, Washington, D.C. 

C-2 

7 0 4 
Briefing by the Nuclear Regulatory 

Commission 

Safety and Safeguards Issues 

May 25, 1989: 

1. Mr. George McCorkle, Deputy Director, Division of 

Safeguards and Transportation, Office of Nuclear Material 

Safety and Safeguards, Nuclear Regulatory Commission, 

Washington, D.C. 

2. Mr. Leland Rouse, Chief, Fuel Cycle Safety 

Branch, Division of Industrial and Medical Nuclear Safety, 

Office of Nuclear Material Safety and Safeguards, Nuclear 

Regulatory Commission, Washington, D.C. 

C-3 

7 0 2 1 
Appendix D 

Spent Fuel Management Policies in Eight Countries 

Prepared for 

The Monitored Retrievable Storage Review Commission 

By 

JK Research Associates, Inc. 

3408 Bonnie Road 

Austin, TX 78703 

October 10, 1989 

D-1 

7 2 ;„) 
TABLE OF CONTENTS 

Page 

1.0 CANADA D-3 

2.0 FRANCE D-4 

3.0 FEDERAL REPUBLIC OF GERMANY D-6 

4.0 JAPAN D-8 

5.0 SPAIN D-10 

6.0 SWEDEN D-11 

7.0 SWITZERLAND D-13 

8.0 UNITED KINGDOM D-15 

9.0 CONCLUSIONS D-17 

10.0 SOURCES D-20 

D-2 

7 0 0 2 I 7 
1.0 CANADA 

1.1 Status of Nuclear Power and Waste 

Management 

Canada has 18 operating reactors (just over 11 GWe) 

that supply about 13 percent of the country's electricity.' 

An additional four reactors are being commissioned or are 

under construction. These reactors are all of the naturaluranium CANDU design developed by Atomic Energy of 

Canada Ltd. (AECL). Existing and projected Canadian reactors are expected to discharge about 34,000 MTU of spent 

fuel through the end of this century, and a total of about 

100,000 MTU by 2050 (if there is no reprocessing.) Reprocessing is not now planned, although no final decision 

has been made about the ultimate disposition of spent fuel. 

1.2 Institutional Structure of Reactor Operation and Waste Management 

Sixteen of the 18 Canadian reactors are owned by a 

single utility, Ontario Hydro. The other two are owned by 

Quebec Hydro and the New Brunswick Electric Power 

Commission. Each utility is responsible for the interim 

management of its own spent fuel. In addition, Ontario Hydro is responsible for development of technology for interim storage and transportation of spent fuel. The Whiteshell 

Nuclear Research Establishment (WNRE) directs and coor 

dinates an R&D program on immobilization and disposal 

of nuclear fuel waste. Whiteshell is part of AECL, which 

reports to the Federal Department of Energy, Mines and 

Resources. The disposal R&D program is funded jointly by 

the Federal government and Ontario Hydro. Institutional 

responsibility for implementation of waste disposal has not 

been decided, nor has the precise funding mechanism. At 

present the utilities collect and accrue funds (via electric 

rates) to cover the estimated costs of spent fuel and waste 

management, and decommissioning. 

Nuclear activities are regulated by the Atomic Energy 

Control Board (AECB), which reports to the Department of 

Energy, Mines and Resources along with AECL. In general, the national government has responsibility for all nuclear affairs, with preemptive rights. 

1.3 Waste Management Strategy 

As noted above, no decision has been made about 

spent fuel disposal or reprocessing, and current policy is to 

keep spent fuel in retrievable storage (discussed below) until such a decision is made. The capability to dispose of 

spent fuel is being developed. There is no legal linkage between reactor operation and availability of a waste repository, and there is no sense of urgency about final disposal. 

The current plan is for WNRE to issue a concept assessment report evaluating a proposed approach for disposal of 

spent fuel and high-level waste (HLW). The report will include results of tests at the Underground Research Laboratory (URL) located near the Whiteshell center, although 

this laboratory is not intended to be the ultimate site of the 

repository. Review of the report, in the early 1990s, will be 

coordinated by the Federal Environmental Assessment Review Office, which will bring in various Federal and Ontario governmental agencies and other organizations and 

organize public hearings. If approval is given after the review process, development of disposal technology will 

continue, probably with the concurrent evaluation of disposal sites. 

1.4 Interim Storage Policy in Detail 

1.4.1 Interim storage: facilities and 

technologies 

At present, almost all spent fuel is stored in pools at 

the reactor sites. There are only six such sites for Canada's 

reactors. Ontario Hydro has three nuclear centers. The 

Bruce center is divided into two separate sites with four reactors each; the Pickering center has eight reactors on a 

single site; and the Darlington center has four reactors either being commissioned or under construction. The other 

two sites have one reactor apiece. All of the sites were designed with large pool storage capacity; the pools at Bruce 

and Pickering should be adequate until the mid-1990s, 

while those at Darlington will be sufficient into the next 

century. The Ontario Hydro sites have central storage basins connected to groups of four reactors. 

A wide range of options for additional spent fuel storage capacity is under consideration, including both wet and 

dry storage, and off-site as well as on-site storage. 2Economic studies by Ontario Hydro have shown that adding 

pool storage may be the most cost-effective option for a 

large capacity facility. This is the likely option for providing additional storage at the two Bruce sites, since there is 

adequate room on the sites and the existing pools are designed to facilitate such expansion. The Pickering site is 

cramped, however, and dry storage, most likely on-site, 

may be necessary. Ontario Hydro has evaluated four dry 

storage options: convection-cooled vaults, concrete storage 

casks, concrete integrated containers (for storage, transportation, and disposal), and metal casks. Ontario Hydro is 

continuing development of the concrete integrated container, and this is the option that would be used at the Pickering 

site if dry storage is selected. Canada has extensive experience with storage in concrete casks. 3 

D-3 
1.4.2 Basis for at-reactor/centralized storage 

decision 

No utility has decided to move off-site for additional 

storage, and it is possible that any such decision would 

await satisfactory demonstration of a concept for disposal. 

Off-site storage may have to be considered eventually for 

the Pickering reactors because of space limitations on-site. 

1.4.3 Financial arrangements for storage 

At-reactor storage is paid for directly by the utilities. 

1.4.4 Other roles for storage site. 

A possible site for offsite storage for Ontario Hydro is 

the Bruce Nuclear Power Development (BNPD) site. This 

site is currently used for low- and intermediate-level waste 

storage and treatment, and is the location of an incinerator. 

2.0 FRANCE 

2.1 Status of Nuclear Power and Waste 

Management 

France has 51 operating nuclear plants (about 53 GWe 

capacity, mostly PWRs) that generate more than 70 percent 

of the electricity produced in that country. France's nuclear 

power strategy is to maintain a full domestic fuel cycle capability, including reprocessing for domestic and foreign 

customers and plutonium recycle in light-water and breeder 

reactors. Spent fuel is stored at reactor sites for only a few 

years before being shipped to a reprocessing plant. The 

HLW from reprocessing is vitrified and will be stored for 

20 years or longer for cooling before geologic disposal in a 

repository. 

2.2 Institutional Structure of Reactor Operation and Waste Management 

French reactors are owned and operated by Electricite 

de France (EDF) which is 100 percent government-owned. 

The Commissariat a l'Energie Atomique (CEA) controls 

nuclear research and development efforts and provides 

technical support to other companies in their licensing activities. The Compagnie Generale des Matieres Nucleaires 

(COGEMA) is responsible for fuels production and reprocessing activities. It is a wholly-owned subsidiary of the 

CEA and owns all of the fuel cycle facilities in France. Although COGEMA is government-owned, it is a commercial venture whose business activities are financed through 

its investments and paid for by its fuel cycle clients. 

EDF is a major client, although it is not required to use 

COGEMA's reprocessing services. Other clients include 

utilities in Japan, Germany, and Switzerland. 

Long-term waste management activities are controlled 

by the Agence Nationale pour la Gestion des Dechets Radioactifs (ANDRA), an organization within the CEA. The 

Chairman of the ANDRA Steering Committee is the Administrator of CEA. Other waste producers are members of 

the Steering Committee including EDF, COGEMA, and 

hospitals. EDF pays 80 percent of the cost of waste activities; COGEMA pays 10 percent; and CEA pays 10 percent. Research and development is funded by CEA, 

ANDRA, and DED, the Delegue pour les Effluents et Dechets Radioactifs (part of CEA). 

Local communities near nuclear facilities are involved 

in siting questions through a formal public inquiry process, 

but do not have a legal veto. However, if there is sufficient 

local opposition, the siting of the facility in the area will be 

abandoned. 

2.3 Waste Management Strategy 

All LWR spent fuel in France is to be reprocessed. 

Plutonium and uranium are both recycled after reprocessing. The costs of reprocessing are now about equal to the 

no-reprocessing option but reprocessing reduces the HLW 

stream and allows the recovery of plutonium. 

France first began reprocessing fuel from its defense 

reactors at Marcoule in a facility called UP1. Additional reprocessing facilities were built at La Hague. The La Hague 

reprocessing plants are being built in two parts. The first 

part, UP2, reprocesses French fuel. It first became operational in 1966 when it was used to reprocess gas-cooled reactor (GCR) fuel. It was modified in 1976 to reprocess 

light water reactor (LWR) fuel and has been used only for 

LWR fuel since 1985. The second part, UP3, is under construction and will handle foreign fuel until France needs the 

capacity for its own fuel. Because the French nuclear program has not grown at the predicted rate, France expects to 

D-4 
have excess capacity at UP3 for some time. COGEMA and 

a German energy company, VEBA, have recently announced an agreement in principle for VEBA to acquire 49 

percent ownership of UP3, and negotiations are currently in 

progress. 

Spent fuel from LWRs is taken to La Hague to be reprocessed. Fuel from GCRs is reprocessed at the Marcoule 

facility. Liquid wastes are stored in tanks temporarily before vitrification. All of the wastes from reprocessing of 

foreign fuels will be stored for 5 years and then shipped 

back to the country of origin. The vitrified waste from 

French reactor fuel will be stored for a minimum of 20 

years, perhaps substantially longer, before permanent disposal because a repository will not be available before 

2010. This gives the opportunity to cool the waste so that 

the thermal impact on the repository host rock will be 

reduced. 

The French reactors will produce a lifetime total of 

about 12,000 cubic meters of vitrified HLW, to be disposed 

of in two or three underground sites. The French are now 

doing deep drilling to explore four sites in different geologic media: clay, salt, schist, and granite. The schedule calls 

for the commencement of final placement of the HLW in a 

repository by the year 2010. 

2.4 Interim Storage Policy in Detail 

2.4.1 Interim storage: facilities and 

technologies 

Spent fuel from LWRs is stored in spent fuel pools at 

the reactors for about 1 year before it is taken to La Hague 

to be reprocessed. Reracking of reactor pools and dry storage at reactor sites are not foreseen for LWR fuel. La 

Hague has four storage pools with over 11,000 MTU capacity, and LWR fuel is stored there for 2 years until it is 

reprocessed. Wet pool storage was selected for this stage in 

the process because it was cheaper than other available 

storage methods (including dry vault storage) for the 

known, large lag storage requirements, and the technology 

has been proven. It also facilitates selection of individual 

fuel assemblies for reprocessing. 

After reprocessing, the liquid HLW is stored on-site at 

the reprocessing facility in tanks until it can be vitrified. 

After vitrification, it will be stored in dry storage vaults on 

site as long as necessary. In the case of UP3, which handles 

only foreign fuel, this period is only 5 years, after which 

time the HLW will be returned to the country of origin. For 

UP2, the storage period will be until a geologic repository 

is available. The facility was designed with a period of at 

least 50 years in mind, and the French believe that the period could be extended as long as needed because of the 

safety of monitored storage. The same is true of the facility 

at Marcoule. The existing dry storage facility at UP2 has 

the capacity to store 5 years of production from the vitrification plant. Capacity will be added in 5-year modules 

as needed. 

The CEA is constructing a dry vault storage facility 

(Cascade) at Cadarache, a CEA-managed nuclear facility, 

for non-commercial fuel owned by CEA. The impetus for 

the project was the need to find storage for the fuel from 

CEA's EL4 heavy water gas-cooled nuclear reactor, which 

closed in 1986. Intermediate storage for less than 50 years 

was planned. Casks, pools, vaults, and concrete canisters 

were considered as alternative storage methods. The advantage of modularity associated with the casks was not important because the quantity of waste was known. Vault 

storage in stainless steel canisters was selected. The initial 

planned capacity of the facility is 180 MTU. The capacity 

of the facility could be increased to 300 metric tons. The 

CEA currently plans to store submarine spent fuel and experimental fuels at Cascade in addition to EL4 fuel. Cascade is scheduled to become operational in 1989. 

2.4.2 Basis for at-reactor/centralized storage 

decision 

There has been no formal consideration of whether to 

store spent fuel at reactors or elsewhere. French policy to 

reprocess all fuel fairly promptly has obviated the need for 

such a decision. The reprocessing facilities have been 

built with sufficient front-end buffer capacity to handle 

contingencies. They were also designed to store all vitrified 

waste on site as long as necessary. 

2.4.3 Financial arrangements for storage 

Front-end storage at reprocessing plants is included in 

the reprocessing charge. 

2.4.4 Other roles for storage site 

As noted, the spent fuel and HLW storage facilities 

are ancillary to the primary activity at Marcoule and La 

Hague, reprocessing. 

2.4.5 Technical experience 

Perhaps the most relevant experience for the U.S. is 

the experience with the spent fuel receiving and handling 

facilities at La Hague. There are two unloading facilities, 

NPH (wet) and T zero (dry) that receive spent fuel in transportation casks, remove the fuel, prepare it for storage, and 

transfer it to one of the four storage pools at the site. NPH 

has two unloading lines with a combined capacity of 800 

metric tons per year, while T zero has a single line with the 

same total capacity as the two wet lines. The throughput 

D-5 
capacity of T zero is comparable to that planned for individual lines at DOE's proposed MRS facility. 

All activities in the dry unloading facility are automated and done remotely. More than 200 casks have been unloaded since the opening of the dry cell in 1986. The dry 

cell will only handle standardized casks (four types), while 

NPH can handle any kind of cask. Dry handling is preferred because wet storage generates more waste, especially 

contaminated water. 

Because of remote handling and automation (which 

reduces the number of workers needed), the dry facility has 

achieved individual worker doses that are far below those 

at the wet facility, and only one percent of the regulatory 

limit. Specifically, in 1987 the average dose per worker per 

year at T zero was only 50 millirem for an annual receipt 

rate of 800 MTU, compared to 320 millirem at NPH and a 

regulatory limit of 5 rem.4 

3.0 FEDERAL REPUBLIC OF GERMANY 

3.1 Status of Nuclear Power and Waste 

Management 

The Federal Republic of Germany (FRG) has 21 operating nuclear power plants (about 23 GWe) which provide 

about 40 percent of the electric power produced in the 

FRG. 5No further construction of nuclear power plants is 

anticipated in the foreseeable future, in part because of 

negative public attitudes towards nuclear activities following the Chernobyl accident. 6 

German reactors have been projected to discharge 

about 9,000 MTU of spent fuel through the end of this century. 7Light-water reactor (LWR) fuel is normally transferred to reprocessing facilities (primarily in France and the 

UK) within 7-10 years after discharge. It is expected that 

return shipments of vitrified HLW from that reprocessing 

will begin in 1992. 

3.2 Institutional Structure of Reactor Operation and Waste Management 

The FRG's nuclear plants are owned by 11 different 

utilities. The utilities are responsible for management of 

spent fuel and use the services of their jointly-funded company DWK (the German Company for Reprocessing of 

Spent Nuclear Fuel). Individual utilities are responsible for 

at-reactor storage, while a subsidiary of DWK, the Fuel Element Storage Company Gorleben Ltd. (BLG), operates 

the interim storage facility for spent fuel elements and radioactive waste materials at Gorleben on behalf of the utilities. (Other storage facilities that are under development 

are discussed below.) 

The Federal government in the FRG is responsible for 

the establishment of repositories for the final disposal of 

HLW and spent fuel (if any is disposed of directly without 

reprocessing). The Federal Science and Engineering Agency, PTB, is the organization directly responsible for collection, storage and final disposal of radioactive waste. The 

PTB has contracted with the German Company for the 

Construction and Operation of Repositories for Waste 

(DBE) for designing, constructing, and operating a repository for the permanent disposal of waste. DWK is one of 

four parent companies of DBE. Nuclear power producers 

pay current waste management costs and accumulate reserves for future decommissioning of nuclear facilities and 

waste management. 

Waste management activities are federally licensed, 

but the State governments actually issue the licenses, acting 

in the name of the Federal government. A formal public 

hearing is required and is organized by the State licensing 

authority. Public intervention is allowed in licensing proceedings. In principle, local governments do not have a legal veto, although in practice it could be difficult to force 

them to accept a waste facility against their will. 

3.3 Waste Management Strategy 

Federal law requires the recycling of spent fuel if economically and technically feasible. The FRG currently 

sends its spent fuel to France, the U.K., and the WAK pilot 

plant in the FRG for reprocessing. Until very recently there 

were plans for construction and operation of a domestic reprocessing plant at Wackersdorf, but those plans were halted when a German energy company, VEBA, announced 

the intention to acquire 49 percent ownership of the UP3 

reprocessing facility at La Hague, France. This will provide 

reprocessing capacity of about 400 MTU per year by the 

end of the century. 8 

While recycling is currently required by law, the FRG 

is also developing the capability for direct disposal of spent 

fuel. This is consistent with the recommendations of a 

study comparing reprocessing and once-through fuel cycles 

performed for the Federal Ministry of Research and TechD-6 

7 0 2 0 2 1 
nology. This study concluded in 1985 that direct disposal 

of spent fuel would be less expensive than reprocessing and 

thermal recycle in the foreseeable future, but recommended 

construction of a reprocessing plant because reprocessing 

appeared to be "indispensable on the grounds of energy 

policy."9At the same time, it recommended development 

of the capability for direct disposal of spent fuel.'° 

Currently, spent fuel is stored in spent fuel pools at reactor sites until it is shipped away for reprocessing. Most 

reactors have 3-10 year pool storage capacity, using compact racks. As discussed below, facilities for dry cask storage of spent fuel and/or returned HLW have been built at 

three sites, although it is uncertain how many of them will 

actually operate. 

Solidified HLW is destined for deep geologic disposal. 

The Gorleben salt dome is under investigation as a candidate site for a permanent repository. Exploratory drilling 

has been conducted at Gorleben and exploratory shafts are 

being sunk. Two disposal concepts are being pursued: emplacement of self-shielded casks in tunnels, and emplacement of canisters of waste into boreholes about 300 meters 

deep. The currently-expected date for operation of the repository is the year 2008. 

DWK is developing a triple-purpose cask, the Pollux 

system, which would be used for transportation, storage, 

and disposal of consolidated spent fuel. The weight limit 

on these casks is 65 metric tons because of the limits in 

cask handling capability of the equipment to be used to 

lower the casks down the repository shafts. Dry rod consolidation is being investigated, and a pilot facility that will 

test "conditioning" (disassembly and consolidation) of 

spent fuel in casks and canisters at a small scale is in the licensing stage. Consolidation would double the capacity of 

each cask (to a total of eight PWR fuel assemblies plus the 

associated skeletons) at a cost expected to be small compared to the savings resulting from use of fewer universal 

casks. The fuel would be stored for decades before disposal 

to allow the thermal output to decrease. 

3.4 Interim Storage Policy in Detail 

3.4.1 Interim storage: facilities and 

technologies 

DWK planned three 1,500 MTU supplemental spent 

fuel storage facilities: one, at the site of the planned reprocessing facility at Wackersdorf, was intended for receipt 

and storage of spent fuel at the front end of the reprocessing plant; the other two, at Ahaus and Gorleben, were to be 

independent interim storage facilities." (Gorleben was initially intended to be the site of an integrated fuel cycle 

complex including a reprocessing plant as well as a final 

repository. The storage facility would have served as storage for fuel prior to reprocessing. However, the reprocessing plant did not materialize, and the storage facility, 

originally licensed for storage of spent fuel, is now, in addition, being licensed for storage of HLW to be returned from 

France.) 

The Gorleben facility has been completed, and the 

Ahaus facility should be completed this summer. However, 

the date for actual receipt of radioactive material at any of 

the facilities is uncertain. Gorleben received an operating 

permit for storage of spent fuel in 1983, but the permit is 

under litigation; only low-level waste (LLW) is now being 

stored there. While a storage license has been granted for 

Ahaus, legal interventions are still possible, and the anticipated initial receipt of spent fuel from the high-temperature 

gas cooled reactor next year is not certain. The storage facility at Wackersdorf has been almost completed. However, 

the political leaders in the state say that there will be no nuclear facilities at the site, so the site is being converted to 

other uses. 

Gorleben has the capacity to store 1,500 metric tons of 

spent fuel or HLW in dry storage for up to 40 years. The 

spent fuel or HLW will be stored in nodular cast iron casks 

similar to those used at the Virgina Electric Power Company's Surry reactor. These casks have been licensed for 

transportation as well as storage in the FRG (the U.S. Nuclear Regulatory Commission [NRC] objects to the use of 

cast iron in transportation casks in the U.S). Up to 420 

casks will be stored in a large building designed for weather protection and shielding. 

DWK officials have indicated that dry cask technology was selected instead of wet storage for several reasons: 

1) it is cheaper than wet storage; 2) it is passive; 3) it can 

be designed for no releases; 4) there is no technical limit on 

its lifetime; 5) it is easy to decommission; 6) it is more politically acceptable because it appears less permanent; 7) 

there are advantages to using the casks for both transportation and storage; and 8) it is flexible in that additional storage capacity can be added easily. 

3.4.2 Basis for at-reactor/centralized storage 

decision 

At-reactor storage of either HLW or spent fuel outside 

of the reactor pools would have required a change to the licenses which could have resulted in hearings and the possible loss of the operating licenses. 

Another factor was the legal requirement that reactor 

operators specify how spent fuel will be managed 6 years 

in advance. This requirement could be met by reprocessing 

contracts covering the fuel, or by availability of an interim 

storage facility for fuel not yet subject to such contracts.' 2 

Local concerns about the duration of storage at the interim facilities did arise, and the state government asked 

D-7 
that a license for Ahaus not be granted until the suitability 

of a final disposal site had been demonstrated. 13While this 

stipulation was not adopted, the concern was addressed by 

assurances that the casks were transport casks that could be 

moved at any time. 

3.4.3 Financial arrangements for storage. 

The storage capacity at the Gorleben facility is divided among the DWK shareholder utilities according to their 

shares. They share operating costs, including depreciation 

of the investment, whether or not they use the facility. They 

will pay the additional cost of the dry storage containers required for any fuel they do ship to the facility, giving some 

economic incentive to maximize pool storage first. (There 

is no such incentive in the case of fuel covered by reprocessing contracts with COGEMA, since the reprocessing fee covers the cost of any interim storage of 

spent fuel required at the reprocessing plant.) 

3.4.4 Other roles for storage site 

The Gorleben facility is currently used to store lowlevel wastes. In addition, DWK plans to construct a pilot 

plant for spent fuel conditioning adjacent to the interim 

storage facility. The throughput of the plant will be limited 

to 35 metric tons of uranium per year. The facility will 

demonstrate the techniques of conditioning and encapsulation of radioactive wastes for final disposal in casks; encapsulating wastes in a form suitable for final storage; 

unloading vitrified HLW from transport casks into storage 

casks for interim or final storage; and maintaining transport 

and storage casks. DWK submitted a license application for 

the facility in May, 1986 and hopes to begin operations by 

1994. 

4.0 JAPAN 

4.1 Nuclear Power 

Japan has 36 nuclear reactors (about 28 GWe capacity) that generate approximately 32 percent of the nation's 

electricity. An additional 15 reactors (with about 15 GWe 

capacity) are under construction." The plants are located at 

15 different coastal sites." Japan plans a complete nuclear 

fuel cycle including recycling of plutonium to breeder reactors beginning about 2020, and to advanced thermal and 

light water reactors. Current law requires that reactor owners must identify a means of reprocessing spent fuel in Japan or abroad. Reprocessing is currently being carried out 

in France and the U.K. and to a small extent at the Tokai 

Mura facility in Japan. A large new reprocessing plant is 

planned to begin operation at Rokkashomura in 1998; the 

license application for this facility was submitted in March 

1989 and receipt of spent fuel at the facility's storage pool 

is expected to begin in 1994. 

4.2 Institutional Structure for Reactor Operation and Waste Management 

Japan's nuclear reactors are owned by nine major utility companies. Japan Nuclear Fuel Service Company 

(JNFS), established by those companies, is responsible for 

commercial reprocessing, including solidification and interim storage of reprocessing wastes, and for construction and 

operation of storage facilities for wastes returned from foreign reprocessors of Japanese fuel. The Power Reactor and 

Nuclear Fuel Development Co. (PNC), which reports to the 

national Atomic Energy Bureau, is the main governmental 

organization responsible for research and development on 

technology for HLW management and for surveying for 

possible repository sites. The Federal government is ultimately responsible for implementing HLW disposal, but no 

particular organization has been identified for carrying out 

that responsibility. The waste generators would pay for disposal, but no fees are being collected at this time. 

The procedures for licensing HLW management facilities have not yet been determined. The Ministry of International Trade and Industry (MITI) and the Prime Minister's 

office (STA) have regulatory authority over commercial reactor licensing, and STA may receive the assignment for 

storage facilities and repositories. Procedures for public involvement in waste management have not been determined 

either, although formal public hearings similar to those for 

reactor licensing are expected. Financial incentives and 

door-to-door visits by utility and government officials have 

been used to obtain public acceptance of reactors in the 

past. In any event, the central government has the legal authority to override a local veto on siting of nuclear 

facilities. 

4.3 Waste Management Strategy 

Current policy is that all spent fuel will be stored at 

reactors for 2-3 years and then shipped offsite for reD-8 

7 0 0 2 1 5 
processing. 16Japan now relies primarily on France and the 

UK for reprocessing services. The JNFS reprocessing plant 

to be built at Rokkashomura is planned to have a capacity 

of 800 MTU per year, just enough to handle the annual discharges from Japanese reactors currently expected for the 

mid-1990s. Careful consideration is being given to whether 

the contracts for reprocessing abroad would be extended 

after the year 2000. This may depend upon whether the 

current schedule for operation of the Rokkashomura plant 

in 1998 can be met. Slippages are possible, especially since 

there has been strong local opposition to the project. JNFS 

plans to construct a 3,000 MTU storage pool at Rokkashomura at the head-end of the reprocessing plant. This 

pool is planned to begin accepting spent fuel in 1994, four 

years ahead of the start of reprocessing. Since the projected 

rate of reactor discharges would fill that capacity in 4 

years, the schedule is very tight. 17 

The HLW from reprocessing will be vitrified and 

stored for 30-50 years for cooling before geologic disposal. 

The first shipments of HLW from Europe are expected in 

1990. The schedule for development of a permanent repository is relaxed. An underground research laboratory is 

planned for Horonobe, on Hokkaido, the northernmost island. This is not intended to be the repository site, however. Regulations for siting a repository are not expected to 

be developed until after 2000, and operation of the repository is not planned until after 2030. 18 

4.4 Interim Storage Policy in Detail 

4.4.1 Interim storage: facilities and 

technologies 

No independent spent fuel storage facility is planned 

in Japan. The only away-from-reactor spent fuel storage 

now contemplated is the 3,000 MTU pool planned as the 

front-end of the Rokkashomura reprocessing facility. Because there might be some need for at-reactor storage if domestic reprocessing is delayed and the foreign contracts are 

not renewed, the Central Research Institute of the Electric 

Power Industry (CRIEPI) is working on dry storage technology, and is currently participating in a 4-year exchange 

agreement with the Electric Power Research Institute 

(EPRI) in the U.S. on that subject. A particular focus of 

this effort is the possible use of nodular cast iron casks for 

transportation as well as storage. 19Such casks have been 

licensed for both purposes in Germany but only for storage 

in the U.S., since the U.S. NRC has concerns about use of 

cast iron in transportation casks. Both Germany and 

Switzerland have selected cast iron storage/transportation 

casks for their central storage facilities. Cask storage is of 

most interest to CRIEPI because it allows storage capacity 

to be added in small increments as needed, with low initial 

capital investment. Transportable casks are of particular interest because the utilities are responsible for spent fuel 

transportation as well as on-site storage, and dual-purpose 

casks are believed to be most cost-effective when the costs 

of both functions are considered together. 

Both returned HLW and the HLW produced at the 

Rokkashomura plant will be stored at that site. The relatively small amount of HLW produced at PNC's Tokai 

Mura plant will be stored at that facility. 

4.4.2 Rationale for at-reactor/centralized storage decision 

Since it is not clear at present that there will be a need 

for spent fuel storage capacity beyond that to be included 

as an integral part of the reprocessing plant, there has been 

no explicit decision about whether or not to expand at-reactor storage. Several factors may be relevant when and if 

such a decision must be made. The reactor sites are relatively small, and some may not have much capacity for 

storage outside of the pools. In addition, the owners of 

some power plants have committed to people living nearby 

to .ship the spent fuel offsite for reprocessing as soon as 

possible.20Thus in some cases the option of new contracts 

with foreign reprocessors may be a more attractive way to 

deal with slippages in domestic reprocessing than dry storage at the reactor site. 

4.4.3 Financial arrangements for storage 

The cost of spent fuel and HLW storage at reprocessing plants is included in the cost of reprocessing. 

4.4.4 Other roles for storage site 

As noted, the only waste storage away from the reactor sites will occur at reprocessing facilities. 

D-9 
5.0 SPAIN 

5.1 Status of Nuclear Power and Waste 

Management 

Spain has ten nuclear reactors (about 7.4 GWe total 

capacity) that supply about 36 percent of the country's 

electricity. 21A moratorium on new nuclear power plant 

construction has been in place since 1983. 

The operating reactors are expected to discharge 1,500 

MTU of spent fuel through the end of this century, and a 

total of about 5,500 MTU by 2035. Only fuel from the one 

GCR (Vandellos) is sent abroad for reprocessing by 

COGEMA. It is currently expected that the LWR spent fuel 

will be disposed of directly without reprocessing. 

5.2 Institutional Structure of Reactor Operation and Waste Management 

Spanish reactors are owned and operated by ten utilities. ENRESA, the state-owned National Waste Management Company created in 1984, is responsible for 

preparation, transportation, treatment, interim storage, and 

disposal of spent fuel and radioactive waste (including lowand intermediate-level waste), as well as for reactor decommissioning. ENRESA collects and manages a fee on both 

nuclear and non- nuclear electricity based on the estimated 

costs for decommissioning and for all spent fuel and waste 

management operations outside power stations. The Ministry of Industry and Energy controls ENRESA, reviews and 

approves the annual waste management plan prepared by 

ENRESA, and sets the waste management fee annually. 

Regulatory review of nuclear facilities is exercised by 

the CSN (Nuclear Safety Council), which evaluates license 

applications and recommends government actions. Licenses for nuclear facilities are granted by the Minister of 

Industry and Energy, after consultation with the CSN and 

local authorities. During the licensing process, public hearings are held to solicit local opinion. 

5.3 Waste Management Strategy 

Spain plans for direct disposal of unreprocessed LWR 

fuel. A small amount (several cubic meters) of solidified 

HLW from French reprocessing of the Vandellos GCR fuel 

will also require disposal. There is no sense of urgency 

about final disposal. Because of the planned aging period 

for spent fuel and HLW, disposal is not expected to begin 

until around 2020. Site selection criteria for a repository 

will be completed by 1995, and candidate sites proposed to 

Federal authorities by 2000. 

5.4 Interim Storage Policy in Detail 

5.4.1 Interim storage: facilities and 

technologies 

In 1987 the Government approved ENRESA's first radioactive waste management plan, including plans to develop a central storage facility for spent fuel. At that time, 

the facility was expected to begin operation in 1994. According to that plan, spent fuel would be stored at reactors 

for about 10 years, then moved to the central storage facility for a period of 40 years or more prior to final disposal. 

However, more recent studies of options for expanding reactor pool storage capacity have indicated that more time is 

available before the central facility is needed. The second 

radioactive waste management plan, approved in January 

1989, does not contain a specific commitment to or schedule for a central storage facility. Instead, the plan indicates 

that there is sufficient time for the decision about the type 

and location of interim storage to ensure that there will be 

extensive experience in other countries with the system that 

is finally selected. 22 

Both wet and dry storage are under consideration, and 

no final decision has been made. ENRESA is currently 

supporting work by an American company (Nuclear Assurance Corporation) on the development and licensing of a 

transportable storage cask for possible use at the central facility and perhaps at reactor sites before shipment to central 

storage: Availability of such casks is seen as providing additional flexibility to the waste management program. 

5.4.2 Basis for at-reactor/centralized storage 

decision 

Two major benefits are cited for a centralized interim 

spent fuel storage facility. First, because of the extended 

schedule for permanent disposal, some reactors may require decommissioning before a repository is available to 

accept the fuel. While at-reactor storage is seen as satisfactory while the reactors are operating, ENRESA—which is 

responsible for decommissioning as well as spent fuel management—would prefer to have the fuel removed from the 

sites after shutdown. (For planning purposes, the current 

waste management plan assumes that dismantlement of reactors could begin 5 years after shutdown. 23 ) Second, the 

central storage facility would provide a site for R&D on 

spent fuel, e.g. on encapsulation techniques for disposal. 24 

Because there is no pressure for early disposal, there 

has been no concern that availability of a central storage 

D-10 

7 0 ") .;) 2 
facility would delay the repository program. 

5.4.3 Financial arrangements for storage 

The cost of a central storage facility would be paid for 

from the fee collected by utilities from consumers of 

electricity. 

5.4.4 Other roles for storage site 

As noted, ENRESA hopes to use a central storage site 

for waste management R&D. 

6.0 SWEDEN 

6.1 Status of Nuclear Power and Waste 

Management 

Sweden has 12 nuclear reactors (about 9.6 GWe total 

capacity) that supply about 50 percent of the country's 

electricity. 25As a result of a national referendum on nuclear power in 1980, a parliamentary decision was taken to allow use of existing nuclear capacity but to phase out all 

nuclear plants by 2010 at the latest. The first unit is 

planned to be shut down in 1995. By the end of the nuclear 

power program in 2010, Sweden's reactors are projected to 

have produced about 7,800 metric tons of spent fuel which 

will be handled as waste. 26Sweden has decided not to reprocess its spent fuel because it is not now economical to 

do so and because of nuclear proliferation concerns. 

Sweden is trying to sell the remainder of its existing reprocessing contracts. 

6.2 Institutional Structure of Reactor Operation and Waste Management 

In general, implementation of waste management is a 

responsibility of the waste generators, while regulation and 

oversight are a responsibility of the government. Swedish 

reactors are owned and operated by four utilities, one of 

which—the State Power Board—is government-owned. By 

law, the owners of nuclear power reactors have primary responsibility for all aspects of radioactive waste management, including both interim storage and disposal. The 

utilities are discharging this responsibility through the 

Swedish Nuclear Fuel and Waste Management Company 

(SKB), created by the utilities in 1972 and controlled by 

them. SKB is responsible for executing the spent fuel and 

waste management program for the Swedish utilities and 

manages waste disposal research and development 

facilities. 

The ultimate and long-term responsibility for disposal 

lies with the Government, which supervises the planning, 

research and development for the waste management program and administers funding for waste management 

through the SKN (the National Board for Spent Nuclear 

Fuel). This funding is provided through a fee on nuclear 

electricity production that varies for each utility depending 

upon the waste mix it produces. The fee is recalculated 

annually. 27 

Regulatory responsibility for nuclear facilities is 

shared by the SSI (the National Institute of Radiation Protection) and the SKI (the Nuclear Power Inspectorate). The 

SSI sets and enforces basic radiation protection standards, 

while the SKI licenses, supervises, and controls safety of 

design, construction and operation of nuclear facilities. 

Any applicant for a license must obtain a site permit from 

the Government. The permit can be vetoed by the local 

municipal administration and must receive favorable recommendations from both SKI and SSI. 

The local Community council can veto the location of 

nuclear facilities and only Parliament could overrule such a 

veto. Sweden provides no direct benefit for the local communities for accepting nuclear facilities. Some communities are antinuclear, while others view nuclear facilities 

more favorably because they provide jobs and other benefits to the local economies. Sweden has created local safety 

committees at each nuclear site to serve as liaison with officials at the nuclear facilities. The committees, which are 

supervised and funded by the government, are entitled by 

law to full information regarding nuclear activities. 

6.3 Waste Management Strategy 

Sweden's approach to waste management has been 

shaped by the 1977 Stipulation Law that linked initial loading of fuel in new reactors to a demonstration that each 

utility had either a plan for safe direct disposal of the spent 

fuel or a contract for reprocessing combined with a plan for 

safe disposal of the HLW. 28This led to early signing of reprocessing contracts with France, and to rapid preparation 

of design studies to demonstrate the existence of concepts 

for safe disposal. Three studies (KBS-1, KBS-2, and 

KBS-3) were prepared, the first dealing with HLW and the 

latter two with direct disposal of spent fuel. They have 

been accepted by the government as adequately demonD-11 

7 0 2 1 3 6 
strating that both HLW and spent fuel can be disposed of 

safely. 

Although SKB contracted for foreign reprocessing of 

over 800 MTU of spent fuel, the government has announced that no additional reprocessing contracts will be 

signed. No plutonium recycle is now contemplated and direct disposal of spent fuel is planned. SKB is trying to sell 

the existing reprocessing contracts. Some reprocessing contracts have already been sold to Japan. Also, a small 

amount of fuel that was shipped for reprocessing has been 

swapped against German spent fuel with some West German utilities, to avoid the need of taking back reprocessing 

waste to Sweden. This was a one-time exchange of reprocessing waste for spent fuel that will not be repeated. 29 

In the reference waste management plan for direct 

spent fuel disposal laid out in KBS-3, spent fuel is normally stored on-site for at least 1 year in a spent fuel pool 

and then shipped by boat to a central interim storage facility, CLAB (described below). The fuel would remain at 

CLAB for 30 to 40 years before final disposal, because the 

resulting tenfold reduction in radiation and heat output 

would facilitate achievement of the relatively low maximum temperature (80°C, according to KBS-3) planned for 

the permanent repository. Based on these assumptions, 

Sweden's target date for developing a repository is currently the year 2020. The shortest possible storage period is 

about 15 years from the date a decision is made, because of 

the time it would take to find a site and build a repository. 

A shorter storage period would require a reduction in the 

amount of waste contained in each canister to keep the 

same target temperature level. 

6.4 Interim Storage Policy in Detail 

6.4.1 Interim storage: facilities and 

technologies 

The CLAB plays the principal role in spent fuel storage in Sweden. At-reactor storage serves only to provide a 

relatively short cooling period before spent fuel is shipped 

to CLAB. Limited lifting capabilities at reactors prevented 

realization of the increased shipping cask capacities that a 

longer period of at-reactor storage would allow. Some of 

the pools in Sweden have high density racks but the newer 

reactors have less pool capacity because of the availability 

of the central interim storage facility. 

A Parliamentary Commission recommended in 1976 

that a central interim storage facility be built. The Commission recommended that the facility be located in an underground cavern and that a sea transportation system be 

developed. The decision to build the central interim storage 

facility was made in 1978. CLAB was built near the Oskarsham Nuclear Plant, a coastal location suitable for sea 

transportation from other Swedish reactors, which are also 

located on the coast. CLAB began receiving fuel in 1985. 

CLAB is a wet pool storage facility. At the time 

CLAB was designed, Sweden was aware of dry cask storage but the technology was not well developed. As a result, 

dry cask storage was not seriously considered. 3° 

The storage building is located underground in a rock 

cavern whose ceiling is 25 to 30 meters below ground level. CLAB has sufficient capacity to store 3,000 metric tons 

of fuel—all of the fuel generated by Sweden's 12 existing 

reactors until the mid-1990s. Expansion will be needed to 

hold the 7,800 metric tons that would be generated by 

those reactors if they operate to 2010. CLAB was built in 

such a way as to facilitate such expansions. 

The facility was built to minimize the doses to personnel. In actual operation, the doses have been only 25 percent of those that had been calculated. In 1987, for 

example, the average dose was about 110 millirem per 

worker. The total dose to workers in that year was about 

6.8 manrem, or about 25 millirem per MTU of spent fuel 

received at CLAB during the year (272 MTU). 31 

6.4.2 Basis for at-reactor/centralized storage 

decision 

The Parliamentary Commission that considered spent 

fuel storage options focused on what approach to central 

storage should be taken, not whether there should be a central storage facility. At the time the study was performed, 

dry storage was not thought to be a readily-licensable option, so the only approach to expanding at-reactor capacity 

was thought to be construction of new pools. This was not 

considered a practical option, particularly in view of the 

limited space at the reactor sites. 32 

Siting was not a problem, since the local community 

welcomed the CLAB facility because it provided jobs and 

because there seemed to be consensus that it is the country's responsibility to handle its own wastes. There was no 

opposition to CLAB based on concerns that availability of 

a storage facility might lead to deferral of disposal. Indeed, 

some environmental groups favor continuous monitored 

storage because they believe it is not yet possible to safely 

and permanently dispose of the waste. 

6.4.3 Financial arrangements for storage 

CLAB is paid for from the waste disposal funds. Costs 

of the facility are allocated among the utilities according to 

the amount of spent fuel they will send to it. 

6.4.4 Other roles for storage site 

There are no current plans to use the CLAB site for 

any other waste management purposes. 

D-12 

7 0 2 2 1 7 
7.0 SWITZERLAND 

7.1 Status of Nuclear Power and Waste 

Management 

Switzerland has five nuclear reactors (about 2.9 GWe 

total capacity) that supply about 38 percent of the country's 

electricity. 33Three others were planned but later cancelled 

mainly because of extensive public opposition. In any case, 

it was less expensive to purchase power from France. No 

new nuclear power plants are planned for at least the next 

10 years. 

A total of about 2,000 MTU of spent fuel is expected 

to have been discharged through the end of this century. 

Fuel is currently stored in reactor pools, and pool capacity 

is expected to be adequate through the mid-1990s. Swiss 

utilities currently purchase reprocessing services from 

France and the UK. It is expected that shipments of vitrified HLW from that reprocessing may begin in 1993. Recycling of separated plutonium in LWRs is practiced 

already on a pilot scale. 

7.2 Institutional Structure of Reactor Operation and Waste Management 

Swiss reactors are owned and operated by five utilities. The utilities are responsible for storing spent fuel, vitrified HLW, and other reprocessing wastes until disposal 

capacity is available. To meet storage needs in the late 

1990s, the utilities initially formed the Consortium 

d'Etudes Lucens (CEL) to plan a centralized interim storage facility for spent fuel and returned HLW to be located 

at the site of a research reactor at Lucens. When this project was dropped for reasons discussed below, a new organization, Zwischenlager Gesellschaft (Intermediate Storage 

Company), was formed to develop a storage facility at another site in Wuerenlingen. 

All producers of radioactive waste are also responsible 

for its safe disposal, although the government is permitted 

to take over this responsibility with utilities funding the activities if the utilities are not able to take care of the problem themselves. The National Cooperative for the Disposal 

of Radioactive Waste (NAGRA/CEDRA), formed by the 

waste producers including the federal government, currently has responsibility for developing disposal facilities. 

The costs of the activities of NAGRA, and the future costs 

of repository construction, are included in the charge for 

electricity. The utilities accumulate reserves for ultimate 

disposal, while NAGRA handles funds for R&D on 

disposal. 

The Swiss Department of Energy is responsible for 

setting the standards and the Government is responsible for 

licensing nuclear power plants and facilities for the interim 

storage and disposal of nuclear wastes. Cantons have a land 

use veto over water use, zoning, and construction permits, 

but may not use this power arbitrarily to block nuclear projects. Such projects must be treated the same as all others. 

Conflicts between the Federal government and local governments (cantons) may be settled by a Federal tribunal. 

Ultimately, the Federal government has the right to assist 

the development of waste disposal facilities through expropriation of land, and can transfer that right to NAGRA. 

7.3 Waste Management Strategy 

Reprocessing with recycling of plutonium and uranium in thermal reactors is the current Swiss strategy for 

the back end of the fuel cycle, and contracts for reprocessing in France and England cover all the spent fuel to the 

mid-1990s. When these contracts expire, the Swiss will 

reexamine whether reprocessing shall continue. The option 

of direct disposal of unreprocessed spent fuel is open, but 

no project is now being conducted to develop this option. 

The first solidified HLW can be returned from France 

in 1993. This waste and any unreprocessed spent fuel that 

cannot be accommodated in reactor pools will be stored in 

a central facility until eventual reprocessing or final disposal. The period of storage for both spent fuel and HLW is 

planned to be about 40 years after the spent fuel (disposed 

of directly or reprocessed to produce HLW) is discharged 

from the reactor. This storage period is planned to reduce 

the heat load and temperature in the final repository and to 

allow time for siting a repository. 34 

A 1978 revision to the Atomic Energy Law provided 

that no new reactor licenses may be issued unless it can be 

demonstrated that safe disposal of the radioactive wastes 

produced by the plants is feasible. Since there were no new 

plant orders, this statute did not put much pressure on the 

development of a final disposal solution. Therefore, the 

Department of Energy conditioned the utilities' licenses for 

their nuclear power plants to require that safe disposal be 

demonstrated by December 1985 or the licenses would be 

revoked. NAGRA was requested to conduct the demonstration. The resultant study was called Project Gewaehr 

(Guarantee). The 6-year study, completed in 1985, concluded that a repository for HLW was feasible with present-day technology. A 6-year review of the study by 

government safety authorities, with input from foreign experts, concluded that Project Gewaehr had provided adequate proof that safe disposal for HLW was achievable, but 

lowarr111■•••■111111MINIIIIII■ 

D-13 

7 2 1 
that no specific site had been shown to be acceptable for a 

repository. 

With a planned 40 year aging period for spent fuel and 

HLW, disposal is not expected to begin until after 2020. 

Despite this relaxed schedule for operation of a repository, 

Project Gewaehr led to a firm policy decision that there 

must be a significant continuous effort towards its development.35The next step required after Project Gewaehr's 

conceptual demonstration of existence of a disposal solution is site characterization to identify precisely where in 

Switzerland the concept could be implemented. One or two 

sites are to be selected for characterization from the surface 

during the 1990s, with sinking of a shaft and construction 

of an underground research laboratory at one site early in 

the next century. (An underground research laboratory is 

already in operation at Grimsel, but this facility is not intended to be developed into a repository.) A decision 

whether to proceed with development of a Swiss repository 

or to participate in a foreign repository will be made 

around the year 2000. If the domestic repository option is 

selected, a license application would be submitted in 2010, 

with operations to begin by 2025. 

7.4 Interim Storage Policy in Detail 

7.4.1 Interim storage: facilities and 

technologies 

Spent fuel is stored on-site at the reactors until it is 

shipped to a reprocessing facility in France or the U.K. All 

plants have the capacity for 7 to 12 years of buffer storage 

over a full core reserve. The older plants only had about 3 

years of buffer capacity but they have reracked to create 

additional storage capacity. 

As noted, a central storage facility is planned to handle both returned HLW and spent fuel not subject to reprocessing contracts. The facility is to be sited in 

Wuerenlingen (siting questions are discussed further below). Plans for the proposed facility call for dry storage of 

1,555 MTU of spent fuel or 550 cubic meters of vitrified 

HLW (from reprocessing 4,968 MTU of spent fuel) in 184 

Castor-type transportation/storage casks. The planned design is very similar to Gorleben, with the casks to be placed 

in a building for shielding and safeguards considerations 

(for spent fuel). The initial capacity is sufficient for 15-20 

years' accumulation, while the storage facility will be designed to have enough capacity to store 60 years of HLW if 

the Swiss continue to reprocess the spent fuel and to store 

30-35 years of spent fuel if reprocessing is discontinued. It 

is also hoped that a waste treatment facility, including advanced compaction facilities and an incinerator for organic 

materials and resins, will be located on the same site. 

In selecting a storage technology, the Swiss considered storage in casks with passive cooling and three options 

involving active cooling: pools, concrete bunkers, and 

modular bunkers. They selected dry cask storage because it 

involved the lowest initial investment costs; it was flexible 

enough to handle either spent fuel or HLW; it required only 

passive cooling; and it could meet the safety standards, 

e.g., withstanding an airplane crash. The ability of cask 

storage to add capacity in very small and relatively inexpensive increments as needed was seen as particularly important in view of the small volumes of waste involved. 

Use of transportable storage casks also left open the option 

of at-reactor storage in the event of difficulties in siting a 

central facility. 

7.4.2 Basis for at-reactor/centralized storage 

decision 

The Swiss considered both decentralized storage at the 

reactor sites and a centralized storage facility as options for 

interim storage of the HLW when it is returned from 

France and the U.K. Several factors appear to have been 

important in the selection of the centralized option. 36It was 

felt that it was easier to do everything associated with providing an interim storage facility just once at a single central site than to do it four times at the four reactor sites. It 

was recognized that a decentralized approach would allow 

existing crews to be used, but overall the centralized approach was seen as a more optimized system. A related 

consideration was the idea of using the site for other waste 

facilities and activities, such as a low-level waste incinerator and a waste conditioning plant. This would provide a 

centralized back end of the fuel cycle. 

Licensing issues were also a consideration. Some restrictions in existing permits prohibit the storage of wastes 

from more than one plant at any plant site, and it would be 

difficult to try to divide the waste stream from abroad in 

such a way that each site only received the waste from reprocessing the spent fuel generated at that site. On the other hand, some licensing considerations may favor a 

decentralized approach. Utilities interpret their permits as 

requiring only a license amendment instead of a new license if the waste is placed within the existing boundaries 

of the plant site, although some disagree with that interpretation. Licensing a centralized facility at a new site involves two phases—a construction permit and an operating 

license proceeding—which provides more opportunities for 

intervention in opposition to the facility. 

Centralized storage was not seen as providing any significant financial advantages over decentralized storage. A 

centralized storage facility would require purchase of land, 

which is very expensive in Switzerland, and would involve 

a longer licensing process. However, locating a waste treatment plant at the same site would allow some cost savings 

D-14 

7 0 0 9 
with regard to the fuel handling crews. On balance, cost 

does not appear to have been an important factor. 

When the decision was made that a centralized facility 

was the preferred option, the difficulty of licensing new 

sites for nuclear activities favored an initial effort to site 

the facility within the cave used by a decommissioned research reactor at Lucens. It was hoped that the existing site 

license would be sufficient, and that a new license would 

not be required. When it became clear that a new license 

would be necessary because the storage facility would require new surface facilities, and that there was strong local 

opposition, the site was dropped. The utilities then adopted 

a two-track approach: plan for the possibility of at-reactor 

storage and seek a new site for a central facility. 

Following the at-reactor track, the Benzau I plant is 

applying for a license amendment now to expand on-site 

storage because it is running out of room in the pool. This 

expansion may be necessary now even if the effort to site a 

central facility is ultimately successful because of the time 

delay involved. If they build additional capacity they plan 

to build enough storage capacity to last for the life of the 

plant. 

Meanwhile, a site at Wuerenlingen has been selected 

for the second attempt to develop a central storage facility. 37This site has a number of advantages. Three of the 

five Swiss reactors are within 20 kilometers of the site, and 

the other two are within 100 kilometers. In addition, 

Wuerenlingen is the location of a national institute for nuclear research (the Paul Scherrer Institut), where some 

waste treatment and conditioning activities including incineration are already conducted. Thus the proposal to include 

a new incinerator and waste conditioning facilities at the 

storage site was not expected to raise major new issues and 

concerns with the local population. 

A license application for the Wuerenlingen site has 

not yet been submitted because of local opposition to the 

project. The safety of the facility does not appear to be 

the source of concern. Rather, the municipality in which 

the site is located wants some direct payment from the utilities for accepting a facility that is not wanted by other 

communities. On June 23, 1989, the local assembly in 

Wuerenlingen met to consider whether to approve a zoning 

plan designed to prohibit construction of the facility or 

whether to allow the facility to proceed subject to the terms 

of an agreement that had been accepted by both the local 

council and the utilities. The agreement included several 

important provisions. First, it provided for annual payments 

to the community by the utilities. Second, it afforded the 

community some direct oversight of the facility by giving it 

one seat on the board of directors. Finally, it limited the period of storage to 25 years, at which time the agreement 

would have to be renegotiated. If the community decided at 

that time not to agree to further storage, the waste in storage at the site would have to be removed within 10 years. 

This provision was explicitly intended to ensure that storage remains only an interim solution. 

By a large margin, the assembly rejected the zoning 

plan and approved the agreement. However, it is likely that 

opponents will be able to call for a full referendum on both 

propositions, which might not occur until the fall. Submission of a license application for the facility will probably 

await the results. 

7.4.3 Financial arrangements for storage 

The utilities will share the costs of developing and operating the central storage facility. Each utility will also pay 

the cost of the casks used to store its own fuel at the 

facility. 

7.4.4 Other roles for storage site 

As discussed above, the site is intended to become a 

center for a wide range of waste management activities, 

many of which are already conducted at the Wuerenlingen 

site of the nuclear research institute. Responsibility for all 

these activities would transfer to the Zwischenlager Gesellschaft, making a single organization at a single site responsible for the management of all radioactive wastes 

prior to disposal. 

8.0 UNITED KINGDOM 

8.1 Status of Nuclear Power and Waste 

Management 

The United Kingdom (U.K.) has 41 power nuclear reactors-26 gas cooled (MAGNOX) reactors, 14 advanced 

gas-cooled reactors (AGRs), and one breeder reactor. These 

reactors represent about 12 GWe total generating capacity, 

and produce about 17 percent of the UK's electricity. The 

UK is planning construction of four new PWR nuclear stations totalling 4.4 GWe between 1990 and 2000. 38Work on 

the first (Sizewell B) has started. 

Spent fuel, including some of foreign origin, has been 

reprocessed at the Sellafield plant (formerly Windscale) 
since 1952. Plutonium from British sources is used in the 

Dounreay prototype breeder reactor or is stored for future 

use in breeders and thermal reactors. A large new plant for 

reprocessing thermal oxide fuel (THORP) is under construction at Sellafield. High-level waste will be vitrified at 

the Sellafield site and stored there for at least 50 years before eventual disposal. 

8.2 Institutional Structure of Reactor Operation and Waste Management 

Although electricity generation is a nationalized industry in the U.K., it is currently being privatized. The two 

major utilities are the Central Electricity Generating Board 

(CEGB) and the South of Scotland Electricity Board 

(SSEB). The former reports to the Secretary of State for 

Energy, the latter to the Secretary of State for Scotland. 

Both are responsible for managing spent fuel until it is 

shipped to Sellafield. British Nuclear Fuels plc (BNFL) is 

responsible for storing and reprocessing the fuel at Sellafield, and for storing the resulting HLW until disposal. 

BNFL reports to the Secretary of State for Energy. 

A national company, U.K. NIREX, Ltd., was established in 1982 to site, build, and operate repositories for 

low- and intermediate-level wastes. Efforts to develop a repository for HLW have been deferred indefinitely, and it is 

not clear whether NIREX will ultimately have that responsibility. The U.K. Department of the Environment (DoE) is 

responsible for waste management policy and for research 

on HLW disposal, which is contracted primarily to the British Geologic Survey and the U.K. Atomic Energy Authority (now known as AEA Technology). Since the waste 

producers are all government-owned organizations, provisions are made in their budgets for waste management 

costs. There is currently no separate waste fund or fee on 

nuclear-generated electricity. 

The DoE is responsible for approving licenses for 

waste management activities. Her Majesty's Nuclear Installation Inspectorate, part of the Health and Safety Executive 

which was established by Act of Parliament, is responsible 

for performing independent assessments of the safety of the 

electricity generating boards' activities. The central government has the legal authority to override local vetoes of 

siting decisions, but this is not done lightly. 

8.3 Waste Management Strategy 

Current planning is that all MAGNOX spent fuel will 

be reprocessed, and most is stored at reactor sites in pools 

for a year or less before shipment to the reprocessing plant. 

Most of the oxide fuel from the AGRs is being stored in 

pools at Sellafield until completion of the new thermal 

oxide reprocessing facility (THORP). While CEGB has a 

major commitment with BNFL to reprocess spent fuel, 

consideration is being given to deferring reprocessing and 

storing the fuel for an extended period. 39To date, commitments have been made to reprocess only 1850 MTU of 

AGR fuel. The question of possible direct disposal of spent 

fuel has not been dealt with yet. 

HLW is now stored in liquid form at Sellafield. It will 

be solidified following completion of a vitrification plant 

(using a French process) now under construction there. The 

solidified waste will be stored at Sellafield for at least 50 

years before ultimate geologic disposal. This policy of extended storage and deferred efforts to site a repository was 

adopted in late 1981 following intense local opposition to a 

drilling program associated with field research for a HLW 

repository.4° The focus of the U.K.'s geologic research program is now on confirming the applicability to the U.K. of 

other countries' research. 

8.4 Interim Storage Policy in Detail 

8.4.1 Interim storage: facilities and 

technologies 

MAGNOX fuel is usually shipped to Sellafield for reprocessing after no more than a year of storage in the reactor pool because the fuel cannot be wet-stored for very 

long. However, there is a dry vault storage facility at the 

Wylfa power station for its MAGNOX fuel. The original 

equipment, installed in 1964, consisted of three 80 MTU 

modules; additional facilities, each with a capacity of 350 

MTU, were added in the late 1970s. (A similar design, applicable to LWR fuel and HLW, was submitted by GEC Energy Systems to the U.S. NRC as a Topical Report and was 

approved in 1988.) 

The AGRs have onsite pool storage capacity for only 

a total of about 2 years of operation. They are dependent on 

shipping fuel to Sellafield within that period, for storage 

there in pools until the THORP plant begins operating. 

CEGB announced last year that it plans to build a dry vault 

storage facility for AGR fuel at the Heysham site, which is 

the location of four reactors.4' This will allow fuel not covered by current reprocessing contracts with BNFL to continue to be shipped offsite in a timely manner, while at the 

same time allowing decisions about reprocessing that fuel 

to be deferred. The facility will allow storage capacity to 

be added in modules of 210 MTU. The facility will begin 

with four modules and can be expanded to up to 30 modules, or about 6000 MTU. Cask storage was considered but 

rejected because of cost. 

The PWRs are being built with much greater storage 

capacity than the AGRs—probably more than 20 years taking into account likely increases in bumup. Because of the 

leeway that this storage capacity provides, the current posiD-16 

7 2 0 2 1 7 
tion is that no decision about the management of the PWR 

spent fuel has to be made at this time. 

8.4.2 Basis for at-reactor/centralized storage 

decision 

The CEGB has not yet publicly stated its arguments 

for the decision in favor of a centralized site for storage for 

AGR fuel. However, economic considerations appear to 

have been an important factor. Because AGR fuel is encased in stainless steel, it requires very thorough drying before storage in order to avoid corrosion. That in turn 

requires a head-end facility for drying the fuel and sealing 

it into containers. This facility (which would be required 

even with cask storage) represents a significant part of the 

total cost of storage. As a result, there are economies of 

scale in constructing only one such facility at a central site. 

The full case for the decision may be made public in 

the Public Inquiry that is likely to result from submission 

of an application for planning permission for use of the site 

for the storage facility. Local reaction to the decision has 

been strong, and concerns about how long the fuel might 

be left there have been expressed, but the facility has not 

become a national issue. 

8.4.3 Financial arrangements for storage 

The AGR storage facility will be a joint venture of the 

CEGB and SSEB, but no financial details are publicly 

available. 

8.4.4 Other roles for storage site 

As noted, Heysham is already the site of four reactors. 

No other waste management activities are planned for the 

site. 

9.0 CONCLUSIONS 

1.The eight countries show great diversity in their institutional and political environments for nuclear power 

and waste disposal. None mirrors the U.S. situation very 

closely. All have substantially less nuclear power generation (and resulting waste) and far fewer waste producers to 

deal with than does the U.S. On the other hand, in six of 

the eight countries, nuclear power represents a larger—in 

some cases, much larger—relative share of the country's 

electricity generation than the approximately 20 percent in 

the United States. (See Tables Dl and D2.) 

2. The countries vary widely in their reprocessing policies. Five plan to reprocess some or all of their spent fuel; 

two have decided not to reprocess; and one (Canada) has 

made no firm decision. (See Table Dl—Reprocessing.) 

3.Reprocessing has in the past allowed some of the 

countries to avoid having to make decisions about spent 

fuel storage. However, because the economics of reprocessing are not now favorable, some of the countries that are 

currently reprocessing fuel are using spent fuel storage as a 

way to defer early commitments to further reprocessing. In 

several of countries that are reprocessing fuel, direct disposal of spent fuel is now considered an option. 

4. All eight countries plan on disposal of HLW or 

spent fuel in a geologic repository, and are engaged in 

some phase of the scientific investigations needed to develop such a repository. 

5. The pace of repository development in these countries is not driven by any perceived urgency to demonstrate 

the existence of a disposal facility or to dispose of waste. 

While two countries (Sweden and Switzerland) have laws 

linking operation of nuclear powerplants to a demonstration of the existence of a safe method for disposing of the 

waste, these laws required only a conceptual demonstration 

rather than actual siting and operation of a disposal facility. 

In general, deferred disposal is viewed as beneficial because it reduces the heat output of the waste. Only West 

Germany plans to have a repository before 2010, and that 

country has no plans for rapid disposal. (See Table DI—

Repository Schedule.) 

6. Centralized facilities for storage of spent fuel and/or 

HLW have been built or are planned (at reprocessing plants 

or other sites) in all but one country. Only in Canada, with 

most reactors located at a few multiple-reactor sites, does it 

appear that at-reactor spent fuel storage might be the preferred option, although no decision has yet been made. (See 

Table Dl—Sites.) 

7.While there have been local concerns raised about 

the length of storage at a central storage facility in some 

cases, this has not become a national issue in any of the 

eight countries as it has in the United States. In particular, 

opposition to storage facilities on the grounds that they 

may reduce the incentive to develop a permanent repository does not appear to have been a major factor in the storage decisions in any of the countries. 

8.Transportable storage casks appear to be the favored modular dry storage option. Two countries have already selected transportable storage casks for their central 

storage facilities, and three others are developing or evalD-17 
:RA . 

• 

. 

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' Reactor•Sites Wet Pools 

. .... , - .., ,.. 

.. ., ...„ „. .., 

•Reproc. ; ; z SF-Wet pools ••4 2 Yrs .; • 

Plants, ; ° „ r•i, ; 'W--:..Dry Vaults, • • >20, Yrs •., 

, 

'EDF- : I : , 

C. ogema: ; 

Litrle 7APper'•eire; ::: , ...".>b-iti 

:Public .° ; ; s 

:Concern ; 

., '. 

•FEDERAL : 

REPUBLIC: 

. .. 

: OF: GER-:. .' 

MANY; `.'. 

.(FRG) ' 

....3:GV.V.e; ; . • 

•(40%) r• ' i 

' " 

Yes r• " 

(Frg,' ' 

F. !' " . - 

Uk) 

. 

:Reactor Sites' " - • Wet PoolS : 3410 Yrs' " 

r• ' ''' ''- - ' " ' ' ' • 

, ; , , . „ — 

.. 

•Ilridep.faCilitY7. 7. ; SF-Dry Casks' ; ' r ; Undecided : 

.(Gorielpenr, :' HLWiLtDry Casks`' r ,>10,Y,rsi; : ' 

Ahaus) , 

Utilifiei : ; 

- . 

. • ; : ; 

Utilities :' r : •• . 

.(ThrU.BLG) ;7, 

. ..... .. , • 

. , .. . 

' $6,6166 -0.1.6. O4.1- 

stion to Siting s. 

Anterirn•Stor-: r . 

age Facilities — , ; s 

. s. 

:.;:?1,500::: 

; 4?I T r 

• JAPAN!" 

(JA) : ',. .. 

' '287GWe !' 

(32%) 77 

• " 7 ' - • 

s 

'(Fr ; 

Ja) :: ; ; -i; , 

, 

.. ; , . 

Reactor: Sites ; -SF-Wet pools; 2-3 Yrs 

•; - '. ' - - '''' - " , ; .. ..' 

., 

rRehicidi.:pranies; r $F•=-Wei Pools! : ; • ii-•-•:4 Yrs r .; t 

•:1-1t- W,Undecid.ed/ . i 30-50 Yr 

' •• ' 

, , „ 

:Utilities:" 

:Utilities; : ; ... 

•(Thry JNFS) ; '', : 

" ' " ' " ' " „• 

Stiong.0pCiosi; ' : ' - 

tion,to•NeW 

RReprocessing: • 

Plent7Where SF: ; 

. and:HLW,Will. 7,7 •.: 

•be:Stored ! i, - 

7>20307: 

. s 

SPAIN • • 

, . . 

, 7 GViia ,.. 

.(36%), 

„..- 

.. „. , .. . . . 

.Reac(pr Sites , ; . Wet.Pools • • 1 Undecided - , 

„

, 

'' 

, 

'' ... .. 

, ... . , . , 

. „ „ 

lIndep: - Pools and/or i Undecided : 

Facility - ; • ;Dry Casks' • • 

(Not ies a • 

„ . 

Utilities`; , 

. ; ', /,. i•• il 7• • 

:Gbvt Corp: , . 

:(ErireSa) ;; •, '' 

. „ . , • „ 

•No Effort Yet • ' „ , . , . : . 

To Site a New ', 

"Storage 

Facility: •• ' 

. . „ ... 

. . „ 

,-,i6ir - 

...., 

. 

SWEDEN , 1 10 GWe• 

(50%) • : 

, - 

•

NO - • :9eactorsos.. Wet Pools' . „-1 Yr r ' 

. . „ . , . . > , 

,. • „' „ 

. , , . . 

•Indepr Facility r •Wet Pools' 15:-40 Yrs - • 

(blab; at Osker-• i , .„ , . act Osker - 

"Sham•Reor r , 

eSite)', ; ', r: ,i i; 

• „ • :Utilities, • • 

. .. ... — : • . 

Utilities 

(Thru.SKB) ... 

Little 'Apparent %; - 

LoCal OpPosi- 

•TiioniO CLAb' :.• 

:(1) ) .'.., 

SWITZER- '., 

'LAND ' ' ' ' ' 

:3 d\I'VW, 

(38%), ., 

. • • . 

Yes • 

(Fr,: : 

Uk) , ' 

•Reactor ; '” ' ; * ' r' 1 2i,Yra'.,7, l• ; 7 

: , r • ;,. ', : ', : ; '. ; , :: ; , 1 : : r .; : '' ; ; '; ; '. „ ., „ „ , 

Indep.;Facility; , . A ■ . SE;171LIAk-i-; ; ;440 Yet ;' ', r. ” 

Nyurenlingeny„ ,; r.: °, r Dry. Casks °•. 

1711_1,■%,•S, not , ' : . • , 

Under Fieprob:' .; : ., , ' . -, 1 : ' : " „ 

 • , „ ' : , .. , . ... 

;contract : ; i: ° 

Utilities 

-., „ .. . , , 

' 

":Utilitide, : '. ' • 

:(Th'il ZWl-' " ' ' 

`-• kherileger ; ',`, 

. • • .. : „ 

.GeSellt1-. — 

Local'OPPO• Si' 

Lion 

„ „ .. 

tion to•Stor-' • 

'abe'•FaCility: • 

addressed• •• 

„ . - . , 

Thidugh"PaY 2 , • : 

ments •to•Corn - - 

.inunity,.25 Yr. , 's : 

Limit Oh OPera-: : 

lion Subject .to; : . 

°Renegotiation ; 

:>2025., 

° 

.s., 

. 

'. UNITED 

. KINGDOM 

, (UK) " . 

1 ai GWe :, ; 

•(17%)" ° 

:YeS : ' 

" : — „ 

'Reactor Sitea ' Wet: ciio la • 41•Yr• ' 

,.`,. s : :; .: ; x. ;" ; : — 

I rideR-1 Facility, ; : -, F.=;-,Dry. Vault :; l; ; : •,' , Undecided : • 

For AGR Fuel • 

.(at:Hej.is6drii: ., ° , 

 :Reattdr•Site); : . 

ii ,,., • • ' " ' - ' 

'Reproc.•Plant• r ' •SF-Weti Pools; " 'Fan/ Yrs . 

 ...... • . 

iHLWL-Dry 50 Yrs r.' 

i Utilities l& 

;Utilities — 

(doint; ',°.` 

.Ye!'..Y.r.e..)% ' ' 

, • „ „ .. , .„ 

BNFL ;-• : •.• ' 

;Lodal Concern'; ,. 

AbourStorr 

'age' Facility • • 

Planned For r : . 

Heysham Reap, : ; , 

orrSitei ; - ° ' .• 

2030; , 

'No decision abbut tutu's reprocessing hai peen•MaOe ' ' „, 

. 'Transportable•storage casks are under developrnent•and are the favored •storage technology, : . 

•.'Exiting transportable: storage casks haVe:heeri selected for,the.itOrage facility. • • 

 Utilities are investigating transportable storage casks for buffdr:stoeage. . ., 

- '01ilitie§ may be•prk.4te ; government; or joint industry-igovernment 'entities. ., • • • • •,,,•: • • • •: • 

D-18 

70 3 2 I 7 3 
- Table- 62: 

Spent`Fuel Staragetriihe:United Statea 

REI"AO- INTERIM STORAGE, * INSTITUTIONAL PUBLIC REPOSGESS- RESPONSI- RESPONSE ITORY 

ING SITES METHODS ° TIME BILITY SCHEDULE 

Reactor Wet ools; ° 6 ry a g ; Undecided 

„ — 

Sites Modules 

Utilities Strong Opposition to Federal 

>2003 

Storage and 

MRS Siting 

Effort . 

 5 4d5 

1466I-EAR 

CAPACITY 

(% 

ELECTR 

GEN.) 

UNITED' 

STATES 

99 GWe 

(?0%),. 

D-19 
uating the technology for later use. (See Table Dl—Interim 

Storage/Methods.) 

9. In summary, the experience of these countries provides useful insights, but does not have any single clear 

message for U.S. spent fuel storage policy. The U.S. must 

make its decisions in a situation that is very different in a 

number of important aspects: in the absolute size (much 

larger) and relative importance (generally smaller) of its 

nuclear power program; in the regulatory, institutional, and 

political environment for nuclear power and waste management; in the pressures to develop a permanent repository 

and the related concerns that central storage facilities 

would delay that goal; and in the geographic characteristics 

(e.g. transportation distances, population densities, and the 

range of options available for siting storage and disposal 

facilities) that must be taken into account in waste management policy. 

10.0 SOURCES 

Principal Sources: This report summarizes information supplied to JK Research Associates by the MRS Review Commission, supplemented by telephone interviews with 

individuals associated with the nuclear power or waste 

management programs of each of the eight countries. 

10.1 Material supplied by MRS Review 

Commission 

There were two main sources of information provided 

by the Commission: 

a. The trip report on the Commission's visits to 

waste management facilities in France, West Germany, Sweden, and Switzerland, prepared by the 

Commission's executive director, Jane A. Axelrad: 

Trip Report—Visits to European Waste Management 

Facilities, October 17-28, 1988, Memorandum to the 

Monitored Retrievable Storage Review Commission, 

September 3, 1989. This memorandum is the principal 

source of information in the sections dealing with the 

four countries it describes. 

b. Briefing materials on waste management programs in the eight foreign countries provided by the 

U.S. Department of Energy (DOE) to the MRS Review Commission. Information about the four European countries visited by the Commission is contained 

in a MRS Review Commission Briefing Package for 

European Fact Finding Trip, dated October 1988. 

This will be referred to as Briefing Package in references. Information on Japan, Canada, Spain, and the 

United Kingdom was provided by the DOE separately 

on June 7, 1989. This material, referred to as Additional Information in references, is the principal 

source of information on the status of nuclear power 

and the related institutional structure contained in the 

sections dealing with the four countries it covers. 

10.2 Interviews 

The following individuals were the principal sources 

of additional information for this report. Dates of the interviews are shown; in some cases there were additional brief 

discussions. A draft of the section of the report dealing 

with each country was also reviewed by one or more of the 

individuals contacted concerning that country. 

Canada: Dr. William Hancox, AECL/WNRE, 

6/26/89. 

Dr. Colin Frost, Ontario Hydro, 6/26/89. 

France: Ms Cheryl A. Hutchison, NUMATEC/ 

COGEMA (Bethesda, MD office), 

6/29/89. 

Germany: Dr. Klaus Einfeld, DWK, 6/26/89. 

Japan: Dr. Toshiari Saegusa, Central Research 

Institute of the Electric Power Industry 

(CRIEPI), 6/29/89. 

Mr. Masami Katsuragawa, PNC (Japan), 

6/20/89, 6/22/89. 

Spain: Mr. Jose Gravalos, ENRESA, 6/26/89. 

Sweden: Mr. Torsten Eng, SKB, 6/21/89. 

Switzerland: Mr. Hans Issler, President, NAGRA, 

6/26/89. 

Mr. Charles McCombie, NAGRA, 

6/22/89. 

U.K. Mr. Thomas McInerney, Managing Director, U.K. Nirex, Ltd., 6/22/89. 

Dr. Peter Wilmer, Central Electricity 

Generating Board, 6/27/89. 

D-20 

7 0 2 2 1 7 
11.0 REFERENCES 

1.Information on nuclear power generation provided 

by Dr. Colin Frost of Ontario Hydro. Spent fuel projections 

assume a 40 year reactor life and an additional 4-unit station of the Darlington design. 

2. Information on the spent fuel storage research program provided by Dr. Colin Frost, Ontario Hydro. 

3. USDOE, Final Version Dry Cask Storage Study, 

DOE/RW-0220, Washington, D.C., February 1989, p. 1-75. 

4. Information provided by Cheryl Hutchison, NUMATEC/COGEMA. 

5. Information on the German nuclear power program 

provided by Dr. Klaus Einfeld, DWK. 

6. International Energy Associates Limited (IEAL), 

Regulatory Strategies for High-Level Radioactive Waste 

Management in Nine Countries, IEAL-R/87-93, Fairfax, 

Virginia, December 1987, p. 3-1. 

7. Interview with Dr. Klaus Einfeld, DWK. 

8. Interview with Dr. Klaus Einfeld, DWK. 

9. Karlsruhe Nuclear Research Center Ltd., Systems 

Study-Alternative Entsorgung, Final Report Executive 

Summary, KWA 2190/1, Karlsruhe, FRG, March 1985, 

p. 24. 

10.Ibid. 

11.Information on the status of storage facilities provided by Dr. Klaus Einfeld, DWK. 

12.USDOE, MRS Review Commission Briefing Package for European Fact Finding Trip, Washington, D.C., 

October 1988, p. GE.4. Referred to hereafter as Briefing 

Package. 

13.Interview with Dr. Klaus Einfeld, DWK. 

14.Information supplied by Dr. Toshiari Saegusa, 

CRIEPI. 

15.IEAL, Regulatory Strategies, p. 5-1. 

16.Ibid., p. 5-7. 

17.Information on status of Rokkashomura plant provided by Dr. Toshiari Saegusa, CRIEPI. 

18.USDOE, Additional Information provided to the 

Monitored Retrievable Storage Review Commission, 

Washington, D.C., June 7, 1989, p. JA.3. Referred to hereafter as Additional Information. 

19.Information on the storage technology research 

program supplied by Dr. Toshiari Saegusa, CRIEPI. 

20. IEAL, Regulatory Strategies, p. 5-3. 

21. U.S. Council for Energy Awareness (USCEA), 

USCEA 1988 International Reactor Survey, Washington, 

D.C., January 1, 1989. 

22. Ministerio de Industria y Energia, Segundo Plan 

General de Residuos Radioactivos, Madrid, Spain, January 

13, 1989, p. 14. 

23. Ibid., p. 17. 

24. Interview with Jose Gravalos, ENRESA. 

25. USCEA, 1988 Survey. 

26. USDOE, Briefing Package, p. SW.9. 

27. USDOE, Briefing Package, p. SW.6. 

28. The Stipulation Law and its consequences are discussed in IEAL, Regulatory Strategies, pp. 6-5-6-6: 

29. Information provided by Torsten Eng, SKB. 

30. Interview with Torsten Eng, SKB. 

31. Information supplied by Torsten Eng, SKB. 

32. Interview with Torsten Eng, SKB. 

33. USCEA, 1988 Survey. 

34. IEAL, Regulatory Strategies, p. 7-9. 

35. Interview with Hans Issler, NAGRA. 

36. Information on the storage decision obtained from 

interviews with Hans Issler and Charles McCombie, 

NAGRA. 

37. Information on the status of the Wuerenlingen site 

provided by Hans Issler and Charles McCombie, NAGRA. 

38. Information supplied by Dr. Peter Wilmer, CEGB. 

39. IEAL, Regulatory Strategies, p. 8-7. 

40. The controversy about the drilling program, and 

the subsequent shift in strategy, are discussed in IEAL, 

Regulatory Strategies, pp. 8-8-8-9. 

41. Information on AGR and PWR storage plans provided by Dr. Peter Wilmer, CEGB. 

D-21 
Appendix E 

Contractor Assistance 

Contractors performed specific tasks to augment the 

Commission's technical work. 

EBASCO Services, Inc. of New York, New York examined at-reactor storage needs and the costs, risks, and 

benefits of rod consolidation. The company provided estimates of at-reactor storage, evaluated storage capacity by 

individual facilities, compared differences between pressurized water reactor (PWR) and boiling water reactor 

(BWR) pool limitations, evaluated the impact of using various pick-up rules, and compared at-reactor storage needs 

under different interim storage configurations. 

Golder Associates, Inc. of Redmond, Washington provided the Commission with a cost simulation model, the 

Nuclear WAste Cost Data Base and SimUlation Model 

(WACUM), designed to estimate the costs of various interim storage strategies, in particular the Department of Energy's cost estimates. In addition, Golder quantified the 

safety and environmental impacts of alternative spent fuel 

management strategies, and analyzed non-cost factors involved in determining MRS need on a quantitative basis. 

ICF Technology Incorporated assessed the need for an 

MRS facility from a transportation perspective, using historical and technical analysis. The company designed the 

MRS Review Commission's Analysis of System Risk and 

Cost (MARC), which was used to evaluate the transportation and systems aspects of alternative spent fuel management strategies. ICF also reviewed, evaluated, and 

provided additional data to supplement the Golder study on 

Safety and Environmental Impacts for Alternative Spent 

Fuel Management Strategies. 

A list of the contractor reports submitted to the Commission follows. Copies of these reports may be obtained 

from the MRS Review Commission until December 31, 

1989. After December 31, 1989, copies of these reports 

will be on file at the Department of Energy in Washington, 

D.C., the Nuclear Waste Technical Review Board, Washington, D.C., the Alexander and Jean Heard Library, Vanderbilt University, Nashville, Tennessee 37235 and the 

College of Engineering Library, University of Texas at 

Austin, Austin, Texas 78712. 

List of Contractor Reports 

EBASCO Services, Inc. 

"Rod Consolidation Costs, Risks and Benefits," June 

1989, Two World Trade Center, New York, NY 

10048. 

"Spent Fuel Storage Need and At-Reactor Capability 

Study," June 1989, Two World Trade Center, New 

York, NY 10048. 

"Reactor Specific Spent Fuel Database and Storage Projection Model Documentation Report," June 1989, Two 

World Trade Center, New York, NY 10048. 

GOLDER Associates, Inc. 

"Cost Estimate for Interim Storage Facilities," October 

1989, by I. Miller, 4104 148th Avenue, NE, Redmond, Washington 98052. 

"Interim Spent Fuel Management Cost Data Base," 

Project No. 893-1032.120, June 1989, by 

W. Dershowitz, C. Breeds, W. Roberds and I. Miller, 

4104 148th Avenue, NE, Redmond, Washington 

98052. 

"Quantitative Evaluation of MRS Non-Cost Factors," 

Project No. 893-7028, June 1989, 1451 Harbor Bay 

Parkway, Suite 1000, Alameda, California 94501. 

"Safety and Environmental Impacts for Alternative Spent 

Fuel Management Options," July 1989, 1451 Harbor 

Bay Parkway, Suite 1000, Alameda, California 

94501. 

"ISFM Cost Estimate Data Base Application User's 

Guide—Version 1.1," Project No. 893.1032.110, 

June 1989, by M. Feuer, C. Breeds and W. Dershowitz, 4104 148th Avenue, NE, Redmond, Washington 98052. 

E-1 

7 0 2 ; 7 7 
"WACUM Versus DOE Systems Study Comparison," 

Project No. 893-1032.250, September 1989, 4104 

148th Avenue, NE, Redmond, Washington 98052. 

"WACUM: Nuclear Waste Cost Database and Simulator 

Model—User's Guide Version 1.13," Project No. 

893-1032.210, June 1989, by I. Miller and W. Fuget, 

4104 148th Avenue, NE, Redmond, Washington 

98052. 

"WACUM Version 1.10 Users Guide," Project No. 

893.1032.210, June 1989, 4104 148th Avenue, NE, 

Redmond, Washington 98052. 

ICF Technology Incorporated 

"Transportation Impacts of the Federal Waste Management 

System," October 1989, 9300 Lee Highway, Fairfax, 

Virginia 22031-1207. 

"Historical MRS Siting and Transportation Studies: A Review and Analysis," June 1989, 9300 Lee Highway, 

Fairfax, Virginia 22031-1207. 

"User Manual and Model Documentation: MARC (Model 

for Analysis of System Risk and Cost)," Version 1.0, 

July 1989, 9300 Lee Highway, Fairfax, Virginia 

22031-1207. 

Upon review of report prepared by Golder Associates, Inc., 

"Safety and Environmental Impacts for Alternative 

Spent Fuel Management Options," Letter Report 

from ICF Technology Incorporated, September 14, 

1989, by Steve Baker, 601 Williams Boulevard, 

Fourth Floor, Richland, Washington 99352-3258. 

E-2 

7 0 0 17 
Appendix F 

Chronology of the Monitored Retrievable Storage Concept 

Before 1970 

At the end of the 1950s, commercial nuclear reactors 

began to produce electricity and, as a byproduct, spent fuel. 

Cumulative orders for nuclear reactors totaled about 74 

million kilowatts just a decade later. 1 

The first International Scientific Conference on the 

Disposal of Radioactive Wastes was held in 1959. In the 

1960s, nuclear waste experiments were being conducted in 

Kansas salt mines but there was little urgency in establishing a disposal program. Commercial spent fuel was to be 

reprocessed, with its residual uranium and plutonium recycled as fuel. However, there were problems with commercial reprocessing. The first reprocessing facility began 

operating in 1966 in West Valley, New York, but was shut 

down in 1972 for expansion; it never reopened due to increased seismic design requirements. A plant in Morris, Illinois, received a construction permit in 1967 but did not 

operate because of design and technical problems. A third 

plant, in Barnwell, South Carolina, received a construction 

permit and was essentially complete in 1977 when commercial reprocessing was indefinitely suspended. 2 

In May 1969, low-level, plutonium-contaminated debris from a fire at the Atomic Energy Commission's (AEC) 

weapons component facility in Rocky Flats, Colorado, was 

sent to the National Reactor Test Station in Idaho for storage. When Idaho's governor and its two U.S. senators protested, AEC Chairman Glenn Seaborg agreed to move the 

waste by 1980. 

1970-1976 

In 1970, the AEC formalized its policy for dealing 

with commercial high-level waste: such waste at reprocessing plants must be converted to solid form within five years 

of its generation; the solidified waste must be transferred to 

a Federal repository within 10 years after the irradiated fuel 

is reprocessed. 3 

In that same year (1970), the AEC tentatively selected 

a full-scale repository site in the salt deposits near Lyons, 

Kansas, pending confirmation tests. By 1972, however, the 

AEC had abandoned the Lyons site because of problems 

with the geologic formation's integrity. Many mining boreholes at the site and an unexplained disappearance of a 

large volume of water flushed into a nearby mine were two 

problems. 4 

With no deep geologic location in sight, the AEC 

shifted emphasis to aboveground, engineered structures—

the first proposed monitored retrievable storage (MRS) facilities. 5The AEC staff was instructed in February 1972 to 

begin designing surface storage facilities at a defense installation in Hanford, Washington, "for high-level commercial wastes and low-level wastes from both commercial and 

AEC activities." 6In June 1972, the AEC revealed plans to 

develop a Retrievable Surface Storage Facility (RSSF), an 

array of mausolea or vaults where waste or spent fuel canisters would be stored.? The Joint Congressional Committee on Atomic Energy reported in 1972 that the radioactive 

waste management program "now includes the conceptual 

design of manmade surface facilities of an expected lifetime of several centuries, as well as research on burial in 

various geologic formations." 8The decision to choose the 

surface storage option "was a response to the dilemma of 

irretrievability" and seemed a "practical answer to a difficult political and technical problem." 9 

Beginning in 1972, the AEC worked on three basic 

approaches to an RSSF: (1) stainless steel canisters in water basins to get rid of heat, and for shielding; (2) canisters 

in concrete basins, and cooled by circulating air; and (3) a 

canister within a 2-inch thick container with the doubly 

contained waste in a 3-foot thick concrete cask, and cooled 

by circulating air. An energy official said such storage 

would be satisfactory for decades, even centuries." )In 

1973, AEC Chairman James Schlesinger said his agency's 

"near-term objective" was an engineered retrievable storage facility, although the "major effort" was a Federal repository "to be ready in the early 1980s." 11 

A year later, a new AEC chairman, Dr. Dixy Lee Ray, 

told the Congressional Joint Committee on Atomic Energy 

that a major waste management effort was "the engineering development of a facility to be ready in the early 1980s 

for the retrievable storage of solidified high-level waste 

from the commercial nuclear power industry. Our objective 

is to provide a surface facility based on proven technology 

where the waste can be safely stored until further treatment 

or disposal is available." She said evaluating geologic disposal was a separate objective.' 2 

F-1 
In September 1974, the AEC issued a draft environmental impact statement (EIS) on the civilian nuclear waste 

program, including the RSSF. 13The RSSF was being designed to store all commercial high-level waste generated 

through the year 2000; it could store wastes for "at least 

100 years." 14Other RSSF features were retrievability of 

waste, ability to receive and store waste canisters, and safety in operations. 

Two months later, the U.S. Environmental Protection 

Agency criticized AEC's draft EIS, saying the statement 

underemphasized the development of a repository. 15Some 

western governors and other individuals also criticized the 

AEC's draft EIS. 16 

The Energy Reorganization Act of 1974 reorganized 

the Nation's energy program on January 17, 1975. The act 

abolished the Atomic Energy Commission and created two 

agencies—the Nuclear Regulatory Commission (NRC) and 

the Energy Research and Development Administration 

(ERDA). 17ERDA, in its budget request for fiscal year 

1976, 18asked for funds for a Retrievable Surface Storage 

Facility at a site to be selected by July 1976, but withdrew 

that request and the environmental impact statement in 

April 1975. 19Thus, the first approach to monitored retrievable storage did not reach the site selection stage mainly 

because of concern that it could become a permanent storage facility, preventing or delaying development of a geologic repository. 

1977-1980 

Nuclear waste storage entered a new phase when, on 

April 7, 1977, President Jimmy Carter deferred indefinitely 

all reprocessing of spent fuel from civilian power reactors. 

This step was taken to reduce the likelihood that the plutonium would be diverted from reprocessing to nuclear 

weapons construction. 20 

This presidential decision directly affected how spent 

fuel from nuclear power reactors was handled. Utilities had 

planned to send spent fuel to commercial reprocessing 

plants and often had provided only enough storage capacity 

to keep spent fuel at reactors for a limited time. With reprocessing indefinitely suspended, nuclear utilities had to 

reconsider the adequacy of at-reactor storage, and national 

policymakers had to reexamine the alternatives for storage 

and disposal of spent fuel from nuclear reactors. 

With energy policy high on the public agenda, Congress created a Federal Department of Energy (DOE), 

which began operations on October 1, 1977. 21 

Seventeen days later, the Federal government proposed a modified version of the MRS approach—Federal 

away-from-reactor (AFR) storage of spent fuel. Under this 

proposal, the fuel owner would pay the Federal government 

for storage and disposal. DOE said that its acceptance and 

taking title to spent fuel from nuclear utilities would remove utility uncertainties about indefinite at-reactor storage of spent fue1. 22 

Because both interim and permanent spent fuel storage facilities were needed, the plan included a geologic repository that would permit retrieval of the spent fuel. One 

or more surface storage facilities would provide interim 

storage until the repository became available. 23 

DOE considered several alternatives over the next two 

years for this Federal away-from-reactor storage, including 

(a) building a 5,000-metric ton (MT) facility on a Federal 

site; (b) buying pools at three closed reprocessing plants; 

and (c) leasing storage space from the Tennessee Valley 

Authority. 24 

On March 15, 1978, President Carter set up an Interagency Review Group (IRG) on Nuclear Waste Management to recommend U.S. policy on nuclear waste 

disposa1. 25The IRG made its recommendations to the President in March 1979. While the report focused on permanent geologic disposal of nuclear waste, it recommended 

two interim measures: (1) AFR storage and (2) intermediate scale facilities (ISFs). 

The IRG reported that "interim storage of spent fuel is 

required during the period of time before disposal facilities 

are available." While utilities should keep spent fuel at reactors until a repository is available, the Federal government "should provide storage capacity as needed for 

limited quantities of spent fuel" at the utilities' expense. 27 

The report foresaw a maximum AFR capacity of 11,800 

metric tons of heavy metal (MTHM) of spent fuel unless 

the first repository was delayed past 1989, in which case 

more AFR capacity would be needed. 28 

The Interagency Review Group called for "a stepwise approach to the development of an HLW [high-level 

waste] repository" while maintaining adequate storage capacity. The ISF would add technical, engineering, and operational data and provide learning experience about the 

licensing and organizational processes involved in developing a repository. While not "an essential component" leading to a full-scale repository, the IRG said the ISF should 

be built if there were "an appropriate opportunity" to do so 

"significantly prior to" opening a permanent repository. 29 

ISFs "can play a distinct and desirable role" in the 

transition "from R&D [research and development] to fullscale operational disposal facilities," the report stated. An 

ISF could store as many as 1,000 spent fuel assemblies or 

waste canisters with the possibility, but not the expectation, 

of removal. The report recommended immediately starting 

to site one or more ISFs in different emplacement media 

and geologic environments. 30 

The ISF, while depicted as a smaller scale geologic facility, had some characteristics of the MRS facility later 

F-2 

7 0 `.4 
proposed by DOE. It was a forerunner of the full-scale repository, providing earlier storage for spent fuel; a part of 

the step-wise approach to developing a repository; an advance exercise of the repository licensing process; and an 

experience in siting and building such a facility before siting and constructing a repository. 

In February 1980, President Carter set forth a nuclear 

waste management policy, reflecting the IRG's recommendations. He emphasized the goal of permanent geologic 

disposal of nuclear waste; said nuclear spent fuel was the 

utilities' responsibility until the permanent Federal repository was built; and asked for authority to build or otherwise 

acquire away-from-reactor facilities for storing the spent 

fuel that utilities did not have room for at their reactor 

sites. 31 

Meanwhile, Congress began working on comprehensive nuclear waste management legislation. The Senate 

Energy and Natural Resources Committee bill (S. 2189), 

passed on July 30, 1980, authorized constructing monitored 

retrievable storage facilities to store wastes in aboveground 

vaults. The bill also included the administration's proposal 

to store utilities' excess spent fuel in AFR facilities; for this 

service, utilities would pay a one-time fee. 32 

The House, after months of hearings and negotiations 

among several committees, passed H.R. 8378 on December 

3, 1980. The measure (1) set a timetable for developing a 

licensed, permanent repository, with NRC to decide on one 

site by 1992; (2) did not approve Federal away-from-reactor storage of spent fuel; and (3) did not authorize an MRS 

facility. 33 

However, the House-Senate conference committee 

could not agree on the bills. The 96th Congress, therefore, 

came close to enacting legislation concerning high-level 

nuclear waste but, at the last minute, could not decide on 

the provisions. MRS was a major bone of contention between the two houses of Congress. 

1981-1982 

In 1981, DOE reviewed the status of the MRS concept 

and analyzed its impact on the nuclear waste management 

system. 34The study examined storage in dry wells, surface 

storage in concrete casks, and storage in air inside tunnels 

("tunnel racks"). Potential MRS roles examined were: 

long-term storage (for 100 years) to allow relatively shortlived isotopes to decay before being disposed of in a geologic repository; dry away-from-reactor storage until fuel is 

reprocessed using a few large centralized storage facilities; 

and permanent storage, replacing the deep geologic repository. Economic evaluations for an MRS facility were based 

on spent fuel capacity of 48,000 MTHM. The DOE study 

suggested that the public would react adversely to deferring 

permanent disposal. The study also indicated that it would 

be difficult to get the public to accept a specific MRS or repository site. 35 

DOE also designed demonstration facilities capable of 

handling up to 1,000 canisters of spent fuel and ten highlevel waste canisters—including two using open-field dry 

wells, one using a tunnel dry well, and one using a tunnel 

rack. DOE said it would take 9 to 11 years to complete a 

demonstration facility on a DOE site, including obtaining 

congressional authorization, meeting National Environmental Policy Act (NEPA) requirements, and obtaining an 

NRC license. 36The designs could be expanded into fullscale facilities. 

The same report said the Retrievable Surface Storage 

Facility was propoed in 1972 as the primary way to store 

high-level and transuranic vitrified waste resulting from reprocessing, allowing development of permanent disposal 

facilities on a longer term basis. Since the RSSF proposal 

was withdrawn in 1975, the report explained, ERDA and 

its successor agency, DOE, focused on developing permanent disposa1. 37 

The 97th Congress began legislative activity on this 

issue in February 1981 but did not enact the Nuclear Waste 

Policy Act until December 1982. Senate committee chairmanships had shifted to Republicans. There was a new 

president, Ronald Reagan, whose administration changed 

many of the policies pursued by the Carter administration. 

The new administration: 

• supported developing nuclear power; 

• favored permanently disposing of high-level radioactive waste in a geologic repository; 

• lifted the deferral of commercial reprocessing but 

offered no incentives to use reprocessing; no private 

reprocessing ventures were initiated; 

• withdrew the Carter administration's offer to provide Federal away-from-reactor storage facilities, 

giving utilities primary responsibility for storing 

spent fuel until reprocessing or disposal facilities 

were developed; 

• narrowed to three the number of repository sites to 

be examined before selecting one for licensing. 38 

In 1981, a number of bills were introduced in both 

houses of Congress but none reached the floor of either the 

House or Senate. 

In 1982, nuclear waste legislation followed the 1980 

pattern to a considerable extent: the Senate acted rather early in the year, the House passed a bill in December, and the 

House-Senate conferees worked into the week before 

Christmas to achieve an agreement. But in 1982, the conferees reached a compromise agreement on the Nuclear 

F-3 

7 0 2 
Waste Policy Act of 1982, which Congress enacted on December 20 and the President signed on January 7, 1983. 39 

Title I, Subtitle C of the act said, "long-term storage 

of high-level radioactive waste or spent nuclear fuel" in 

MRS facilities "is an option." The legislation did not authorize an MRS facility, but did instruct DOE to submit to 

Congress by June 1, 1985, a proposal for constructing one 

or more MRS facilities. For the first MRS, the proposal 

was to include at least three alternative sites and at least 

five alternative combinations of sites and facility designs. 

Preparing the proposal required an environmental assessment, not an environmental impact statement. An MRS, if 

authorized, would have required an NRC license. 

The act also directed DOE to enter into contracts with 

the generators and owners of spent fuel. The contracts provide that in exchange for a fee to be paid into a Nuclear 

Waste Fund, beginning not later than January 31, 1998, 

DOE would take title to the spent fuel and dispose of it in a 

geologic repository. 4° An MRS, if built, would be funded 

from the Nuclear Waste Fund. 

The act further directed DOE to provide not more than 

1,900 MT of storage for those utilities which could show 

that they could not reasonably provide adequate storage; 

this directive was intended to ensure the continued, orderly 

operation of the utilities' reactors. 4 ' The utilities were to 

pay for the storage,42and those needing it were to enter 

into contracts with DOE by January 1, 1990. 43Existing 

Federal sites or the sites of any civilian nuclear power reactors were candidates for storage. 

1983-1987 

Following enactment of the Nuclear Waste Policy Act, 

the issue of managing nuclear waste shifted from the legislative to the executive branch. DOE presented its initial 

MRS plans in April 1984, in a draft mission plan which the 

Nuclear Waste Policy Act required. Under this plan, an 

MRS would provide backup storage in case the availability 

of a permanent repository was delayed significantly. Once 

a repository was available, utilities would ship spent fuel 

directly to it for packaging and disposal. When the at-reactor spent fuel backlog was reduced sufficiently, the MRS 

would ship its spent fuel to the repository for packaging 

and disposal." 

However, a DOE reassessment concluded in 1985 that 

an MRS facility should be an integral part of an "improved-performance" waste management system. Under 

this revised approach, the MRS facility would: receive 

spent fuel directly from most, possibly all, reactors; consolidate and package the fuel, including overpacking with disposal containers for permanent disposal in a repository; and 

store the fuel temporarily before shipment to the 

repository. 45 

DOE's 1985 mission plan for the civilian radioactive 

waste management program said the MRS facility in this 

"integral" waste management system "does not have the 

same role" as the earlier concept of an MRS facility. 46Under the integral proposal, the MRS facility would be more 

than a storage operation; its main function would be preparing waste for emplacement in a repository. 

In April 1985, DOE issued a preliminary analysis of 

the need for and feasibility of an MRS facility 47and identified three sites in east and central Tennessee as the preferred and alternative locations for developing site-specific 

designs of MRS facilities. DOE's preferred location was at 

the Clinch River breeder reactor site, owned by the Tennessee Valley Authority (TVA) and adjacent to DOE's Oak 

Ridge reservation. Recommended alternatives were DOE's 

Oak Ridge reservation and TVA's cancelled Hartsville nuclear power plant site (northeast of Nashville). 48 

A proposal for the Tennessee MRS facility, including 

an environmental assessment and a program plan, was 

drafted in December 1985 to submit to Congress in early 

1986. However, the proposal could not be submitted as 

planned because Tennessee filed suit charging DOE with 

failing to consult properly with the State before proposing 

the MRS sites. The U.S. District Court for the Middle District of Tennessee, on February 6, 1986, ruled in favor of 

the State, and, on February 7, issued an injunction prohibiting DOE from submitting the MRS proposal to 

Congress. 49 

The U.S. Court of Appeals for the Sixth Circuit reversed the District Court's decision on November 25, 

1986.50Tennessee appealed to the U.S. Supreme Court 

which, on March 30, 1987, denied certiorari. The next day, 

DOE formally submitted its MRS proposal to Congress, 

recommending an MRS facility in Tennessee. 51 

1987-1989 

DOE issued an amendment to its mission plan—in 

draft on January 28, 1987, and in final form in June—that: 

• delayed the date on which nuclear waste could first 

be accepted at the repository from 1998 to 2003; 

• formalized the decision, announced in May 1986, to 

postpone site-specific activities for the second 

repository; 

• said the proposed integrated MRS would prepare 

spent fuel for emplacement in a repository, serve as 

a central receiving station, and act as a buffer for 

waste acceptance if the first repository were delayed; and 

• proposed that the MRS be limited to 15,000 metric 

tons uranium (MTU), and not receive spent fuel unF-4 

7 0 2 4 
til the NRC had authorized constructing the repository, to meet concerns that the MRS facility could 

become a substitute for a permanent repository. 52 

Thus, the integral MRS was a vital part of DOE's overall 

strategy for nuclear waste management. 

On March 31, 1987, Congress received DOE's proposal for an integral MRS facility to be built at the Clinch 

River site in Roane County, Tennessee, with interim storage limited to 15,000 MTU and with waste acceptance 

precluded until NRC authorized constructing the first repository. The proposal said the MRS would collect, process, and store wastes temporarily from eastern nuclear 

reactors, with spent fuel from western reactors normally 

being shipped directly to the repository. 53 

Meanwhile, congressional activity continued with 

many nuclear waste bills introduced in both houses in 

1987. Nuclear waste ended up as one of many national issues in the Omnibus Budget Reconciliation Act. On December 21, the House and Senate approved the conference 

report on the budget reconciliation act, completing congressional action on the Nuclear Waste Policy Amendments Act of 1987 (NWPAA). 54President Reagan signed 

the act on December 22, 1987. 55 

The 1987 amendments act reaffirmed the repository 

program as the primary focus of the Federal waste management effort. The act directed DOE to terminate all site-specific activities (other than reclamation) at all candidate 

repository sites other than Yucca Mountain. 56The NWPAA 

"annulled and revoked" DOE's proposal to locate an MRS 

in Tennessee. 57The amendments act created the Monitored 

Retrievable Storage Review Commission to prepare a report on whether a monitored retrievable storage facility is 

needed as part of a national nuclear waste management system that achieves the purposes of the Nuclear Waste Policy 

Act. 58Congress specifically directed the Commission to 

compare using a monitored retrievable storage facility to 

using at-reactor storage before disposing of spent fuel in a 

repository. 59Although the amendments authorized DOE to 

site, construct, and operate an MRS, the department was 

not authorized to survey or evaluate potentially suitable 

sites until the MRS Review Commission submitted its report.60Furthermore, the statute included certain conditions, 

to be incorporated in any MRS license the NRC issued, 

that closely link an MRS construction and operation to the 

repository schedule. 6 ' 

The Commission's report was due June 1, 1989 but, in 

1988, because of delays in appointing Commission members, Congress extended the due date to November 1, 

1989.62 

In May 1988, DOE initiated a series of system studies 

as part of updating its analysis of the MRS facility's role in 

the waste management system. DOE announced its revised 

policy position at a May 25, 1989 public briefing before 

the MRS Review Commission. DOE's preferred concept 

"is an integral MRS designed to allow development in 

stages." 63In the first stage, the MRS facility would receive, inspect, and store spent fuel until shipment to the 

repository. Packaging spent fuel—part of the "integral 

MRS" concept advanced by DOE in 1985—would be optional and "could be added at a later date," according to 

DOE.64 

The system studies "did not identify any significant 

benefit at present in consolidating or packaging spent fuel" 

at the MRS facility. 65DOE concluded that a "basic MRS" 

(one that receives, stores, and stages waste for shipment to 

the repository) located in the Eastern United States "provides the greatest benefits to the waste-management system" for early and adequate acceptance of spent fuel, 

schedule confidence, and increased system flexibility. 

These benefits, DOE said, would be greater if the "linkages" in the 1987 amendments act were eliminated or 

modified, but DOE still favored an MRS even with the 

linkages.66 

F-5 
Appendix F Notes 

1.Carter, Luther, Nuclear Imperatives and Public Trust, 

Washington, D.C.: Resources for the Future, 1987, p. 46. 

2. Office of Technology Assessment, U.S. Congress, Managing the Nation's Commercial High-Level Radioactive Waste, New 

York: UNIPUB, 1985 (Hereafter cited as OTA), p. 84. 

3. 10 CFR Part 50, Appendix E 

4. OTA, p. 85. 

5. OTA, p. 207. 

6. Hewlett, Richard G., Federal Policy for the Disposal of 

Highly Radioactive Wastes from Commercial Nuclear Power 

Plants, Washington, D.C.: Department of Energy, March 9, 1987, 

p. 21. 

7. Carter, p. 75. 

8. U.S. Congress, Joint Committee on Atomic Energy, Report on Authorizing Legislation for the Atomic Energy Commission for Fiscal Year 1973, JCAE report 92-1066, 92nd Cong., 2d. 

Sess., May 16, 1972, p. 11. 

9. Hewlett, p. 21. 

10.U.S. Congress, Hearings on ERDA Authorizing Legislation for Fiscal Year 1976 Before Subcomm. on Legislation, Joint 

Comm. on Atomic Energy, Part 2, 94th Cong., 1st Sess., Feb. 27, 

1975 (Hereafter cited as 1975 ERDA Hearings) pp. 1260-1261, 

1297. (Statement of Frank Pitman, Director, Division of Waste 

Management and Transportation, Energy, Research and Development Administration). 

11.U.S. Congress, Hearings on AEC Authorizing Legislation 

for Fiscal Year 1974 Before Joint Comm. on Atomic Energy, Part 

1, 93rd Cong., 1st Sess., Jan. 30, 1973, p. 44. (Statement by James 

Schlesinger, AEC Chairman.) 

12.U.S. Congress, Hearings on AEC Authorizing Legislation 

for Fiscal Year 1975 Before Joint Comm. on Atomic Energy, Part 

1, 93rd Cong., 2d. Sess., Feb. 19, 1974, p. 18. (Statement by Dixy 

Lee Ray, AEC Chairman.) 

13.Atomic Energy Commission, draft environmental 

statement, "Management of Commercial High-Level and 

Transuranium-Contaminated Radioactive Waste," WASH-1539, 

September 1974. 

14.Atlantic Richfield Hanford Co., "Retrievable Surface 

Storage Facility for Commercial High-Level Waste," ARHSA-175, April 1974, pp. 1-5. 

15.Environmental Protection Agency, "Environmental Impact Statement Comments on WASH-1539, the AEC Draft EIS 

for Management of Commercial High-Level and TransuraniumContaminated Radioactive Waste," D-AEC-A00107-00, November 21, 1974. 

16.OTA, p. 235. 

17.Energy Reorganization Act of 1974, 42 U.S.C. 5801 note. 

18. 1975 ERDA Hearings, pp. 1260-1261. 

19.Hewlett, pp. 32-33. 

20. Public Papers of the Presidents of the United States, 

Jimmy Carter, Book 1, April 7, 1977, pp. 582-583. 

21. DOE Organization Act, 42 U.S.C. 7101 et. seg. (1977). 

22. General Accounting Office, "Federal Facilities for Storing Spent Nuclear Fuel—Are They Needed?" GAO/EMD-79-82, 

June 27, 1979 (Hereafter cited as GAO/EMD-79-82), pp. i–ii. 

23. Carter, p. 134. 

24. GAO/EMD-79-82, p. 

25. Public Papers of the Presidents of the United States, 

Jimmy Carter, Book 1, March 15, 1978, p. 509. 

26. Interagency Review Group on Nuclear Waste Management, Report to the President, TID-29442, March 1979 (Hereafter cited as IRG Report). 

27. IRG Report, p. 62. 

28. IRG Report, pp. D-23 to D-25. 

29. IRG Report, pp. 55, 63. 

30. IRG Report, pp. 54, 55, 59. 

31. Public Papers of the Presidents of the United States, 

Jimmy Carter, Book 1, February 12, 1980, pp. 296-301. 

32. Congressional Record, July 30, 1980, pp. 20360-20367. 

33. Congressional Record, December 3, 1980, pp. 31925-

31946. 

34. Department of Energy, "The Monitored Retrievable Storage Concept," DOE/NE-0019, Dec., 1981 (Hereafter cited as 

DOE/NE-0019), p. vii. 

35. DOE/NE-0019, pp. vii–xv. 

36. DOE/NE-0019, pp. xv–xvi. 

37. DOE/NE-0019, p. xiv. 

38. OTA, p. 88. 

39. Public Law 97-425, 96 Stat. 2067, 42 U.S.C. § 10101 et 

seq. (January 7, 1983). 

40. 42 U.S.C. § 10222(a). 

41.42 U.S.C. § 10155. 

42. 42 U.S.C. §§ 10155(a) and 10156. 

43. 42 U.S.C. §§ 10155(a) and 10156. 

44. Department of Energy, "Mission Plan for the Civilian 

Radioactive Waste Management Program," Vol. 1, DOE/ 

RW-0005, June 1985 (Hereafter cited as DOE/RW-005), p. 72. 

45. DOE/RW-005, pp. 122, 126. (See also, Department of 

Energy, "Screening and Identification of Sites for a Proposed 

Monitored Retrievable Storage Facility," DOE/RW-0023, April 

1985, (Hereafter cited as DOE/RW-0023), p. 4.) 

46. DOE/RW-0123, p. 72. 

47. Department of Energy, "The Need for and Feasibility of 

Monitored Retrievable Storage—A Preliminary Analysis," DOE/ 

RW-0022, April 1985. 

48. DOE/RW-0023, pp. 1-3. 

49. Tennessee v. Herrington, 626 E Supp. 1345 (M.D. Tenn. 

1986). 

50. Tennessee v. Herrington, 806 F. 2d 642 (6th Cir. 1986), 

cert. denied, 480 U.S. 946 (March 30, 1987). 

51. Department of Energy, "OCRWM Mission Plan Amendment," DOE/RW-0128, June 1987 (Hereafter cited as DOE/ 

RW-0128), pp. 45-46. 

52. DOE/RW-0128, pp. 6, 11-14. 

53. Department of Energy, "Monitored Retrievable Storage 

Submission to Congress, Vol. 1, The Proposal," DOE/ 

RW-0035/1-Rev. 1, March 1987, pp. 1-6. 

54. Congressional Record, December 21, 1987, pp. S 18690, 

H 11991. 

55. Nuclear Waste Policy Amendments Act of 1987, Public 

Law 100-203, 101 Stat. 1330 (1987). 

56. 42 U.S.C. § 10172. 

57. 42 U.S.C. § 10162(a). 

58. 42 U.S.C. § 10163. 

F-6 

7 0 2 
59. 42 U.S.C. § 10163. 

60. 42 U.S.C. § 10162(b) and 10164. 

61. 42 U.S.C. § 10168(a). 

62. Public Law 100-507, 102 Stat. 2541 (1988). 

63. Isaacs, Thomas H., Associate Director, External Relations and Policy, Office of Civilian Radioactive Waste Management, Department of Energy, Transcript of MRS Review 

Commission Briefings, May 25, 1989 (Hereafter cited as Briefing Transcript), p. 11. 

64. Briefing Transcript, p. 12. 

65. Department of Energy, "MRS System Study Summary 

Report," DOE/RW-0235, June 1989 (Hereafter cited as Task J), 

p. iii. 

66. Task J, pp. iv—ix. 

F-7 
Appendix G 

Description of the Models 

This appendix contains a description of the two principal analytic models, MARC and WACUM, used in this report, the acceptance schedules used in cost estimates, and 

the method used to locate an MRS for modeling purposes. 

Section One: MARC Model 

A. MARC Model Overview 

MRS Review Commission's Analysis of System Risk 

and Cost (MARC) is a single-commodity, constrained-optimization model designed by ICF Technology Incorporated 

to aid the MRS Review Commission in comparing, in 

terms of risk and cost, alternative strategies for managing 

spent nuclear fuel. MARC is a modified version of a network optimization code originally developed by Battelle 

Memorial Institute called TRICAM (Transportation RIsk 

& Cost Analysis Model). In MARC, the scope has been 

expanded beyond TRICAM's focus on transportation to include the entire waste management system. The scope of 

the system modeled in MARC covers the generation of 

spent fuel at the Nation's commercial nuclear reactors, the 

temporary storage at these reactors (in the reactor pools 

and, where necessary due to pool storage capacity limits, in 

dry casks), storage and processing at MRS, transportation 

from the reactors and/or the MRS to the repository, and final packaging and burial of the spent fuel at the repository. 

MARC calculates the logistics solution (i.e., the schedules 

and quantities of spent fuel flows through user-defined 

storage and transportation systems from the reactors to final disposal at the repository), which minimizes the life-cycle system cost or risk or a linear combination of cost and 

risk. The computer routine within MARC which performs 

the actual optimization is NETFLO. NETFLO is documented in the literature.' 

B. The Spent Fuel Management System as 

Modeled in MARC 

The spent fuel management system is modeled in 

MARC using a primary network and a sub-network. The 

primary network comprises the three types of facilities in 

the system, i.e., the reactors at which the spent fuel is generated, up to three monitored retrievable storage facilities 

(commonly referred to as an MRS), and the final disposal 

facility (called the repository). The sub-networks model the 

various functions that can be performed at each such facility. This two-tiered network structure in MARC is described 

below. 

1. Primary Network 

Figure G.1 is a schematic representation of the primary network structure in MARC. It depicts, for a single year 

and for a single reactor, the various "paths" available to 

move the spent fuel from a reactor site to the repository, 

which is the permanent disposal site. Fuel discharged from 

reactors is placed in a storage pool for cooling. After it has 

been cooled sufficiently, it could be placed into dry casks 

stored at the reactor site. The transfer of spent fuel into the 

dry casks takes place in the pool. Under existing technology, the spent fuel is assumed to be transferred back into the 

pool for loading into a transport cask for shipment. Dry 

storage is part of the reactor sub-network. These components are included in illustrations of the primary network 

(Figures G.1 and G.2) to highlight the fact that dry storage 

is an integral part of MARC. 

Inventories in the reactor pools, in dry storage at reactors, at the MRS, and at the repository provide the year-toyear linkage in MARC. The combined spatial-temporal 

network in MARC is depicted schematically in Figure G.2. 

(Note that Figures G.1 and G.2 show networks for a single 

reactor; in MARC, similar networks are generated for every reactor in the system.) Clearly, there are innumerable 

"paths" through space and time, including a stop at an 

MRS, along which spent fuel from a reactor can reach its 

final destination at the repository. The number of paths can 

exceed several million for the complete network containing 

G-1 
eactor Pool 

Repositor 

igure G.1=-Schematic Representation of the Spatial Network in MARC 

MRS 

all the reactors. MARC searches for the set of paths that 

would involve the least risk or cost, or variations thereof, 

for accomplishing the transfer of the spent nuclear fuel to 

the repository. 

Arcs connecting the facilities represent the transportation alternatives available between them. For instance, two 

facilities between which both truck and rail service are 

available would be connected by two arcs, one for each 

mode. Transportation can occur between reactors (referred 

to as transshipment), from reactors to MRSs and repositories, and from the MRSs to the repository. The risks and 

costs of shipping a unit of waste along each arc are incorporated in MARC's objective function as the transportation 

coefficients. 

2. Sub-networks 

MARC models each facility through sub-networks, as 

shown in Figures G.3 through G.S. Nodes within such a facility sub-network are also connected by arcs, representing 

the functions that are to be performed at these facilities, 

such as storing, consolidating, packaging, receiving, and 

shipping. The unit risks and costs associated with these activities are incorporated into MARC's objective function as 

coefficients. 

a. Reactor Sub-network 

The sub-networks for reactors include three current 

year nodes (Figure G.3): a reactor pool node, the dry storage node, and the aggregate shipping node that includes 

both the pool and dry storage. In addition, there are two 

nodes that update the inventory of spent fuel from one year 

to the next. The flows of waste along the arcs connecting 

these nodes are described below. 

i. Reactor Pool Node 

Waste can enter the current year reactor pool node 

from four sources. Discharges from the reactor during the 

year enter the reactor pool on arc 1. (See Figure G.3.) The 

previous year's inventory is carried over to the current year 

reactor pool node along arc 2. Transshipments from other 

reactor pools during the year enter on arc 3. Waste removed 

from dry storage for shipment enters on arc 8. Data for the 

spent fuel discharges (arc 1) are obtained from the discharge projections compiled at the Pacific Northwest Laboratory and updated each year. 2 

Consolidation of spent fuel, and associated re-packaging, can be modeled for specific reactors. When consolidation and packaging functions are activated for a reactor, the 

unit costs and risks for these functions are imposed on arc 

1. The implicit assumption is that reactors consolidate 100 

percent of the spent fuel in their pools, if consolidation at 

that reactor is selected. Consolidation occurs before any 

choices need to be made, such as shipping the fuel off-site 

or placing it in dry storage; thus, the consolidation or the 

packaging functions at reactors are inputs and are not part 

of the optimization performed in MARC. 

Outflows from the current year reactor pool node can 

occur on three arcs. Waste can be transferred to dry storage 

casks at the reactor site (arc 4), it can be removed from the 

pool for shipment (arc 5), or it can be kept in inventory, 

i.e., transferred to next year's reactor pool (arc 6). Arc 6 is 

an example of the year-to-year linkage in the model. 

G-2 

7 0 2 [J 0 2 7 
Figure G.2—Schematic Representation of the Space-time Network in MARC 

Reactor Pool MRS 

ry Storage Repository 

G-3 
.Transhipments.to 

, other Reactors PoOls 3 

•Transhipments 

Frorh•Othei 

•'Reector Pools 

Note: All infarination is for ,current: 

year,Onleii stated otherwise.° 

;Next. Year 

Reactor'Pricil; 

Node' : ; 

igUee .3-Reactor. Sub=netitiotk 

',preyious",Yeer 

Dry Storage; 

Reactor. — 

Node;, 

2. Inventory From 7 

Previous Year 

Shipments to .; 

Repository ' ° 

10 --O. 

MventoriFroin .. 

Previous Year 

Shipments

19: MRS1:: " ' 

1 Discharges 

6 Mvehtory. 4 , Arkoehiciri. 

to Next Year !to Next,Year;',. 

ii. Dry Storage Node 

Waste is either placed in dry storage from the currentyear reactor pool node (arc 4) or it is brought forward as inventory from the previous year dry storage node (arc 7). 

Outflows from the current year dry storage node include removals for shipment (arc 8) and transfers to the next year 

dry storage node (arc 9). Arc 9 is another year-to-year linkage in the model. 

iii. Aggregate Shipping Node 

The aggregate shipping node serves to constrain the 

total quantity of waste shipped from a reactor in a given 

year to no more than the annual shipping capacity of that 

reactor. Inflows into the aggregate shipping node are the removals from the reactor pool. (This may include spent fuel 

transferred to a transportation cask from dry storage, arc 5.) 

Shipments from this node can go to the repository (arc 10), 

the MRS (arc 11), or another reactor pool (arc 3A). 

All reactors can ship by truck, but not all can ship by 

rail. Separate shipment arcs (not shown in the figure) are 

modeled for the modal option available at a reactor. For example, a reactor that can ship by truck and rail would be 

modeled with two shipment arcs each to the MRS and the 

repository. More than one cask type can be defined for a 

given mode, in which case additional arcs would be 

generated. 

b. MRS Nodes 

Figure G.4 is the sub-network for the MRS node. It 

comprises three current-year nodes: the receiving node, the 

storage node, and the shipping node. In addition, there is a 

node that updates the MRS inventory from one year to the 

next. 

Shipments from the various reactors enter the MRS 

receiving node either on arc 1 or on arc 1A, depending on 

the shipment mode. The waste is gathered and placed in 

storage (arc 2) along with the previous year inventory (arc 

3). Waste in the current-year storage node is either transferred to the shipping node for shipment to the repository 

(arc 4) or to the year storage node (arc 5). The MRS is assumed to ship to the repository by rail. However, if truck 

shipments are also to be considered, another shipment arc 

would be modeled. If consolidation and packaging at the 

MRS are selected, the unit costs for these activities are added to arc 2. 

G-4 

7 0 2 ! 
Truck Shipments 

F rom Reactors 

1 

Rail Shipments 

to Repository 

Figure GA—MRS Sub-network 

Previous Year 

MRS Storage 

Node 1 

3 I nventory From 

Previous Year 

1A 

Rail Shipments 

From Reactors 

5 Inventory 

to Next Year 

Note: All information is for current 

year unless stated otherwise. 

c. Repository Node 

The formulation of the repository is fairly straightforward, as depicted in Figure G.5. There is a receiving node 

for shipments received in the current year from the reactors 

(arcs 1 and 1A) and from the MRS (arc 2). This waste is 

added to the inventory from the previous year (arc 4) and 

carried forward to the next year inventory (arc 5). The unit 

costs and risks of disposal are incorporated on arc 3. If consolidation and packaging are selected, the unit costs and 

risks for these functions are also included on arc 3. Note 

that there are no outflows from this node because the repository is the final disposal site for the waste. 

C. Constraints 

MARC is a constrained optimization model. There are 

numerous types of constraints under which the optimization can be performed. All constraints in MARC are specified through MARC's interface module. (See the User 

Manual and Model Documentation 3for a detailed description of all the constraints that are modeled in MARC and 

how they can be changed.) In general terms, the constraints 

in MARC include capacity and throughput limits. Capacity 

constraints relate to the maximum quantities that can be 

stored at a particular facility, whereas both the minimum 

and maximum levels can be specified for throughput rates. 

Examples of capacity constraints include the maximum 

quantity of spent fuel that can be stored in the various reactor pools and the maximum inventory that is allowed to be 

held at an MRS. An example of a throughput constraint is 

the maximum quantity of spent fuel that is allowed to be 

received at the MRS annually. This annual total can be disaggregated by mode, if the quantities received by truck and 

rail are required to be controlled separately. Minimum 

throughput rates can also be set, to force a desired quantity 

of fuel to be shipped to that facility. Furthermore, the user 

can specify whether inventory is allowed at the reactors 

and/or the MRSs at the end of the optimization. If ending 

inventory is disallowed at a given facility, then all fuel will 

be shipped out of that facility. 

D. Objective Function 

The objective function of the model minimizes the total lifetime risks or costs associated with the flows described in the previous section, without violating any of the 

constraints. To include both risks and costs in the objective 

function, a composite variable is computed for every arc in 

the model. This variable, referred to as the objective function coefficient (z 1j1 ), is a weighted average of the unit 

costs and risks associated with waste flows on these arcs. 

The weights are the relative values assigned to risk and 

G-5 

7 0 4.• 

0 
4 , 

Truik Shipments From Reactors • . 

Newt, Year .! 

:RePOSitbijt::: 

StOrage4iOde- inforthation'isjor current 

yearAiniess stated otherwise.: 

igure Repoiltoili Su6-heti/Olt 

Previoui Year 

Repository: 

Storage:Node'. 

!If Inyentory:Frrn 

 Spent.Fuel Placed in 

;Repository. Storage; 

5. InveniOrli to 

, 14 e,lq V*: 

values for the material flows (x ut) which, taken together 

across all arcs and all years, minimize the value of the objective function (Equation 2). Note that the optimization 

occurs across the entire set of nodes and arcs over the life 

of the transportation program. This is not to say, however, 

that there will be activity on every arc in every solution; 

many xots will be zero. 

E. Total Risk and Cost 

The total risks and costs associated with the solution 

for any specified problem are calculated directly from the 

solution, as follows: 

R =~i~.~ ~t (rot• Xut) (3) 

C = (cut• Xut) (4) 

where, 

R = the total risks associated with a particular solution, for all arcs and all years, 

C = the total costs associated with a particular solution, for all arcs and all years, 

and 

xijt = the computed values of x o, associated 

with a particular solution. 

cost, and are user-specified for each run. Specifically: 

= a • rut+ 13 • cut (1) 

rut = 

cut = 

a = 

= the objective function coefficient associated with moving 1 MTU (metric ton 

uranium) of waste along arc ij (i.e., 

from node i to node j) in year t, 

the risk associated with moving 1 MTU 

of waste along arc ij in year t, 

the cost associated with moving 1 

MTU of waste along arc ij in year t, 

the relative weight assigned to risk, and 

= the relative weight assigned to cost. 

The objective function in the model is defined as: 

Minimize: Z =~;FjF,t (zut• xot) (2) 

where, 

zi t 

where, 

Z = the value of the objective function, and 

xut = the quantity of material flowing along 

arc ij in year t, measured in metric tons 

uranium (MTU). 

For any specified constraint set, the model computes 

G-6 

7 0 2 0 2 g I'd 
Section Two: Differences Between the Methodology/Data Used 

in this Study and in Previous Analyses 

Analyses prepared by DOE and the University of Tennessee have relied on simulation models to evaluate transportation impacts for different waste management cases. As 

described above, MARC is an optimization program, and 

its methodology is fundamentally different from simulation. Simulation models require the analyst to prespecify 

how the system will operate through a series of rules and 

how it will respond to changes in scenario/strategy sets. 

Simulation models do not have any tradeoff logic and as 

such cannot determine the "best" solution given a set of 

constraints. 

Constrained optimization, in contrast, seeks minimum 

cost or minimum risk solutions achievable for the specified 

scenario/strategy. MARC makes choices on the basis of total cost and risk that will be incurred over the life of the 

project and selects solutions that minimize these costs and 

risks. 

An example of the difference between simulation and 

optimization helps to illustrate this point. In previous studies, DOE used a simulation program that relied on a spent 

fuel pick-up sequence based on the oldest fuel first rule. 

This rule specifies the order in which fuel is to be shipped 

from each reactor regardless of pool capacity constraints, 

thereby introducing inefficiencies in the way the system is 

operated. Calculations of cost under this situation will be 

higher than necessary. Optimization, on the other hand, 

does not require prespecification of the pick-up sequence. 

The choice of which fuel to ship is based instead on the 

most effective way to reduce cost and risk. MARC, for example, will evaluate pool capacity, the cost of alternative 

storage options on-site, the cost of shipping, and other factors in order to decide the sequence for shipping fuel. 

Another example of the difference between these two 

methodologies occurs when an MRS is included in the 

waste management system. When DOE evaluated an eastern MRS, it specified that all of the reactors west of 100° 

longitude would ship directly to the western repository, and 

all reactors east of the line would first ship to the MRS. 

When these cases were run, reactors that were east of the 

dividing line but closer to the repository than the MRS ended up shipping all the way back east to the MRS, and then 

all the way west to the repository. MARC does not require 

the specification of such rules because shipping decisions 

are based on the lowest risk/cost strategy available. 

In addition to the methodological differences, there 

are also data differences. First, MARC assesses cost and radiological risk for the entire spent fuel management system 

rather than just spent fuel transportation. Radiological risks 

(routine and accident-related) associated with waste management activities modeled in MARC are presented in an 

ICF Technology Incorporated letter to the MRS Review 

Commission, September 14, 1989. That letter contains estimates of worker and public management activities, as well 

as the rationale for dose estimates. Costs associated with 

waste management activities were developed by Golder 

Associates, Inc., and used in MARC. 4 

Second, some of the transportation data used in this 

study differ from data used in previous studies. The most 

important are the radiological risk values. Radiological risk 

data used in this study were taken from "Development of 

RADTRAN-Based Unit Risk Factors for Use in TRICAM," (Battelle 1989). These data were developed using 

the most updated version of RADTRAN (Modified RADTRAN III) rather than the earlier versions of RADTRAN 

that were used by DOE and the State of Tennessee. 

DOE, in its most recent transportation system studies, 5 

used radiological risk data provided by Argonne National 

Laboratory. A comparison of the Argonne and modified 

RADTRAN III risk estimates is currently underway at Argonne National Laboratory. It appears that Argonne's risk 

estimates are lower for truck shipments and higher for rail 

shipments than the data provided by modified RADTRAN 

III. However, the precise difference will not be known until 

Argonne completes its comparative evaluation. 

The differences noted here between the methodology 

and data used in the present study and in the studies conducted prior to May 1989 are fully discussed in a review of 

these previous studies. 6 

Section Three: WACUM 

A. Introduction 

This section describes WACUM, the Nuclear WAste 

Cost Data Base and SimUlation Model. WACUM was developed by Golder Associates, Inc., under contract number 
T60355960 with the Monitored Retrievable Storage Review Commission. The purpose of the WACUM program is 

to provide cost estimates for the overall commercial interim spent nuclear fuel management system (ISFM) in the 

United States. WACUM does not address requirements for 

defense or commercial high-level waste. 

WACUM, which runs on MS-DOS (IBM-compatible) 

personal computers, is written in the Turbo Pascal programming language, Version 5.0. The main modules in 

WACUM are: 

• WACUM simulator: generation of a requirements 

file (see below) from a user-defined system strategy 

and operating scenario. 

• WACUM requirements editor: interactive entry/editing of annual processing requirements, which specify the quantities and types of processes which will 

occur in the system. 

• WACUM costing module: computation of the costs 

for an ISFM system to meet a set of requirements. 

• WACUM database editor: interactive entry and editing of cost accounts, which contain cost estimates 

for individual components of the spent fuel handling 

system. 

Figure G.6 shows the relationship between these modules. 

The WACUM simulator takes as input a user-defined 

"strategy" defining the configuration of the spent fuel system, along with a "scenario" defining the dates at which 

different facilities (MRSs and repositories) will operate and 

their processing capacities. Input data are defined interactively by the user, and may be saved as a "strategy file." 

When a simulation is conducted, the strategy and scenarios 

are combined with data from historical and projected discharges of spent fuel from reactors. The product of the simulation is a "requirements file," which lists all of the 

processes which were required in the simulation, along 

with the location where the process occurred and the annual quantities required. A typical simulation takes about one 

minute to compute. 

The requirements file is normally created by the 

WACUM simulator, but can be created using the requirements file editor if desired. The editor allows the user to 

look through the individual requirement records in the file 

and to modify, delete, or create new requirements. Individual requirement records can have their costs computed and 

displayed on the screen. 

The costing option in WACUM uses the cost data base 

to compute the costs associated with the simulation. The 

cost data base, is discussed below in Part B. 

The primary output of the costing option is two Lotus 

1-2-3 Version 2.0(r) compatible data files, containing summary and detailed cost data. (See Figure G.6.) Costs for 

each account and for the totals are presented as an expected 

value and a tenth and ninetieth percentile value. WACUM 

uses the Monte Carlo method to compute the statistical distributions of the cost totals. A typical costing run takes 

about one minute to perform. 

The database edit module allows the user to look 

through the cost account records and to modify, delete, or 

create new cost accounts. The cost data base is not normally modified by the user. The cost data base is described 

in "Interim Spent Fuel Management Cost Database Report," Dershowitz et al., June 1989. 

All of the costs in WACUM are expressed in thousands of constant 1989 dollars. No allowance is made for 

inflation. However, the Lotus-compatible files produced by 

WACUM do contain formulas which enable the user to 

readily calculate the discounted costs in 1989 dollars. 

B. Cost Data Base 

The WACUM Encoded Cost Data Base contains subjective, probabilistic assessments for the unit costs of each 

of the modular cost accounts. This information was derived 

at a week-long probability encoding workshop held at 

Golder Associates, Inc., offices, Redmond, Washington, 

April, 1989. All of the unit costs in the encoded data base 

are expressed probabilistically, generally in terms of the 

minimum, most likely, and maximum possible values. 

1. Design of Cost Accounts 

The goals for the development of cost accounts were 

that they should be: 

• comprehensive, 

• mutually exclusive, 

• modular, and 

• capable of containing all costs for at-reactor, IFS, 

MRS, and repository storage, including: 

— facility costs (development and evaluation 

(D&E), design, and construction), 

— operation and maintenance, 

— transportation, 

— support systems, 

— institutional payments to affected states, and 

— licensing and permitting. 

Several alternative cost account structures were considered, including systems based on the DOE cost account 

system utilized for the total system life-cycle cost analysis, 

systems based on physical components (such as hot cells), 

and systems based on functions (such as packaging). Due 

to the requirements of the WACUM code, the cost accounts 

G-8 

7 0 2 0 
were defined primarily in terms of function, although in 

some cases accounts were defined for major physical components required for a function. 

2. Cost Accounts 

Each cost account is defined by the function performed (e.g., consolidation, transportation, etc.), and the 

cost of providing that function is expressed in terms of 

fixed operating costs, variable operating costs, fixed (capital) costs, and development and evaluation costs. The total 

costs for the ISFM system, thus, consist of the requirements for the number of parameter units required of each 

function (e.g., MTU processed) times the parameter unit 

cost (e.g., $/MTU), summed over the various cost accounts. 

The functional requirements (i.e., number of parameter units required for each function) are specified separately, either directly by the user in a "requirements file" 

or by the WACUM simulator. Cost accounts can contain 

components (such as a crane) which serve more than one 

function; in most cases, however, such items are contained 

in an infrastructure account. 

Where possible, the cost accounts were defined in 

terms of unit costs (e.g., $/MTU, $/year, or $/item) in order 

to facilitate analysis of different strategies. 

Fixed Costs represent the total cost of acquisition for 

the component. D&E Costs, which are charged only once 

no matter what quantity of the component is required, 

represent design, engineering, testing and licensing costs. 

Fixed Operating Costs are the annual cost of keeping the 

component in service, including amortization of replacement costs for components with short operating lives. Variable Operating Costs are directly related to the quantity of 

spent fuel processed in a given year. 

Both fixed operating costs and variable operating 

costs are always paid in the year they are incurred. Fixed 

and D&E costs are paid according to defined schedules. 

Each schedule defines the base year for costing and the 

start and end years relative to the base year. As an example, the base year for fixed costs would be the startup date 

of the repository. Then, costs would accumulate starting six 

years before the repository start date and ending one year 

prior to the repository start date. The costs would be distributed uniformly over the six years. 

3. WACUM Simulator 

The simulator in WACUM tracks the movement of 

spent fuel on a year-by-year basis, from the originating 

pools to its eventual burial in a repository. The simulator is 

provided with the locations and capacities of all the pools, 

and with projected rates of discharge of spent fuel. It follows a series of rules, described below, to determine what 

happens each year from 1991 to 2050. The record of all of 

the operations that were required is then written to a requirements file, for subsequent costing. 

The simulator follows a set of rules which define what 

actions are taken at each stage of the simulation. These 

rules represent a significant simplification of what might be 

expected in the real world. However, within the constraints 

imposed by operating on a PC, it is felt that the simulation 

is reasonable. 

The simulator rules are as follows: 

• For each year, the simulator first ships from reactors 

and MRS to fill available repository space. It then 

ships from reactors to fill available MRS space. Finally, it stores new fuel discharged at the reactors. 

When appropriate, reracking of reactor pools or atreactor consolidation may be performed. Any excess 

fuel at the reactors is placed into dry storage. A fullcore reserve is maintained in the reactor pools at all 

times prior to shutdown. An option is provided 

which allows direct shipment of unconsolidated fuel 

from reactors to a repository when the MRS is full. 

This is significantly more economical than routing 

all fuel through the MRS. 

• The sequence in which spent fuel is selected for 

shipment from the reactors is as follows. The pickup rule selected by the user (oldest fuel first, oldest 

fuel first provided pool is reracked, or oldest fuel 

first provided pool is reracked and full) is used to 

identify which reactors should ship in the current 

year to fill the combined repository and MRS available capacities. An option is provided to prioritize 

fuel from shutdown reactor pools. All reactors in the 

selected list which ship directly to a repository then 

do so. The balance of repository capacity, if any, is 

then filled by shipping from MRS to repositories. 

Finally, the available MRS capacity is then filled 

from the reactors, using the pick-up rule. Note that 

fuel is never shipped unless it is at least five years 

old. 

• If there is insufficient qualified fuel according to the 

pick-up rule, the rule proceeds to the next lower level. Once all shipments have been processed, new 

discharges for the year are added to the reactor 

pools. If a pool is full (allowing a full-core reserve), 

dry storage is used. Requirements to rerack a pool or 

to consolidate fuel at a reactor pool are automatically triggered when the pool fills. (Consolidation 

only takes place if called for in the reactor strategy.) 

• Fuel shipped out of a facility generates requirements 

for embarkation, to change storage modes (via the 

pool, for a reactor) to the shipping cask, and for 

transport. 

G-9 

7 2 I 4 
the reactor. The maintenance cost is variable, depending on the number of pools at the site and how 

many reactors are shut down. 

• All reactor requirements are totalled in order to conserve memory space in the computer. As a result, all 

at-reactor cost accounts must have "unitized" costs, 

expressed per MTU. 

• Transportation requirements are expressed in terms 

of the number of casks shipped, the transportation 

mode, and the origin and destination regions. The 

cost module converts these requirements to miles 

and days, to compute the number of vehicles and 

casks required, and the mileage costs. 

• Dual-purpose casks received at a repository are not 

recycled. 

A more complete description of the WACUM model 

and the data base it uses are available in "Interim Spent 

Fuel Management Cost Data Base: Report to the Monitored 

Retrievable Storage Review Commission" 7and "WACUM: Nuclear Waste Cost Database and Simulation Model 

Users Guide Version 1.13: Report to the Monitored Retrievable Storage Review Commission." 8 

• Fuel received at a facility generates requirements for 

debarkation, handling, and storage-mode changes as 

specified by the design of the facility. Consolidation, 

if required, occurs only after the fuel is changed to 

"bare" storage mode in a hot cell. 

• Whenever fuel is changed to a new storage mode, 

the necessary number of casks are purchased (if not 

already available). 

• The reactor data file contains the current capacity of 

each pool and the maximum capacity if it was reracked. WACUM will rerack a pool when it becomes full provided that the reracked capacity will 

be at least 20 percent greater than the initial 

capacity. 

• At the reactors, consolidation of the fuel existing in 

the pool takes place if the consolidation option is selected and if the pool is reracked and full. Sufficient 

fuel is consolidated to create the required amount of 

spent fuel pool capacity. 

• At each reactor, if there is any fuel left five years after the shutdown date, it is transferred to a dummy 

storage mode for post-shutdown storage, and a requirement for storage is generated. This generates a 

"maintenance" cost as long as there is any fuel at 

Section Four: Assumptions and Acceptance Schedules 

Used in WACUM Simulations 

The assumptions and acceptance schedules used in the 

WACUM simulations generally follow those used by DOE 

in its system studies, but there were two significant exceptions. Rather than using the oldest fuel first pick-up rule, 

the WACUM base case simulations were made using a 

pick-up rule which assigned first priority to pools which 

were "full," i.e., any further storage would encroach on the 

reserve necessary to ensure the core of the reactor could be 

stored in the pool, and the pool had been fully reracked. 

Second priority was assigned to pools which were full but 

not fully reracked and third priority assigned according to 

the oldest fuel first principle. The oldest fuel first principle 

was also employed to assign priority within the group of 

pools which satisfied either the first or second criterion. 

The other exception to the DOE analysis involved 

cases where a linked MRS had reached the point that it 

could no longer accept fuel because of an inventory limit. 

In such instances, reactors were allowed to ship directly to 

the repository. This assumption reduced the handling and 

processing costs at the MRS. 

The acceptance schedule used for the repository and, 

where relevant, the MRS is shown below. For the cases in 

which the repository was assumed to begin operation in the 

year 2003 or the year 2013, ramp-up and acceptance rates 

identical to DOE's were used. However, a higher acceptance rate was used in the 2003 cases for that period of 

time after which the discharge of spent fuel from operating 

reactors and the withdrawal of spent fuel from at-reactor 

storage was not adequate to support the 3,000 MTU annual 

acceptance rate. For the cases in which the repository was 

delayed until the year 2023, higher acceptance rates were 

used because WACUM is limited to a 60-year modeling 

period. 

Acceptance schedules used for the cases in which the 

repository began operation in the year 2003 were: 

Repository: 2003 through 2005, 400 MTU/year; 2006, 

900 MTU; 2007, 1,800 MTU; 2008 through 2033, 

3,000 MTU/year; 2034 through 2045, 1,000 MTU/ 

year. 

G-10 

7 0 2 0 9 S 
MRS: 2000 and 2001, 1,200 MTU/year; 2002 and 

2003, 2,000 MTU/year; 2004, 2,700 MTU/year; 

2005 through 2028, 3,000 MTU/year; 2029 through 

2045, 1,000 MTU/year. 

Acceptance schedules for cases in which the repository began operation in the year 2013 were: 

Repository: 2013 through 2015, 400 MTU/year; 2016, 

900 MTU; 2017 1,800 MTU; 2018 through 2045, 

3,000 MTU/year. 

MRS: Unlinked MRS was the same as the schedule 

given above for the 2003 case. For the linked MRS 

the schedule was 2010 and 2011, 1,200 MTU/year; 

2012 and 2013, 2,000 MTU/year; 2014, 2,700 

MTU; 2015 through 2040, 3,000 MTU/year; 2040 

through 2045, 1,000 MTU/year. 

Acceptance schedules for cases in which the repository began operation in the year 2023 were: 

Repository: 2023 through 2025, 400 MTU/year; 2026, 

900 MTU; 2027, 1,800 MTU; 2028, 3,000 MTU; 

2029 through 2050, 3,820 MTU/year. 

MRS: Unlinked MRS was the same as the schedule 

given above for the 2003 cases except the acceptance period was extended from the year 2045 to 

the year 2050 at the rate of 1,000 MTU/year. For 

the linked MRS, the schedule was 2020 and 2021, 

1,200 MTU/year; 2022 and 2023, 2,000 MTU/year; 

2024, 2,700 MTU/year; 2025 through 2050, 3,120 

MTU/year. 

Section Five: MRS Location 

For modeling purposes, the MRS was located in the 

Eastern United States. To perform the risk and transportation analyses in this study, a hypothetical location for an 

MRS was postulated. To do this, an averaging method was 

used in which the country was divided into six regions, and 

the geometric centroid of each was identified. The risks 

from the two eastern-most centroids were averaged to form 

a composite location. This methodology follows the 

methodology used in the DOE transportation system studies.9A sensitivity analysis was performed to determine the 

effects of MRS location on risk. In the cost analysis, the 

MRS was assumed to be located at the centroid of the 

Southeastern region. 

G-11 

7 0 2 1 9 
Appendix G Notes 

1. Kennington, J.L., and Helgason, R.V., Algorithms for Network Programming, New York: John Wiley & Sons (1980). 

2. "Reactor-Specific Spent Fuel Discharge Projections: 1984 

to 2020," PNL-5396, Pacific Northwest Laboratory, Richland, 

Washington (1985). 

3. ICF Technology Incorporated, "MARC: User Manual and 

Model Documentation." (1989). 

4. Dershowitz, W., Breeds, C., Roberds, W. and Miller, I. 

"Interim Spent Fuel Management Cost Data Base," 893-

1032.120, June 20, 1989 (Hereafter cited as Dershowitz et al.). 

5. Office of Transportation Systems and Planning, Battelle 

Nuclear Systems Group, "MRS Systems Study, Task F: Transportation Impacts of a Monitored Retrievable Storage Facility," May 

1989 (Hereafter cited as Task F). 

6. ICF Technology Incorporated, "Historical MRS Siting and 

Transportation Studies: A Review and Analysis," June 1989. 

7. Dershowitz et al. 

8. Miller, I. and Fuget, W., "WACUM: Nuclear Waste Cost 

Database and Simulation Model User's Guide Version 1.13: Report to the Monitored Retrievable Storage Review Commission," 

Golder Associates, Inc., Seattle: 1989. 

9. Task F, pp. 16-20. 

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TABLE :171.1;_vARIATIoNso* gTH 

NOLNIFts:STAATEdy 

• Intrautility transshipment 

• 50yo atreacor,consolidation, 

• '100% rail transportation 

• 100% rail transportation (avoid population 

; dentart', ; 500, ()op people) ;‘ 

• Dual-purpose casks 

• Dual-purpose. casks +190%/ail transportation 

Appendix H 

Sensitivity Analyses 

The base cases evaluated in this report are discussed 

in Chapter Three. Variations on these base case strategies 

were evaluated in Chapters Four and Five of the report to 

determine the sensitivity of system risks and costs to modifications in the base case strategies. This appendix describes the variations evaluated. 

Section One: Health, Safety, and Environmental Impacts 

Sensitivity analyses were performed in Chapter Four 

for each of the base cases strategies. A 2013 repository 

start date was selected for the sensitivity analyses because 

it was considered at that time a more likely repository start 

date than 2003 or 2023. However, the purpose of the sensitivity analyses was to determine the sensitivity of risk estimates to changes in a single key parameter or groups of 

parameters, and either of the other repository start dates 

would have given similar results. 

A. Variations on the No-MRS Strategy 

The variations on the No-MRS strategy are summarized in Table H.1 and discussed below. 

1. Intrautility Transshipment Allowed 

Transshipment of spent fuel between reactors of the 

same type (e.g., PWRs) owned by the same utility is allowed as a means for providing additional spent fuel storage capacity, if needed at a reactor to maintain full-core 

reserve. 

2. Fifty Percent At-reactor Consolidation 

This variation assumes 50 percent of all spent fuel is 

consolidated at reactor sites. Only reactors that could obtain life-of-plant pool storage would be expected to use rod 

consolidation since it is unlikely utilities would adopt a 

strategy that would require two different techniques (rod 

consolidation and dry storage) for increasing spent fuel 

storage capacity. If these reactors consolidated all of their 

spent fuel, about 50 percent of all spent fuel would be consolidated at reactors. 

3. One Hundred Percent Rail Transportation 

The base case assumes 54 percent of reactors can ship 

by rail, the same assumption used by DOE in its system 

studies. This case assumes all reactors ship by rail (regardless of whether or not they presently have the capability to 

do so). The objective is to ascertain the maximum benefit 

that could be obtained by switching to rail shipment. This 

variation would bound the State of Tennessee's estimates. 

4. One Hundred Percent Rail Transportation (Avoid 

Population Centers >500,000 People) 

In this case, all shipments are routed so that there are 

H-1 

7 2 
no spent fuel shipments through population centers greater 

than 500,000 people. The purpose is to ascertain whether 

such routing will substantially affect public risk. 

5. Dual-purpose Casks 

A dual-purpose cask is used both to store and transport spent fuel. It can be reused after spent fuel is removed 

from the cask following transportation from the reactor to 

the repository or an MRS. The reuse may be for either storage or transport. The appeal of this concept lies in the potential to minimize handling of spent fuel. For this case, the 

analysis assumes dual-purpose casks are used to store and 

ship spent fuel. For this case and the next, the analysis assumes: (1) the dual-purpose cask will be licensed and available when needed; (2) even after prolonged storage, the 

dual-purpose cask would not have to be opened to be recertified for transport. 

6. Dual-purpose Casks Plus 100 Percent Rail 

Transportation 

In this case, the analysis assumes dual-purpose casks 

are used to store and ship spent fuel, and all spent fuel is 

shipped by rail. 

B. Variations on the MRS Strategies 

The variations on the MRS strategies are summarized 

in Table H.2 and discussed below. 

1. Intrautility Transshipment Allowed 

See explanation under variations on No-MRS strategy. 

2. Unlinked MRS Inventory Limits 

In the unlinked MRS base case, there were no inventory limits. In the sensitivity analysis, inventory limits of 

5,000, 15,000, and 30,000 MTU of spent fuel were used to 

determine the effects of varying inventory limits. 

TABLE ;VARIATIONS :ON,THE' 

Intrautilitjr:t~anssflipmenf allowed-' 

Alihked:MRS'iriVeritiory'limitsAltetnay\ie m9s:sepe:001inKaje: 

Unlinked mRs110Oated iefcential:U: S 

Consolidation attbe: plinked MRS:: 

3. Alternative MRS Schedule Linkage 

In the linked MRS (NWPAA) base case, the MRS 

schedule was linked to the repository schedule in accordance with the NWPAA. The practical effect of this linkage 

is that the MRS could begin operation no earlier than about 

three years before the repository. In this variation, it is assumed that the MRS can begin operation five years before 

the repository. This allows a determination of the effect of 

a relaxation in the schedule linkage. The capacity limits 

still hold. 

4. Unlinked MRS Located in Central U.S. 

In the linked and unlinked base cases, the MRS is assumed to be located in the Eastern United States. This case 

assumes an MRS facility at a hypothetical location in the 

Central United States. The effects of the transportation to 

and from hypothetical MRS facilities located in the northern and southern centroids in the central third of the country were calculated and then averaged. 

Section Two: Spent Fuel Transportation Safety 

All cases in Chapter Five were analyzed with the repository beginning operations in 2013. 

For the No-MRS strategy, the variations are the same 

as those listed in Table H.1 except that dual-purpose 

casks were analyzed with the use of 100 percent rail transport only. 

For the linked and unlinked MRS strategy, the variations are as listed in Table H.2 except that inventory limits 

and schedule linkages were restricted to fewer cases than in 

Chapter Four, and there was no consolidation at the MRS. 

H-2 

7 0 2 3 4 
Appendix I 

The Commission's Recommendations: Cost, Capacity, 

and Financing 

Section One: Costs 

The Commission's recommendations to create the 

Federal Emergency Storage (FES) and User-Funded Interim Storage (UFIS) facilities do not rest on the expectation 

that they would reduce the cost of the spent fuel management and disposal system. The FES is intended to provide 

resilience to the system by insuring that spent fuel can be 

removed expeditiously from a reactor pool in an emergency 

and to provide storage for reactors that would have to shut 

down because they were unable to build at-reactor dry storage facilities. The UFIS will provide an alternative to onsite dry storage for utilities that choose to use it, at their 

own expense. The UFIS may reduce the share of the total 

cost that comes from the Nuclear Waste Fund, but it is unlikely to reduce overall system cost. 

The annual Federal Interim Storage Fee Study' estimates the cost of storage facilities for a number of alternative types, sizes, and locations. In the 1988 report, the 

capital costs for a 1,900 MTU facility ranged from a low of 

$140 million for a facility located at a site where transfer 

facilities and hot cell facilities were already in existence 

and made use of a field drywell storage system to a high of 

$220 million for a facility located at a site without transfer 

or hot cell facilities using dry cask storage. 

The Commission also asked Golder Associates Inc., 

who developed the cost data base and simulation model described in Chapter Six, to provide some preliminary cost 

estimates. These estimates were based on the encoded cost 

data base described in Chapter Six, which explicitly incorporates uncertainty about the future escalation of such 

costs. Thus, they are higher than today's engineering estimates of what it would cost to build and operate such facilities. As emphasized in their report, these estimates were 

"very preliminary, order of magnitude only." 2Golder estimated that the capital cost of a 2,000 MTU capacity facility 

built at a site with existing hot cell and transfer facilities 

using dry casks for storage would be $330 million. The 

capital cost of the same facility built at a site without these 

facilities was estimated to be $370 million. 

For a 5,000 MTU facility using dry cask storage, 

Golder estimated the capital cost to be $530 million if built 

at a site with transfer facilities and hot cells and $570 million if built at a site without such facilities. 

Section Two: Capacity 

The recommended capacities of the FES and UFIS are 

not intended to provide for all storage needs over the life 

cycle of the national spent fuel management system. The 

Commission's objective is to provide a prudent degree of 

resiliency and redundancy in the system over the next 10 to 

15 years. The recommendations assume that, as outlined in 

Recommendation No. 3 in Chapter Nine, the Congress will 

reconsider the subject of interim storage by the year 2000; 

the recommendations also reflect the concerns that have 

been expressed about such facilities becoming a de facto 

repository. 

The FES facility's principal purpose is to provide a 

place for spent fuel should there be an emergency at a reactor, which would make it desirable to remove all of the fuel 

stored in the pool. As indicated in Chapter Nine, about 

1,000 MTU of capacity would be required to empty a large, 

full pool at an operating reactor and would always be reserved for that purpose. The remaining 1,000 MTU of capacity would be available for use by utilities that would 

have to shut down before the end of their designed operating life because they were unable to provide on-site dry 

storage if the UFIS were not available. 

Until the Facility Interface Capability Assessment 

(RCA) survey being conducted by DOE on reactor capabilities is completed, it will not be possible to ascertain 

how many, if any, reactors will be unable to accommodate 

I-1 
at their sites all of the spent fuel they will discharge. However, if neither a repository nor an MRS were available, in 

20 years about 13,900 MTU of dry storage capacity would 

be needed at reactor sites. Assuming that utilities plan at least five years ahead, provision has already 

been made for about 1,300 MTU of dry storage. Thus, even 

if as many as 10 percent of the reactors were to find it impossible to store additional discharges of spent fuel on-site, 

the provision of 1,000 MTU of capacity for this purpose 

seems reasonable and conservative over the 10- to 15-year 

planning horizon the Commission has used. 

Reserving 1,000 MTU for emergency purposes also 

appears to be a reasonable and conservative assumption. 

Emergencies at nuclear power plants that would require the 

reactor to shut down or a pool to be emptied are rare 

events. The frequency of rare events is difficult to predict. 

However, some calculations that provide rough estimates 

are available. The Reactor Safety Study, commonly referred 

to as WASH-1400 or the Rasmussen Report, which was 

published by the NRC in 1975, estimated that the probability of a serious accident involving a core meltdown, in 

the current generation of reactors, was 1/20,000 per reactor 

year. 3Assuming 100 reactors will be operating over the 

next 20 years, there would be 2,000 reactor years. Using 

the WASH-1400 probability estimate of a core meltdown 

as the probability of a serious accident would mean that the 

probability of a serious accident occurring during that time 

period would be equal to 2,000 x 1/20,000 or 10 percent. 

The risk estimates in WASH-1400 have been criticized from a number of perspectives. 4The Lewis Reports 

concluded that the estimates may be off by one order of 

magnitude in either direction, which would mean that over 

the time period in question, the probability of a serious accident would range from a low of 1 percent to a high of 

100 percent. In any event, the Commission believes the 

probability that a serious accident may occur is not negligible, thus, it would be prudent to maintain a capability to 

deal expeditiously with the possible need to remove the 

spent fuel from the pool. A reasonable estimate of the capacity required to accomplish this appears to be 1,000 

MTU. 

Section Three: Financing 

In its submission to the Congress of the MRS Program 

Plan, DOE presented a funding plan calling for the MRS to 

be financed through the Nuclear Waste Fund. It said it did 

not consider user funding for an MRS because: 

[A]n approach that imposes a surcharge on only 

the generators and owners of spent fuel that passes through the MRS facility would be inconsistent with the integral nature of the MRS facility. 

The decision of which fuel will pass through the 

MRS facility rests on overall system considerations and not on the preferences of individual 

utilities. Hence, this approach is not considered 

further. 6 

As DOE's proposed MRS has evolved from a comprehensive packaging, consolidation, storage, and logistical facility into a simpler "basic" facility providing only storage 

and logistics, this logic has become less persuasive, particularly if the facility is constrained by an inventory limit. 

As explained in Chapter Seven, the smaller the MRS, 

the more limited its services, and the fewer the number of 

utilities that make use of it, the weaker the case for general, 

industry-wide financing on both equity and economic efficiency grounds. Thus, the Commission recommends that its 

UFIS, a 5,000 MTU, optional, off-line, centralized interim 

storage facility, be user funded. 

There are two basic ways to design user-fee systems: a 

cost approach and an auction approach. 

The cost approach is illustrated in considerable detail 

in the annual Federal Interim Storage Fee studies, which 

have been prepared by E.R. Johnson Associates, Inc., for 

the Department of Energy since 1983. 7 

The cost approach is normally utilized when the demand for the facility is expected to be smaller than its potential capacity. In the case of an FIS, E.R. Johnson 

Associates has identified 13 utility sites as prospective FIS 

users. By 1995, they estimate, these sites will have a combined demand of only 1,286 MTU compared to an authorized FIS capacity of 1,900 MTU. Since none of the sites 

has applied to use the FIS and the report assumes an MRS 

will open in 1998 followed by a repository in 2003, the expectation that the demand for an FIS would be less than its 

authorized 1,900 MTU limit appears quite conservative. If 

the demand for the facility were expected to exceed its capacity, a lottery or some sort of "needs" criteria for making an administrative determination would have to 

be used to decide who would get the available capacity and 

who would not. 

The auction system is the second approach to designing a user-fee system. It is based on price rather than cost. 

It is best suited to a situation in which the demand for the 

1-2 

7 0 0 2 0 6 
facility is uncertain or is expected to be greater than the capacity of the facility. If there is more storage needed than 

the facility is able or permitted to provide, letting potential 

users bid for it helps insure that the use will go to those 

who "need" or value it most (in the sense that they are 

willing to pay the highest price to acquire it). 

Similarly, if it is not clear that there are enough interested users to justify building a facility, holding an auction 

provides a mechanism for ascertaining how much storage 

is desired and whether potential users are willing to pay 

enough to enable the government to provide the service. If 

the proceeds from the auction were not sufficient to cover 

the cost of building the facility, it simply would not be 

built. Subsequent auctions could be held, however, to ascertain if conditions or expectations had changed sufficiently to warrant building the facility. 

The design criterion underlying the cost approach is 

to insure that the fees cover all capital and operating costs 

of the facility. This is done with a two-fee system. As outlined in the annual FIS report prepared by E.R. Johnson 

Associates, an "initial" fee, paid when the contract is 

signed, covers all construction and licensing expenses expected to be incurred before the facility opens. Then a "final" fee is determined which covers: (1) transportation 

costs to the FIS, (2) estimated operating and decommissioning costs, and (3) an adjustment for any over or under 

estimates that may have been made in establishing the "initial" fee. The final fee is paid when the fuel is delivered to 

the FIS. Since the report assumes a repository will be available in 2003 and the fuel from the FIS will have to be 

transferred within three years as specified by the NWPA, 

there is little (assumed) uncertainty about how long the 

spent fuel will be stored at the facility. In the case of a 

UFIS, there might be considerably more uncertainty and, 

thus, it would probably be prudent to make the operating 

expenses an annual fee, payable as long as the fuel remained at the facility, rather than part of a "final" fee. 

Under the auction approach, an auction would be held 

at which prospective users would bid for the available storage capacity with the highest bidders winning the right to 

store spent fuel at the facility. In order to assure that the 

fees collected cover all costs of the facility, a variation of 

the two-fee system described in the cost approach above 

could be used. The initial fee would be set on the basis of 

bids received at auction and paid when construction was 

initiated. The final fee and annual operating charge would 

be set as described above so as to insure all costs were fully 

compensated. 

The principal problem in implementing this approach 

is the uncertainty as to the cost of licensing the facility. The 

financial risk associated with a commitment to license an 

inherently controversial nuclear facility of this sort may be 

too great to permit a two-fee, auction-implemented, userfunded mechanism to function. Further, potential users 

would need some assurance that a centralized facility 

would be available by a specific date, if they are to be able 

to efficiently compare the centralized storage alternative 

with at-reactor storage. Therefore, prior to the auction of 

storage rights, DOE, with the advice and assistance of 

NRC, should provide a realistic estimate of the licensing 

costs and a guarantee that licensing costs in excess of this 

amount would be paid for from contingency funds. 

Under a cost system, eligibility criteria would probably be needed to insure: (1) the demand for storage could 

be anticipated with enough certainty to make a reasonable 

estimate of costs, and (2) the demand for the facility would 

not exceed the desired capacity limit. 

If the auction system were used, it would be important 

to make the auction as competitive as possible. Effective 

competition usually requires a large enough number of bidders to make collusion among them difficult to arrange or 

enforce. In the case of utilities, the number of potential bidders is probably large enough, at least for storage in the late 

1990's and beyond.8Under either a cost or an auction 

system, efficiency would be enhanced if the rights (or contracts) to store spent fuel could be bought and sold. This 

would allow all utilities to compare the cost of on-site storage options with the cost of centralized storage and make 

adjustments if warranted. It would also encourage utilities 

to bid in an auction system since they could sell rights at a 

later date if their need for storage were to change or if an 

increase in the price of the rights were to make it more advantageous to sell rather than use them. 

1-3 
Appendix I Notes 

1.E.R. Johnson Associates, Inc., for Pacific Northwest Laboratory, "1988 Federal Interim Storage Fee Study: A Technical and 

Economic Analysis," PNL-6727/UC-85, November 1988 (Hereafter cited as FIS Study/PNL-6727), p. 4-4. Costs rounded in 

text. 

2. Golder Associates Inc., "Interim Storage Facility Cost Estimates," October 2, 1989. Costs rounded in text. 

3. Nuclear Regulatory Commission, "The Reactor Safety 

Study: An Assessment of Accident Risks in U.S. Commercial Nuclear Power Plants," (Rasmussen Report) WASH-1400, 

NUREG-75/014, October 1975. 

4. See Nuclear Energy Policy Study Group, Nuclear Power 

Issues and Choices, Cambridge, Massachusetts: Ballinger Publishing Company, 1977, pp. 221-233, and Wood, William C., Nuclear Safety Risks and Regulation, Washington, D.C.: American 

Enterprise Institute, 1983, pp. 41-43, for a discussion of the 

WASH-1400 estimates. 

5. H.W. Lewis et al., "Risk Assessment Review Group: Report to the U.S. Nuclear Regulatory Commission," NUREG/ 

CR-0400, September 1978. 

6. Department of Energy, "Monitored Retrievable Storage 

Submission to Congress," DOE/RW-0035/1, Rev. 1, March 1987, 

Vol. III, pp. 5.1-5.3. 

7. FIS Study, PNL-6727, November 1988, and previous 

years. 

8. The number of sites projected to require dry storage if an 

MRS or a repository is not available increases from 12 in 1995, to 

32 in 2000, to 44 in 2005. 

1-4 

7 
Appendix J 

Managing Spent Fuel Transportation Risks 

This appendix describes the risk management and regulatory rationale for, and the historical safety performance of, 

spent fuel transportation. 

Section One: Risk Management and 

Regulatory Rationale 

Two Federal agencies—the Department of Transportation (DOT) and the Nuclear Regulatory Commission 

(NRC)—have authority to regulate radioactive waste transportation. DOT, under the Hazardous Materials Transportation Act, has the authority to establish standards for safety 

aspects of the transport of all hazardous materials in interstate and foreign commerce, including spent fuel.' DOT sets 

standards for routing, vehicle safety, and driver qualifications and sets standards and specifications for packaging of 

radioactive materials. NRC has authority under the Atomic 

Energy Act of 1954 to regulate the receipt, possession, use, 

and transfer of radioactive materials. 2NRC establishes performance standards for transportation packaging for highly 

radioactive materials, certifies casks, establishes safeguards 

requirements to prevent sabotage of shipments, and approves shipment routes. To avoid duplicate or conflicting 

regulation, DOT and NRC agreed in an interagency 

Memorandum of Understanding that DOT would defer to 

NRC on setting standards for shipping casks for spent fuel 

and other high-level radioactive materials and would incorporate NRC standards into its transportation regulations. 3 

The Department of Energy (DOE) manages the spent 

fuel disposal program and will be responsible for transporting spent fuel to a repository and/or MRS when one is 

available. Part of that responsibility includes providing assistance to State and local governments in preparing for 

transportation emergencies involving spent fuel. 

States and some local jurisdictions regulate and inspect hazardous material transportation to varying degrees. 

In particular, State and local governments are responsible 

for responding to accidents and other transport 

emergencies. 

Jurisdictions may overlap and regulations conflict. 

However, whoever is responsible for regulating or managing the transportation of any hazardous material, including 

spent fuel, must consider four elements: 

Hazard identification; 

Hazard containment; 

Operational controls to reduce risk; and 

Emergency response in case of an accident. 

A. Hazard Identification 

The specific hazard of spent fuel, radioactivity, is easily identified. Spent fuel emits ionizing radiation, which 

can harm living tissue, causing delayed effects, such as 

cancer, or, at very high exposures, immediate death. When 

first removed from a reactor core, spent fuel is also thermally very hot. Spent fuel is also heavy. Its weight, combined with that of the material necessary to shield it, 

increases the difficulties of handling and transporting it. 

B. Hazard Containment: The Transportation 

Cask 

Before being transported, radioactive material is 

placed in transport casks. These casks are the primary device relied upon to prevent routine or accidental release of 

radiation. They are massive cylindrical structures, weighing 

from 20 to 100 tons, designed to be sufficiently dense and 

thick to shield the radiation and strong enough structurally 

to survive an accident without releasing radioactivity. The 

casks are made of two 1- to 2-inch thick concentric stainless steel shells, between which is yet another layer of 

heavy metal, such as lead or depleted uranium, to provide 

shielding. (See Figure J.1.) 

J-1 
7 0 2 3 0 2 2 1 0 

Figure J.1-100 Ton Combined Transport Cask 

Rail/Barge 

FUEL ASSEMBLY 

(26 PWR 52 BWR CAPACITY) 

IMPACT LIMITER 

DEPLETED URANIUM 

GAMMA SHIELD 

SOLID NEUTRON SHIELD 

(WITH 24 COPPER STAINLESS STEEL FINS) 

STAINLESS STEEL 

OUTER SKIN 

WEDGE-LOC " 

CLOSURE MECHANISM 

SPACER 

IMPACT LIMITER 

ROTATION TRUNNION 

REMOVABLE FUEL BASKET 

(PWR SHOWN) 

HY-85 

INNER SHELL 

HY-85 

OUTER SHELL 

LIFTING TRUNNION 

SOURCE: NUCLEAR ASSURANCE CORPORATION 

J-2 
1. Regulation of Casks 

a. Accident Protection 

Regulatory standards concerning accident protection 

for spent fuel shipping casks prescribe specific engineering 

test conditions for shipping casks. 4The specified test conditions include free fall, puncture, fire, and water immersion. These test conditions are designed to be engineering 

representations of the mechanical, thermal, and hydrostatic 

forces that may be encountered in severe transportation accidents. The specified conditions are more severe than 

those encountered in the vast majority of accidents. For example, the most likely kind of fire in an accident would be 

a pool fire in which the cask would be heated principally 

from one side, allowing some of the fire's heat to be dissipated into the air. The fire test standard requires the cask to 

be placed in an all-engulfing fire totally enveloping the 

cask so that no heat can be dissipated into the air. Although 

not impossible, this situation is unlikely to arise in a transportation accident. 

According to the regulations, the tests may be performed by computer analysis, 5scale model testing, fullscale testing, or a combination of all three. 6These accident 

protection standards are in accord with those of the International Atomic Energy Agency, which are applied worldwide. A study sponsored by the Nuclear Regulatory 

Commission (commonly referred to as the "Modal 

Study")7concludes that 99.4 percent of transportation accidents that could involve a spent fuel cask would result in 

no release or releases so small that they would be below 

NRC regulatory standards and thus would pose no significant risk. Accidents with more severe consequences are 

conceivable, but they occur with decreasing probability. 

b. Emissions Under Normal Conditions 

Regulations for spent fuel shipping casks specify permissible levels for external radiation. (These standards apply to all radioactive material transport packages.) 8 

External radiation may not exceed 200 millirem per hour 

anywhere on the surface of the package. The transport index—the maximum radiation level, in millirem per hour 

measured one meter from the package—should not exceed 

ten.9Compliance with these external radiation limits is required regardless of how much radioactive material the 

cask carries. 

Therefore, the more radioactive material the cask carries, the smaller is the allowed external dose permitted per 

unit of material shipped. That is, if a certain amount of 

spent fuel is put in one big cask, as opposed to, say, five 

small casks, the total external dose permitted by regulation 

would be five times smaller than if that same spent fuel 

were put into the five small casks. This logic—that using 

fewer bigger casks would, under current regulation, result 

in less allowed total radiation than using smaller casks—

suggests two things: (1) Trains can carry much bigger 

casks than trucks, because a freight car can carry a much 

heavier load than a truck. Thus, trains may serve better 

than trucks to reduce the amount of radiation emitted during normal transportation. (However, trains have associated 

with them much higher, non-radiological traffic fatality 

rates than trucks, and the non-radiological transportation 

risks dominate.) (2) Using the largest possible casks on 

trucks may serve to reduce the dosage during truck transport. However, State regulation may make the widespread 

and routine use of overweight trucks infeasible. 

A truck weighing more than 80,000 lbs., including 

payload, must obtain a permit from each State in which it 

operates. Also, as a condition for issuing the permit for 

overweight trucks, a State may impose allowable axle 

weight, time-of-day, and other restrictions. In addition, 

some local governments and toll authorities may establish 

standards that are more stringent than the States'. Complying with these restrictions may be difficult, or even infeasible, since some of them may conflict with one another. At 

this time, there is no way of gauging whether or how many 

States will issue overweight truck permits for the duration 

of the waste disposal program or what restrictions will be 

imposed from State to State. 

C. Operational Controls 

Although the transportation cask itself is the principal 

line of defense against accidental releases of radioactivity 

into the environment, other measures could reduce the risk 

of accidents and the magnitude of potential consequences 

should a release occur. These measures include operational 

controls, such as (1) routing, (2) inspection and enforcement, (3) driver and other vehicle operator qualifications 

and training, and (4) mode choice. 

1. Routing 

a. Criteria 

Routes can be chosen to enhance safety, using the 

same routing considerations that apply to transportation of 

hazardous materials in general. A route may be chosen for 

its quality and low accident record; to avoid population 

centers in order to reduce the magnitude of the potential 

consequences should a release occur; or for the emergency 

response capabilities along the route. For radioactive materials, the total travel time is also a factor since it affects the 

total amount of radiation received, especially by the crew. 

These routing criteria often conflict. For example, 

avoiding population centers usually means increasing travel 

distance and time, which increases the radiation exposure 

J-3 
to the crew and may increase exposure to the public and increase traffic fatalities. Avoiding population centers may 

also mean traveling on lower quality roads or tracks. This 

is especially the case with rail transport since the railroad 

routes with the higher quality tracks are usually the ones 

which connect centers of economic activity and population 

concentration. 

b. Regulations 

DOT, which has the authority to set routing standards, 

has done so only for trucks, not for trains, and only for 

highly radioactive materials, including spent fue1. 10Except 

for local pick-up and delivery and unforeseen emergencies, 

motor carriers are to transport the spent fuel on a system of 

"preferred routes." These are to consist of the Interstate 

Highway System and alternate routes designated by States 

in lieu of, or in addition to, the Interstates. The alternative 

route selection process requires a comparative risk analysis 

of the routes being examined and requires consultation 

with affected jurisdictions." In addition to this system of 

routes, the carrier is required to use the Interstate bypass or 

beltway around a city whenever one exists. Once on the 

prescribed system, the only allowed criterion for route 

choice within the system is reduction of transit time. 

Many States, especially in the West, are urging the 

Department of Energy to begin selecting highway routes 

well in advance of the disposal program's shipments. 12 

Early knowledge of routes would permit States along the 

routes to begin contingency planning and preparations for 

responding to emergencies. 

2. Inspection and Enforcement 

The responsibility for inspection and enforcement is 

shared among Federal regulatory agencies and the States. 

Different enforcement officials inspect shipments for one 

or both of two purposes: traffic safety and safety from the 

specific hazards of spent fuel. 

Both the Federal Highway Administration (FHWA) 

and the Federal Railroad Administration (FRA) of the DOT 

have inspection programs to determine compliance with 

general requirements covering their respective regulated 

carriers. These cover facets of carrier operations, such as 

vehicle brakes, track condition, and hours of service for 

truck drivers. 

There is no Federal highway inspection program specifically directed to spent fuel shipments, but State highway patrols do carry out routine inspections to assure that 

trucks meet Federal requirements for highway transport. 

On the other hand, it has been the FRA's practice in recent 

years to make inspections specifically directed to rail transportation of spent fuel. The track along the entire route is 

inspected at the beginning of each shipping program (or 

campaign), and re-inspected at six-month intervals. The 

rolling stock—the locomotive, cask cars, buffer cars, and 

caboose—is inspected before each shipment. 

NRC's practice has been to inspect for compliance at 

the licensee facility at the beginning of each major campaign. Once the series of shipments is underway, NRC 

does not routinely inspect every shipment. 

3. Driver Qualifications and Training 

Federal requirements for driver qualifications for 

highway freight carriage in general also apply specifically 

to radioactive materials carriage. Requirements for general 

motor freight carriage include commercial license standards, driver qualifications, and driving-under-the-influence 

of alcohol thresholds." In addition, before qualifying for 

transporting spent fuel, drivers must have had training on 

the regulatory requirements for radioactive material transport, the nature of the hazard, and emergency procedures." 

There are no analogous, radioactive material-specific training requirements for train crews. 

4. Mode Choice 

Choosing whether to use trucks or trains may be considered another operational safety measure, but the choice 

to reduce hazard is not always obvious, because while shipping by train may reduce total normal transport dose, it 

may incur higher traffic fatalities. 

D. Emergency Preparedness 

If a release does occur, effective emergency response 

can mitigate the consequences of an accident. Since a 

transportation accident can occur anywhere, preparedness 

is an issue of high concern to State, Tribal, and local officials, especially those in regions in the potential pathways 

of repository program shipments. This concern is heightened in the West where some States lie in a corridor of 

shipments from the East to the proposed repository in 

Nevada. 

Some State and local governments and Indian Tribes 

believe they are ill-prepared to respond to a spent fuel 

transportation accident and cannot afford to develop a capability. These concerns were often expressed at the Commission's public hearings. 15Some States want DOE to 

designate, well in advance, routes to be used in the waste 

disposal program so they can begin the preparatory planning process to develop an emergency response capability. 

Some States, such as Illinois and Colorado, have passed 

laws that exact fees for shipments of spent fuel through or 

within their States to pay for radiological safety programs. 

DOE provides some technical and financial emergency preparedness assistance to States. Section 180(c) of the 

J-4 

7 0 t 0 
Nuclear Waste Policy Act (NWPA),' 6as amended, requires 

DOE to provide technical and financial assistance for training purposes to States through which the spent fuel shipments will pass. In the Waste Isolation Pilot Plant program, 

the DOE repository program for defense transuranic waste, 

DOE has provided emergency response training assistance 

to five corridor States affected by the anticipated 

shipments.' 7 

Apart from DOE, which is directly involved as the 

manager of the spent fuel disposal program, the customary 

Federal role has been one of coordination and technical and 

financial assistance. The lead Federal agency for this function is the Federal Emergency Management Agency 

(FEMA), whose responsibility includes response to emergencies of all kinds. FEMA has developed a guide for State 

and local planning for emergency response to radiological 

transportation accidents. 18Otherwise, spent fuel transportation accidents are generally addressed only as a part of 

broader programs of training and financial assistance. 

Section Two: Spent Fuel Transportation Safety Performance 

Spent fuel has been shipped routinely for some time: 

in the past 30 years approximately 6,500 spent fuel assemblies have been shipped in the United States. 19From 1982 

through 1988, according to a Department of Transportation 

data base, there have been about 1,000 spent fuel shipments. 20The volume of spent fuel traffic is extremely 

small compared to the more than one billion tons of hazardous materials of all kinds transported annually. The 

number of spent fuel shipments will remain small even 

when the routine shipments from reactors begin. These 

shipments should number no more than 1,000 per year. 

Federal government programs have been responsible 

for a major share of recent spent fuel transport. 2 ' These activities included shipments of spent fuel from certain utilities to government facilities for the civilian spent fuel 

disposal programs demonstration projects such as rod consolidation; the court-ordered return of spent fuel from the 

West Valley, New York, reprocessing plant to the original 

utilities; and the transport of Three Mile Island debris to 

Idaho. Activities in the private sector have included intrautility shipments, such as those between Duke Power Company's Oconee and McGuire plants, and shipments from 

some reactors, such as Monticello, to the General Electric 

storage facility at Morris, Illinois. 

The safety performance of spent fuel transportation 

has been good and is consistent with the performance predicted by risk analyses. In 1971, DOT started an incidentreporting requirement for hazardous materials, entering 

data into a computerized data base, the Hazardous Materials Information System. In the 14 years from January 

1971 to March 1985, four transportation accidents occurred 

involving spent fuel shipping casks and one empty cask. 

One driver died from the injuries sustained in one of the 

accidents, but no radioactivity was released in any of the 

accidents. 22 

In its study on transportation of hazardous materials, 

the Office of Technology Assessment of the U.S. Congress 

found "technical evidence and cask performance in service 

indicate that NRC performance standards yield spent fuel 

shipping cask design specifications that provide an extremely high level of public protection, much greater than 

that afforded in any other current hazardous materials shipping activity. However, meticulous adherence to the designs during cask manufacture and to required safety 

procedures during loading and transport are critical factors 

in ensuring public and environmental safety." 23 

J-5 
Appendix J Notes 

1.49 U.S.C. 1801-1812. 

2. 42 U.S.C. Chapter 23. 

3. Transportation of Radioactive Materials, Memorandum of 

Understanding, 44 FR 38690 (July 2, 1979). 

4. 10 CFR 71.73. 

5. Computer models have been validated by full-scale tests in 

the late 1970s. 

6. 10 CFR 71.41. 

7. Nuclear Regulatory Commission, "Shipping Container 

Response to Severe Highway and Railway Accident Conditions," 

Volume 1, NUREG/CR-4829, February 1987, p. 9-28. 

8. Most radioactive materials are carried in what is referred 

to as Type-A packages, which have far less stringent regulatory 

requirements than Type-B packages, the packaging required for 

shipping spent fuel. Some materials, such as smoke detectors, are 

so low in radioactivity content that the only packaging requirement is a "strong tight" container. 

9. 10 CFR 71.47. 

10.49 CFR 177.825. 

11.Other than this designation role, States have little room to 

maneuver in the routing regulations because of the potential for 

Federal preemption. 

12.Western Interstate Energy Board, "Resolution of the 

Western Interstate Energy Board," adopted March 1988. 

13.Office of Technology Assessment, "Gearing Up for Safety: Motor Carrier Safety in a Competitive Environment," OTASET- 382, September 1988, p. 57. 

14.49 CFR 177.825(d). 

15.Massaro, Tony, Director of Environmental Affairs, City 

and County of Denver, Colorado, Transcript of Monitored Retrievable Storage Review Commission Public Hearings (Hereafter cited as Hearings Transcript), January 5, 1989, pp. 11-15; 

Massey, Rex J., Associate, Intertech Consultants, Inc., Carson 

City, Nevada, on behalf of Lincoln County and the City of Caliente, Nevada, Hearings Transcript, January 5, 1989, p. 38; Jackson, Carol, MRS Coordinator, West Virginia Citizens for a Clean 

Environment, Hearings Transcript, January 17, 1989, p. 254; 

Drey, Laura, News Editor, Coalition for Alternatives to Shearon 

Harris, Hearings Transcript, February 16, 1989, pp. 169-70; 

Hoyle, Janet, President, Blue Ridge Environmental Defense 

League, Hearings Transcript, February 16, 1989, p. 70. 

16.42 U.S.C. § 10175. 

17.Department of Energy, "Draft Plan for the Waste Isolation Pilot Plant Test Phase: Performance Assessment and Operations Demonstration," DOE/WIPP 89-011, April 1989, pp. 3-9. 

18.Federal Emergency Management Agency, "Guidance for 

Developing State and Local Radiological Emergency Response 

Plans and Preparedness for Transportation Accidents," FEMAREP-5, Draft Revision, August 1988. 

19.Office of Technology Assessment, "Transportation of 

Hazardous Materials," OTA-SET-304, July 1986, (Hereafter cited as OTA-SET-304), p. 107. 

20. Department of Transportation, Research and Special Programs Administration, Hazardous Materials Information System 

computer run made February 27, 1989. 

21. Battelle Memorial Institute, "Analysis of Institutional Issues and Lessons Learned from Recent Spent Nuclear Fuel Shipping Campaigns (1983-1987)," BMI/OTSP-03, May 1988, p. 1. 

22. OTA-SET-304, p. 107. 

23. OTA-SET-304, p. 109. 

J-6 

70 
Appendix K 

Glossary, Acronyms, and Abbreviations 

AEC: Atomic Energy Commission. Its functions have been 

assumed by DOE and NRC. 

AFR: Away-from-reactor storage. Spent fuel storage outside a reactor site boundary. Normally used for receipt and interim storage of irradiated fuel from 

several nuclear power plants. 

ALARA: "As low as reasonably achievable." A radiation 

protection principle, held by national and international scientific and regulatory authorities, and applied to 

radiation exposures. The term means as low as is reasonably achievable taking into account the state of 

technology, and the economics of improvements in 

relation to benefits to the public health and safety, 

and other societal and socioeconomic considerations, 

and in relation to the utilization of atomic energy in 

the public interest. 

At-reactor storage: Spent fuel storage that is integral with 

a reactor, or situated within the site boundary of a nuclear power station. 

Background radiation: Nuclear radiation due to the natural environment and to naturally occurring radioactivity within the body. 

Beta particles: A charged particle that is emitted by certain radioactive materials and is physically identical 

with the electron. 

Boiling water reactor (BWR): A light-water reactor in 

which water, used as both coolant and moderator, is 

allowed to boil in the core. The resulting steam is 

used directly to drive a turbine to generate electricity. 

Burnup: A measure of consumption of fissile content of 

reactor fuel, expressed as either the percentage of 

fuel atoms that have undergone fission, or the amount 

of energy released per unit mass of nuclear fuel in the 

reactor. Units normally used for the latter are 

megawatt-days per ton of uranium or heavy metal. 

Canister: The first material envelope surrounding a waste 

form (e.g., spent fuel rods) to provide containment 

for storage and handling purposes. 

Carrier: A company engaged in transporting high-level 

waste or spent fuel by land or water. 

Cask: A massive container used to transport and/or store 

irradiated nuclear fuel. It provides physical and radiological protection and dissipates heat from the 

fuel. 

Cask, dual-purpose:,A cask that could serve as a storage 

module as well as a transport cask. 

Cask, universal: A cask that could be used for spent fuel 

storage, transportation, and emplacement in the repository without further repackaging or overpacks. 

CFR: Code of Federal Regulations. 

Characterization: The collecting of information necessary 

to evaluate suitability of a region, location, or site. 

Cladding: An external layer of material (usually of Zircaloy or stainless steel) directly surrounding nuclear 

fuel that seals and protects it from the environment, 

and protects the environment from radioactive materials produced during irradiation. 

Commercial nuclear reactor: A civilian nuclear power 

plant, owned by an electric utility or utilities, and operated for generating electricity for commercial sale. 

It is required to be licensed by the NRC. 

Consolidation: The operation performed on spent fuel assemblies during which the non-fuel bearing components (upper and lower fuel-assembly tie plates, 

assembly spacer grids and any other assembly structural members) are removed and reduced in volume, 

and the fuel rods are collected and formed into a 

closely packed bundle for insertion into a canister, to 

achieve volume reduction, thereby reducing the space 

required for storage, transportation or disposal. 

Container: A receptacle designed to hold a canister of 

spent fuel or radioactive material to facilitate movement and storage. 

Criticality: A self-sustaining neutron chain reaction in 

which the number of neutrons lost by absorption or 

leakage just equals the number produced by the fission process. 

Decommissioning: The process of removing a nuclear facility from operation and returning it to a condition 

where it can be released for unrestricted use. Its contents may be decontaminated and dismantled, or decontaminated and converted to another use. This 

process occurs over a period of several years. 

Dedicated train: A train purposefully configured and opK-1 
erated to serve a specific function, such as to move a 

certain commodity, to use a certain type of equipment, or to handle traffic by a certain shipper. Dedicated trains are different from "regular trains," 

which generally transport many commodities using 

many types of equipment for many different shippers. 

Disposal: Emplacement in a repository of high-level radioactive waste, spent nuclear fuel, or other highly 

radioactive material with no foreseeable intent of recovery, whether or not such emplacement permits the 

recovery of such waste. 

DOE: U.S. Department of Energy. 

Dose equivalent: A quantity used for radiation protection 

purposes that expresses on a common scale for all radiations, the irradiation incurred by exposed persons. 

It is defined as the product of the absorbed dose and 

the quality factor, a measure of the biological effectiveness of the radiation which produced the dose. Its 

unit is the rem or sievert. 

DOT: U.S. Department of Transportation. 

Dry storage: Storage of spent nuclear fuel, in a canister or 

not, surrounded by one or more gases such as helium, 

air, nitrogen or carbon dioxide, in cask, drywell, silo 

or vault systems. Dry storage is passive, modular, 

and low in maintenance, and provides an alternative 

for nuclear power plants that cannot accommodate 

additional storage in spent fuel pools. 

EIS: Environmental impact statement. 

Enriched fuel: Nuclear fuel containing uranium which has 

been enriched in its fissile isotopes or to which 

chemically different fissile nuclides have been added. 

Commercial nuclear power plants in the United 

States use uranium which has been enriched so that it 

contains 2-5 percent U-235. 

EPA: U.S. Environmental Protection Agency. 

ERDA: Energy Research and Development Administration. With NRC, successor to the U.S. Atomic Energy Commission. Predecessor to the Department of 

Energy. 

Federal Emergency Storage Facility (FES): A facility to 

serve as a safety net of storage for spent nuclear fuel 

for emergency purposes. 

Federal Interim Storage Facility (FIS): A Federally 

owned and operated facility possibly located at an 

existing Federal site, that would provide storage for 

spent nuclear fuel from civilian reactors whose owners cannot reasonably provide adequate storage capacity on-site. The Nuclear Waste Policy Act 

currently limits the capacity of such storage to 1,900 

metric tons. 

Fertile isotope: An isotope capable of being transformed 

into a fissile isotope by neutron capture at specific 

neutron energies. 

Field drywell: Stationary, below-ground, lined individual 

cavities to store spent fuel. Shielding is provided by 

the surrounding earth and a shield plug. Heat dissipation is by conduction through the earth to the atmosphere. 

Fissile isotope: An isotope in which neutrons of any energy can induce fission. 

Fission products: A general term for the complex mixture 

of nuclides produced as a result of nuclear fission. 

Fuel assembly: A geometrical array of fuel rods, pins, 

plates, etc., held together by structural components 

for insertion in a reactor. Also called fuel bundle, fuel 

cluster, and fuel element. 

Gamma ray: Short wave-length electromagnetic radiation 

emitted during the radioactive decay of certain 

nuclides. 

Half-life: Time during which half of the atoms of a radioactive substance undergo radioactive decay. Halflives vary from millionths of a second to billions of 

years. After a period equal to 10 half-lives, the radioactivity has decreased to about 0.1 percent of its original value. 

High-level waste: The highly radioactive material resulting 

from the reprocessing of spent nuclear fuel, including 

liquid waste produced directly in reprocessing and 

any solid material derived from such liquid waste, 

that contains fission products in sufficient concentrations; and other highly radioactive material that the 

Nuclear Regulatory Commission, consistent with existing law, determines by rule requires permanent isolation. In the United States spent nuclear fuel is 

considered to be high-level waste. 

Highway route controlled quantity: Amount of radioactivity within a certain type of package that makes the 

package subject to DOT highway routing requirements. Spent nuclear fuel would be a highway route 

controlled quantity of radioactive materials. 

Independent spent fuel storage facility (ISFSF): A wet 

or dry storage facility located separate from a nuclear 

power plant or fuel reprocessing plant. An ISFSF located at the site of another facility (e.g., a reactor) is 

considered independent, even if it shares utilities 

services or physical protection, provided that it does 

not affect the safety of the other nuclear installation. 

Integral MRS: MRS facility which would receive and 

eventually ship to the repository all spent fuel requiring permanent disposal, and thus integrate the MRS 

into the Federal waste management system. In the integral MRS, there may be a "Western Strategy" in 

K-2 

7 0 0 2 2 
which the spent fuel from western reactors would go 

directly to the repository. 

Interim storage: Storage of radioactive materials such that 

(a) isolation, monitoring, environmental protection 

and human control are provided; and (b) subsequent 

action involving treatment, transport, and disposal or 

reprocessing is expected. 

Ionizing radiation: Any electromagnetic or particulate radiation capable of producing ions, directly or indirectly, in its passage through matter. 

IRG: Interagency Review Group on Nuclear Waste Management. Established in 1977, it submitted its report 

on nuclear waste management to President Carter in 

1979. 

Light water reactor: A nuclear reactor that uses light (ordinary) water to moderate (slow down) high-velocity 

neutrons and remove heat from the reactor core. 

Low-level waste: Radioactive waste not classified as highlevel radioactive waste, transuranic waste, spent nuclear fuel, or byproduct material as defined in section 

11(e)(2) of the Atomic Energy Act. 

Metric ton: 1,000 kilograms; about 2,200 pounds. 

Metric tons of uranium (MTU): That measure of weight 

equivalent to about 2,200 pounds of uranium loaded 

into a reactor as fresh fuel. 

Millirem: One-thousandth of a rem. In the International 

System of Units this would be equal to 0.00001 

sieverts. (See definition for rem) 

MRS: Monitored retrievable storage. Storage of spent fuel 

or high-level waste in facilities that provide sustained 

monitoring capability and retrievability. 

NEPA: National Environmental Policy Act of 1969. 

NRC: U.S. Nuclear Regulatory Commission. With ERDA, 

successor to U.S. Atomic Energy Commission. 

NTS: Nevada Test Site. 

Nuclear Waste Fund: Fund established by the Nuclear 

Waste Policy Act of 1982 to assure that the costs of 

high-level radioactive waste management and disposal are borne by the owners and generators of the 

waste. At present, the owners and generators pay into 

the Waste Fund a fee of one mill per net kilowatthour of nuclear-generated electricity. 

NWPA: Nuclear Waste Policy Act of 1982. 

NWPAA: Nuclear Waste Policy Amendments Act of 1987. 

OCRWM: Office of Civilian Radioactive Waste Management, in the Department of Energy. 

Overpack: A secondary external enclosure for packaged 

spent fuel providing additional protection. 

Packaging: The act of preparing spent nuclear fuel for 

handling, storage, shipment, and/or disposal. A cask 

or overpack may be a permanent part of the package. 

Person-rem: A unit of population dose equivalent obtained 

by multiplying the dose equivalent in rem by the 

population exposed. In the International System of 

Units, this would be expressed in person-sieverts. 

Plutonium: A heavy element (atomic no. 94) which comprises about 1 percent of spent nuclear fuel from 

commercial light water reactors. One of the principal 

fissile isotopes of plutonium is Pu-239 which has a 

half-life of about 24,000 years. 

Pressurized water reactor (PWR): A light water reactor 

having primary and secondary cooling circuits. In the 

primary circuit, heat is transferred from the reactor 

core to a heat exchanger by means of water kept under high pressure to achieve high temperature without boiling; in the secondary circuit, steam is 

produced to drive turbines to generate electricity. 

Radioactive decay: Spontaneous decay or disintegration of 

an unstable atomic nucleus, accompanied by the 

emission of ionizing radiation. 

Radionuclide: An unstable radioactive isotope that decays 

toward a stable state at a characteristic rate by the 

emission of ionizing radiation(s). 

Rem: The unit of dose equivalence commonly used in the 

United States. In most countries the rem has been replaced by the sievert, which is the unit of dose equivalent in the International System of Units. A sievert 

is equal to 100 rem. 

Repository: A facility for the permanent deep geologic 

disposal of high-level radioactive waste and spent nuclear fuel. It includes both surface and subsurface 

areas where high-level radioactive waste and spent 

nuclear fuel handling activities are conducted. 

Reprocessing: Recovery of fissile and/or fertile material 

from irradiated nuclear fuel by chemical separation 

from fission products and other radionuclides (e.g., 

activation products, actinides); selected fission products may also be recovered. 

Reracking: Replacement of existing fuel storage racks 

with modified racks designed to increase the amount 

of spent fuel that can be stored in pools at reactor 

sites. 

Retrievability: Capability of spent fuel or high-level waste 

to be removed from where it has been stored or 

disposed. 

Risk: Possibility of suffering harm or loss. The magnitude 

of the risk depends on both the probability of occurrence of an event and the expected consequences 

should the event occur. 

Safeguards: Includes physical protection and material accountability. Physical protection is protection against 

sabotage of spent fuel. Sabotage is a deliberate, malevolent act that could result in high environmental 

radiation levels or release of radioactive materials to 

K-3 
the environment. Material accountability is protection 

against undetected theft or diversion of the fissile 

material in spent fuel. 

Shipping cask (transport cask): A container to transport 

spent fuel and other radioactive wastes. It provides 

physical and radiological protection, and dissipates 

heat from the fuel during shipment. 

Spent nuclear fuel: Irradiated fuel element not intended 

for further reactor service. 

Storage: Retention of high-level radioactive waste, spent 

nuclear fuel, or transuranic waste with the intent to 

recover such waste or fuel for subsequent use, processing, or disposal. 

Transuranic waste: Waste material contaminated with 

plutonium and other elements having atomic numbers higher than 92. In the commercial fuel cycle, 

transuranic waste is produced primarily from the reprocessing of spent fuel and the manufacture of 

mixed uranium-plutonium fuel. 

User-Funded Interim Storage (UFIS): Voluntary storage 

of spent nuclear fuel by utilities who (1) do not have 

space at their reactor for life-of-plant-storage, or may 

not be able to obtain a license for additional storage; 

(2) have shutdown reactors at sites where they no 

longer operate nuclear power facilities; (3) prefer to 

ship spent fuel to this facility than retain it on-site. 

Uranium: A naturally occurring radioactive element with 

the atomic number 92 that has become the basic raw 

material of nuclear energy. 

Vitrification: The conversion of high-level waste materials 

into a glassy or noncrystalline solid for subsequent 

disposal. 

WIPP: Waste Isolation Pilot Plant. A facility for geologic 

disposal of transuranic waste from defense-related 

activities. The WIPP is located near Carlsbad, New 

Mexico. 

K-4 

7 0 2 
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