Generic Environmental 

Impact Statement for 

Continued Storage of 

Spent Nuclear Fuel

Final Report

Office of Nuclear Material Safety and Safeguards

NUREG-2157

Volume 1 
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Generic Environmental 

Impact Statement for 

Continued Storage of 

Spent Nuclear Fuel 

Final Report 

Manuscript Completed: August 2014 

Date Published: September 2014 

Waste Confidence Directorate 

Office of Nuclear Material Safety and Safeguards 

U.S. Nuclear Regulatory Commission 

Washington, D.C. 20555-0001 

NUREG-2157 

Volume 1 

COVER SHEET 

Responsible Agency: U.S. Nuclear Regulatory Commission, Office of Nuclear Material Safety 

and Safeguards 

Title: NUREG–2157, Generic Environmental Impact Statement for Continued Storage of Spent 

Nuclear Fuel – Final Report, Volumes 1 and 2 

For additional copies or questions about this Generic Environmental Impact Statement, contact: 

 Sarah Lopas 

 NEPA Communications Project Manager 

 

Phone: 1-800-368-5642, extension 287-0675 

Email: Sarah.Lopas@nrc.gov 

U.S. Nuclear Regulatory Commission 

Office of Nuclear Material Safety and Safeguards 

Waste Confidence Directorate 

Mail Stop 3WFN 14-C64 

11555 Rockville Pike 

Rockville, Maryland 20852 

September 2014 iii NUREG௅2157 

Abstract 

This Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel

(GEIS) generically determines the environmental impacts of continued storage, including those 

impacts identified in the remand by the Court of Appeals in the New York v. NRC decision, and 

provides a regulatory basis for a revision to 10 CFR 51.23 that addresses the environmental 

impacts of continued storage for use in future NRC environmental reviews. In this context, “the 

environmental impacts of continued storage” means those impacts that could occur as a result 

of the storage of spent nuclear fuel at at-reactor and away-from-reactor sites after a reactor’s 

licensed life for operation and until a permanent repository becomes available. The GEIS 

evaluates potential environmental impacts to a broad range of resources. Cumulative impacts 

are also analyzed. 

Because the timing of repository availability is uncertain, the GEIS analyzes potential 

environmental impacts over three possible timeframes: a short-term timeframe, which includes 

60 years of continued storage after the end of a reactor’s licensed life for operation; an 

additional 100-year timeframe (60 years plus 100 years) to address the potential for delay in 

repository availability; and a third, indefinite timeframe to address the possibility that a repository 

never becomes available. All potential impacts in each resource area are analyzed for each 

continued storage timeframe. 

The GEIS contains several appendices that discuss specific topics of particular interest, 

including the technical feasibility of continued storage and repository availability as well as the 

two technical issues involved in the remand of New York v. NRC—spent fuel pool leaks and 

spent fuel pool fires. Finally the GEIS contains NRC’s responses to public comments on the 

draft GEIS and proposed Rule and in doing so provides additional technical background on, and 

explanation of, the GEIS’s analyses and conclusions. 

The GEIS also discusses the NRC’s Federal action—the adoption of a revised Rule, 

10 CFR 51.23, to codify (i.e., adopt into regulation) the analysis in the GEIS of the 

environmental impacts of continued storage of spent fuel—and the options the NRC could 

take under the no-action alternative. 

September 2014 v 185(*௅

Contents 

Abstract ....................................................................................................................................... iii 

Figures ....................................................................................................................................... xix 

Tables......................................................................................................................................... xxi 

Executive Summary ................................................................................................................ xxiii

Abbreviations/Acronyms ....................................................................................................... lxvii

Units of Measure ...................................................................................................................... lxxi

1.0 Introduction .................................................................................................................... 1-1

1.1 History of Waste Confidence .................................................................................... 1-1

1.2 Scope of the Generic Environmental Impact Statement .......................................... 1-4

1.3 Purpose of the Generic Environmental Impact Statement ....................................... 1-

1.4 Proposed Federal Action .......................................................................................... 1-

 Purpose of and Need for the Proposed Action ......................................................... 1-6

1.6 Alternatives ............................................................................................................... 1-6

1.6.1 No-Action Alternative .................................................................................... 1-6

1.6.1.1 Site-Specific Review Option........................................................... 1-

1.6.1.2 GEIS-Only Option .......................................................................... 1-8

1.6.1.3 Policy-Statement Option ................................................................ 1-8

1.6.2 Alternatives Considered but Eliminated ........................................................ 1-9

1.6.2.1 Cessation of Licensing or Cessation of Reactor Operation ........... 1-9

1.6.2.2 Implementing Additional Regulatory Requirements ..................... 1-10

1.6.3 Comparison of Reasonable Alternatives .................................................... 1-10

 Public and Agency Involvement ............................................................................. 1-11

 Scoping Process ......................................................................................... 1-11

 Public Comments Received on the Draft GEIS and Proposed Rule .......... 1-12

 Cooperating Agencies ................................................................................ 1-12

1.8 Analytical Approach ................................................................................................ 1-12

1.8.1 Approach to Impact Assessment ................................................................ 1-12

1.8.2 Timeframes Evaluated ................................................................................ 1-13

1.8.3 Analysis Assumptions ................................................................................. 1-

1.8.4 Other Environmental Analyses ................................................................... 1-18

 Significance of Environmental Impacts ....................................................... 1-23
Contents 

185(*௅ vi September 2014 

1.8.6 Issues Eliminated from Review in this GEIS .............................................. 1-24

 GEIS Contents ............................................................................................ 1-24

1.9 Other Applicable Federal Requirements ................................................................ 1-

1.10 References ............................................................................................................. 1-

2.0 Generic Facility Descriptions and Activities ............................................................... 2-1

2.1 Generic Facility Descriptions .................................................................................... 2-1

2.1.1 At-Reactor Continued Storage Site Descriptions ......................................... 2-2

2.1.1.1 General Description of Single-Unit Nuclear Power Plant Site ........ 2-2

2.1.1.2 General Description of Multiple-Unit Nuclear Power Plant 

Sites ............................................................................................... 2-

2.1.1.3 Reactor and Fuel Technologies ..................................................... 2-6

2.1.2 Onsite Spent Fuel Storage and Handling ................................................... 2-11

2.1.2.1 Spent Fuel Pools ......................................................................... 2-11

2.1.2.2 At-Reactor Independent Spent Fuel Storage Installations ........... 2-13

2.1.3 Away-from-Reactor ISFSIs ......................................................................... 2-18

2.1.4 Dry Transfer System ................................................................................... 2-20

2.2 Generic Activity Descriptions .................................................................................. 2-24

2.2.1 Short-Term Storage Activities ..................................................................... 2-24

2.2.1.1 Decommissioning Activities during Short-Term Storage .............. 2-

2.2.1.2 Activities in Spent Fuel Pools ...................................................... 2-

2.2.1.3 Activities at At-Reactor ISFSIs ..................................................... 2-29

2.2.1.4 Activities at Away-from-Reactor ISFSIs ....................................... 2-30

2.2.2 Long-Term Storage Activities ..................................................................... 2-31

2.2.2.1 Construction and Operation of a DTS .......................................... 2-31

2.2.2.2 Replacement of Storage and Handling Facilities ......................... 2-34

2.2.3 Indefinite Storage Activities ........................................................................ 2-

2.3 References ............................................................................................................. 2-36

3.0 Affected Environment .................................................................................................... 3-1

3.1 Land Use .................................................................................................................. 3-1

3.2 Socioeconomics ....................................................................................................... 3-4

3.2.1 Employment and Income .............................................................................. 3-

3.2.2 Taxes ............................................................................................................ 3-6

3.2.3 Demography ................................................................................................. 3-6

3.2.4 Housing ........................................................................................................ 3-

 Public Services ............................................................................................. 3-
Contents 

September 2014 vii 185(*௅

3.2.6 Transportation .............................................................................................. 3-

3.3 Environmental Justice .............................................................................................. 3-8

3.4 Climate and Air Quality ........................................................................................... 3-11

3.4.1 Climate ....................................................................................................... 3-11

3.4.2 Greenhouse Gases .................................................................................... 3-12

3.4.3 Criteria Pollutants ....................................................................................... 3-13

 Geology and Soils .................................................................................................. 3-14

3.6 Surface-Water Quality and Use .............................................................................. 3-16

 Groundwater Quality and Use ................................................................................ 3-

3.8 Terrestrial Resources ............................................................................................. 3-19

3.8.1 Upland Vegetation and Habitats ................................................................. 3-20

3.8.2 Lowland and Wetland Vegetation and Habitats .......................................... 3-21

3.8.3 Wildlife ........................................................................................................ 3-21

3.9 Aquatic Ecology ...................................................................................................... 3-22

3.9.1 Aquatic Habitats ......................................................................................... 3-23

3.9.1.1 Freshwater Systems .................................................................... 3-23

3.9.1.2 Estuarine Ecosystems ................................................................. 3-24

3.9.1.3 Marine Ecosystems ..................................................................... 3-

3.9.2 Aquatic Organisms ..................................................................................... 3-

3.9.2.1 Fish .............................................................................................. 3-

3.9.2.2 Aquatic Macroinvertebrates ......................................................... 3-26

3.9.2.3 Zooplankton ................................................................................. 3-

3.9.2.4 Single-Celled Algae ..................................................................... 3-

 Other Aquatic Invertebrates and Vertebrates .............................. 3-

3.9.2.6 Aquatic Macrophytes ................................................................... 3-

3.10 Special Status Species and Habitats ..................................................................... 3-28

3.11 Historic and Cultural Resources ............................................................................. 3-30

3.12 Noise ...................................................................................................................... 3-33

3.13 Aesthetics ............................................................................................................... 3-34

3.14 Waste Management ............................................................................................... 3-34

3.14.1 Low-Level Radioactive Waste .................................................................... 3-34

3.14.2 Mixed Waste ............................................................................................... 3-36

3.14.3 Hazardous Waste ....................................................................................... 3-36

3.14.4 Nonradioactive, Nonhazardous Waste ....................................................... 3-

 Pollution Prevention and Waste Minimization ............................................ 3-
Contents 

185(*௅ viii September 2014 

 Transportation ........................................................................................................ 3-38

3.16 Public and Occupational Health ............................................................................. 3-38

3.16.1 Radiological Exposure ................................................................................ 3-39

3.16.1.1 Regulatory Requirements for Occupational Exposure ................. 3-39

3.16.1.2 Regulatory Requirements for Public Exposure ............................ 3-40

3.16.2 Radiological Exposure from Naturally Occurring and Artificial Sources ..... 3-40

3.16.3 Occupational Hazards ................................................................................ 3-42

 References ............................................................................................................. 3-42

4.0 Environmental Impacts of At-Reactor Continued Storage of Spent Fuel ................ 4-1

4.1 Land Use .................................................................................................................. 4-3

4.1.1 Short-Term Storage ...................................................................................... 4-4

4.1.2 Long-Term Storage ...................................................................................... 4-

4.1.3 Indefinite Storage ......................................................................................... 4-6

4.2 Socioeconomics ....................................................................................................... 4-6

4.2.1 Short-Term Storage ...................................................................................... 4-6

4.2.2 Long-Term Storage ...................................................................................... 4-

4.2.3 Indefinite Storage ......................................................................................... 4-9

4.3 Environmental Justice .............................................................................................. 4-9

4.3.1 Short-Term Storage .................................................................................... 4-11

4.3.2 Long-Term Storage .................................................................................... 4-12

4.3.3 Indefinite Storage ....................................................................................... 4-14

4.4 Air Quality ............................................................................................................... 4-14

4.4.1 Short-Term Storage .................................................................................... 4-14

4.4.2 Long-Term Storage .................................................................................... 4-16

4.4.3 Indefinite Storage ....................................................................................... 4-

 Climate Change ...................................................................................................... 4-18

 Short-Term Storage .................................................................................... 4-18

 Long-Term Storage .................................................................................... 4-19

 Indefinite Storage ....................................................................................... 4-20

4.6 Geology and Soils .................................................................................................. 4-20

4.6.1 Short-Term Storage .................................................................................... 4-20

4.6.2 Long-Term Storage .................................................................................... 4-21

4.6.3 Indefinite Storage ....................................................................................... 4-21
Contents 

September 2014 ix 185(*௅

 Surface-Water Quality and Use .............................................................................. 4-22

 Short-Term Storage .................................................................................... 4-22

 Spent Fuel Pools ......................................................................... 4-22

 ISFSIs .......................................................................................... 4-23

 Conclusion ................................................................................... 4-23

 Long-Term Storage .................................................................................... 4-23

 Indefinite Storage ....................................................................................... 4-24

4.8 Groundwater Quality and Use ................................................................................ 4-

4.8.1 Short-Term Storage .................................................................................... 4-

4.8.1.1 Spent Fuel Pools ......................................................................... 4-

4.8.1.2 ISFSIs .......................................................................................... 4-

4.8.1.3 Conclusion ................................................................................... 4-

4.8.2 Long-Term Storage .................................................................................... 4-

4.8.3 Indefinite Storage ....................................................................................... 4-28

4.9 Terrestrial Resources ............................................................................................. 4-29

4.9.1 Short-Term Storage .................................................................................... 4-29

4.9.1.1 Spent Fuel Pools ......................................................................... 4-29

4.9.1.2 ISFSIs .......................................................................................... 4-32

4.9.1.3 Conclusion ................................................................................... 4-33

4.9.2 Long-Term Storage .................................................................................... 4-33

4.9.3 Indefinite Storage ....................................................................................... 4-

4.10 Aquatic Ecology ...................................................................................................... 4-36

4.10.1 Short-Term Storage .................................................................................... 4-36

4.10.1.1 Spent Fuel Pools ......................................................................... 4-36

4.10.1.2 ISFSIs .......................................................................................... 4-42

4.10.1.3 Conclusion ................................................................................... 4-43

4.10.2 Long-Term Storage .................................................................................... 4-43

4.10.3 Indefinite Storage ....................................................................................... 4-44

4.11 Special Status Species and Habitat ....................................................................... 4-44

4.11.1 Short-Term Storage .................................................................................... 4-44

4.11.1.1 Spent Fuel Pools ......................................................................... 4-44

4.11.1.2 ISFSIs .......................................................................................... 4-46

4.11.1.3 Conclusion ................................................................................... 4-

4.11.2 Long-Term Storage .................................................................................... 4-48

4.11.3 Indefinite Storage ....................................................................................... 4-49

4.12 Historic and Cultural Resources ............................................................................. 4-49
Contents 

185(*௅ x September 2014 

4.12.1 Short-Term Storage .................................................................................... 4-

4.12.2 Long-Term Storage .................................................................................... 4-

4.12.3 Indefinite Storage ....................................................................................... 4-

4.13 Noise ...................................................................................................................... 4-

4.13.1 Short-Term Storage .................................................................................... 4-

4.13.2 Long-Term Storage .................................................................................... 4-

4.13.3 Indefinite Storage ....................................................................................... 4-

4.14 Aesthetics ............................................................................................................... 4-

4.14.1 Short-Term Storage .................................................................................... 4-

4.14.2 Long-Term Storage .................................................................................... 4-

4.14.3 Indefinite Storage ....................................................................................... 4-

 Waste Management ............................................................................................... 4-

 Short-Term Storage .................................................................................... 4-

 Low-Level Radioactive Waste...................................................... 4-

 Mixed Waste ................................................................................ 4-60

 Nonradioactive Waste .................................................................. 4-61

 Long-Term Storage .................................................................................... 4-61

 Low-Level Radioactive Waste...................................................... 4-62

 Mixed Waste ................................................................................ 4-63

 Nonradioactive Waste .................................................................. 4-64

 Indefinite Storage ....................................................................................... 4-

 Low-Level Radioactive Waste...................................................... 4-

 Mixed Waste ................................................................................ 4-

 Nonradioactive Waste .................................................................. 4-

4.16 Transportation ........................................................................................................ 4-66

4.16.1 Short-Term Storage .................................................................................... 4-66

4.16.2 Long-Term Storage .................................................................................... 4-

4.16.3 Indefinite Storage ....................................................................................... 4-69

 Public and Occupational Health ............................................................................. 4-69

 Short-Term Storage .................................................................................... 4-69

 Long-Term Storage .................................................................................... 4-

 Indefinite Storage ....................................................................................... 4-

4.18 Environmental Impacts of Postulated Accidents .................................................... 4-

4.18.1 Design Basis Events ................................................................................... 4-

4.18.1.1 Design Basis Events in Spent Fuel Pools .................................... 4-
Contents 

September 2014 xi 185(*௅

4.18.1.2 Design Basis Events in Dry Cask Storage Systems .................... 4-81

4.18.1.3 Conclusion ................................................................................... 4-84

4.18.2 Severe Accidents ........................................................................................ 4-84

4.18.2.1 Severe Accidents in Spent Fuel Pools ......................................... 4-

4.18.2.2 Severe Accidents in Dry Cask Storage Systems and DTSs ........ 4-88

4.18.2.3 Conclusion ................................................................................... 4-90

4.19 Potential Acts of Sabotage or Terrorism ................................................................ 4-91

4.19.1 Attacks on Spent Fuel Pools ...................................................................... 4-92

4.19.2 Attacks on ISFSIs and DTS ........................................................................ 4-94

4.19.3 Conclusion .................................................................................................. 4-

4.20 Summary ................................................................................................................ 4-

4.21 References ............................................................................................................. 4-99

5.0 Environmental Impacts of Away-From-Reactor Storage ............................................ -1

 Land Use .................................................................................................................. -

 Short-Term Storage ...................................................................................... -

 Long-Term Storage ...................................................................................... -6

 Indefinite Storage ......................................................................................... -8

 Socioeconomics ....................................................................................................... -8

 Short-Term Storage ...................................................................................... -8

 Long-Term Storage ...................................................................................... -9

 Indefinite Storage ....................................................................................... -10

 Environmental Justice ............................................................................................ -10

 Short-Term Storage .................................................................................... -11

 Long-Term Storage .................................................................................... -14

 Indefinite Storage ....................................................................................... -1

 Air Quality ............................................................................................................... -

 Short-Term Storage .................................................................................... -

 Long-Term Storage .................................................................................... -18

 Indefinite Storage ....................................................................................... -18

 Climate Change ...................................................................................................... -19

 Short-Term Storage .................................................................................... -19

 Long-Term Storage .................................................................................... -21

 Indefinite Storage ....................................................................................... -21
Contents 

185(*௅ xii September 2014 

 Geology and Soils .................................................................................................. -21

 Short-Term Storage .................................................................................... -21

 Long-Term Storage .................................................................................... -22

 Indefinite Storage ....................................................................................... -23

 Surface-Water Quality and Use .............................................................................. -23

 Short-Term Storage .................................................................................... -23

 Long-Term Storage .................................................................................... -24

 Indefinite Storage ....................................................................................... -

 Groundwater Quality and Use ................................................................................ -

 Short-Term Storage .................................................................................... -

 Long-Term Storage .................................................................................... -26

 Indefinite Storage ....................................................................................... -26

 Terrestrial Resources ............................................................................................. -

 Short-Term Storage .................................................................................... -

 Long-Term Storage .................................................................................... -28

 Indefinite Storage ....................................................................................... -29

 Aquatic Ecology ...................................................................................................... -29

 Short-Term Storage .................................................................................... -29

 Long-Term Storage .................................................................................... -30

 Indefinite Storage ....................................................................................... -31

 Special Status Species and Habitats ..................................................................... -31

 Short-Term Storage .................................................................................... -31

 Long-Term Storage .................................................................................... -33

 Indefinite Storage ....................................................................................... -34

 Historic and Cultural Resources ............................................................................. -

 Short-Term Storage .................................................................................... -

 Long-Term Storage .................................................................................... -

 Indefinite Storage ....................................................................................... -40

 Noise ...................................................................................................................... -41

 Short-Term Storage .................................................................................... -41

 Long-Term Storage .................................................................................... -42

 Indefinite Storage ....................................................................................... -43
Contents 

September 2014 xiii 185(*௅

 Aesthetics ............................................................................................................... -43

 Short-Term Storage .................................................................................... -43

 Long-Term Storage .................................................................................... -44

 Indefinite Storage ....................................................................................... -

 Waste Management ............................................................................................... -

 Short-Term Storage .................................................................................... -

 Long-Term Storage .................................................................................... -46

 Indefinite Storage ....................................................................................... -48

 Transportation ........................................................................................................ -49

 Short-Term Storage .................................................................................... -49

 Long-Term Storage .................................................................................... -

 Indefinite Storage ....................................................................................... -

 Public and Occupational Health ............................................................................. -

 Short-Term Storage .................................................................................... -

 Long-Term Storage .................................................................................... -

 Indefinite Storage ....................................................................................... -

 Environmental Impacts of Postulated Accidents .................................................... -

 Potential Acts of Sabotage or Terrorism ................................................................ -

 Summary ................................................................................................................ -

 References ............................................................................................................. -60

6.0 Cumulative Impacts ....................................................................................................... 6-1

6.1 Methodology for Assessing Cumulative Impacts ...................................................... 6-1

6.2 Spatial and Temporal Bounds of the Cumulative Impacts Assessment ................... 6-3

6.3 Past, Present, and Reasonably Foreseeable Actions .............................................. 6-3

6.3.1 General Trends and Activities ...................................................................... 6-4

6.3.2 Other NRC-Regulated or Spent Fuel-Related Activities during 

Continued Storage ........................................................................................ 6-8

6.3.2.1 Final Reactor Shutdown Activities Prior to Decommissioning ....... 6-8

6.3.2.2 Decommissioning of the Reactor Power Block (including the 

spent fuel pool), DTS, and ISFSI ................................................... 6-9

6.3.2.3 Activities to Prepare the Spent Fuel for Transportation to a 

Repository for Final Disposal ......................................................... 6-9

6.3.2.4 Transportation of Spent Fuel from an At-Reactor or AwayFrom-Reactor Storage Facility to a Repository for Disposal ........ 6-10
Contents 

185(*௅ xiv September 2014 

6.4 Resource-Specific Analyses ................................................................................... 6-10

6.4.1 Land Use .................................................................................................... 6-10

6.4.1.1 Potential Cumulative Impacts from General Trends and 

Activities ....................................................................................... 6-10

6.4.1.2 Potential Cumulative Impacts from Other NRC-Regulated or 

Spent Fuel-Related Activities ....................................................... 6-11

6.4.1.3 Conclusion ................................................................................... 6-12

6.4.2 Socioeconomics ......................................................................................... 6-12

6.4.2.1 Potential Cumulative Impacts from General Trends and 

Activities ....................................................................................... 6-13

6.4.2.2 Potential Cumulative Impacts from Other NRC-Regulated or 

Spent Fuel-Related Activities ....................................................... 6-13

6.4.2.3 Conclusion ................................................................................... 6-

6.4.3 Environmental Justice ................................................................................ 6-

6.4.3.1 Potential Cumulative Impacts from General Trends and 

Activities ....................................................................................... 6-16

6.4.3.2 Potential Cumulative Impacts from Other NRC-Regulated or 

Spent Fuel-Related Activities ....................................................... 6-

6.4.3.3 Conclusion ................................................................................... 6-18

6.4.4 Air Quality ................................................................................................... 6-18

6.4.4.1 Potential Cumulative Impacts from General Trends and 

Activities ....................................................................................... 6-19

6.4.4.2 Potential Cumulative Impacts from Other NRC-Regulated or 

Spent Fuel-Related Activities ....................................................... 6-19

6.4.4.3 Conclusion ................................................................................... 6-20

 Climate Change .......................................................................................... 6-21

 Potential Cumulative Impacts from General Trends and 

Activities and from Other NRC-Regulated or Spent FuelRelated Activities ......................................................................... 6-21

 Conclusion ................................................................................... 6-23

6.4.6 Geology and Soils ...................................................................................... 6-23

6.4.6.1 Potential Cumulative Impacts from General Trends and 

Activities ....................................................................................... 6-23

6.4.6.2 Potential Cumulative Impacts from Other NRC-Regulated or 

Spent Fuel-Related Activities ....................................................... 6-24

6.4.6.3 Conclusion ................................................................................... 6-

 Surface-Water Quality and Use .................................................................. 6-

 Potential Cumulative Impacts from General Trends and 

Activities ....................................................................................... 6-26
Contents 

September 2014 xv 185(*௅

 Potential Cumulative Impacts from Other NRC-Regulated or 

Spent Fuel-Related Activities ....................................................... 6-26

 Conclusion ................................................................................... 6-

6.4.8 Groundwater Quality and Use .................................................................... 6-28

6.4.8.1 Potential Cumulative Impacts from General Trends and 

Activities ....................................................................................... 6-28

6.4.8.2 Potential Cumulative Impacts from Other NRC-Regulated or 

Spent Fuel-Related Activities ....................................................... 6-29

6.4.8.3 Conclusion ................................................................................... 6-30

6.4.9 Terrestrial Resources ................................................................................. 6-30

6.4.9.1 Potential Cumulative Impacts from General Trends and 

Activities ....................................................................................... 6-31

6.4.9.2 Potential Cumulative Impacts from Other NRC-Regulated or 

Spent Fuel-Related Activities ....................................................... 6-32

6.4.9.3 Conclusion ................................................................................... 6-33

6.4.10 Aquatic Resources ..................................................................................... 6-34

6.4.10.1 Potential Cumulative Impacts from General Trends and 

Activities ....................................................................................... 6-34

6.4.10.2 Potential Cumulative Impacts from Other NRC-Regulated or 

Spent Fuel-Related Activities ....................................................... 6-

6.4.10.3 Conclusion ................................................................................... 6-36

6.4.11 Historic and Cultural Resources ................................................................. 6-

6.4.11.1 Potential Cumulative Impacts from General Trends and 

Activities ....................................................................................... 6-38

6.4.11.2 Potential Cumulative Impacts from Other NRC-Regulated or 

Spent Fuel-Related Activities ....................................................... 6-38

6.4.11.3 Conclusion ................................................................................... 6-39

6.4.12 Noise .......................................................................................................... 6-40

6.4.12.1 Potential Cumulative Impacts from General Trends and 

Activities ....................................................................................... 6-41

6.4.12.2 Potential Cumulative Impacts from Other NRC-Regulated or 

Spent Fuel-Related Activities ....................................................... 6-41

6.4.12.3 Conclusion ................................................................................... 6-42

6.4.13 Aesthetics ................................................................................................... 6-43

6.4.13.1 Potential Cumulative Impacts from General Trends and 

Activities ....................................................................................... 6-43

6.4.13.2 Potential Cumulative Impacts from Other NRC-Regulated or 

Spent Fuel-Related Activities ....................................................... 6-44

6.4.13.3 Conclusions ................................................................................. 6-
Contents 

185(*௅ xvi September 2014 

6.4.14 Waste Management ................................................................................... 6-

6.4.14.1 Potential Cumulative Impacts from General Trends and 

Activities ....................................................................................... 6-46

6.4.14.2 Potential Cumulative Impacts from Other NRC-Regulated or 

Spent Fuel-Related Activities ....................................................... 6-

6.4.14.3 Conclusion ................................................................................... 6-

 Transportation ............................................................................................ 6-

 Potential Cumulative Impacts from General Trends and 

Activities ....................................................................................... 6-

 Potential Cumulative Impacts from Other NRC-Regulated or 

Spent Fuel-Related Activities ....................................................... 6-

 Conclusion ................................................................................... 6-

6.4.16 Public and Occupational Health ................................................................. 6-

6.4.16.1 Potential Cumulative Impacts from General Trends and 

Activities ....................................................................................... 6-

6.4.16.2 Potential Cumulative Impacts from Other NRC-Regulated or 

Spent Fuel-Related Activities ....................................................... 6-

6.4.16.3 Conclusion ................................................................................... 6-

 Environmental Impacts of Postulated Accidents ........................................ 6-

 Potential Cumulative Impacts from General Trends and 

Activities ....................................................................................... 6-

 Potential Cumulative Impacts from Other NRC-Regulated or 

Spent Fuel-Related Activities ....................................................... 6-

 Conclusion ................................................................................... 6-

6 Summary ................................................................................................................ 6-

6.6 References ............................................................................................................. 6-

7.0 Cost-Benefit Analysis .................................................................................................... -1

 Assumptions ............................................................................................................. -2

 New Reactor Applications ............................................................................ -4

 Reactor License Renewal ............................................................................. -6

 ISFSI Licensing ............................................................................................ -

 Estimated Costs and Benefits of the Proposed Action ............................................. -8

 Estimated Costs and Benefits of the Site-Specific Review Option ........................... -9

 Estimated Costs and Benefits of the GEIS-Only Option ........................................ -10

 Estimated Costs and Benefits of the Policy-Statement Option .............................. -12

 Comparison of Alternatives .................................................................................... -14

 Final Analysis and Final Recommendation ............................................................ -
Contents 

September 2014 xvii 185(*௅

 References ............................................................................................................. -

8.0 Summary of Environmental Impacts of Continued Storage ..................................... 8-1

8.1 Summarized Environmental Impacts of Continued Storage ..................................... 8-2

8.2 Unavoidable Adverse Environmental Impacts of Continued Storage ....................... 8-4

8.3 Irreversible and Irretrievable Commitments of Resources Associated with 

Continued Storage ................................................................................................... 8-

8.4 Relationship Between Short-Term Uses of the Environment for Continued 

Storage and the Maintenance and Enhancement of Long-Term Productivity .......... 8-8

 References ............................................................................................................... 8-9

9.0 List of Preparers............................................................................................................. 9-1

10.0 Index .............................................................................................................................. 10-1

11.0 Glossary ........................................................................................................................ 11-1

Appendix A – Scoping Comments ........................................................................................ A-1

Appendix B – Technical Feasibility of Continued Storage and Repository Availability .. B-1

Appendix C – Outreach and Correspondence ..................................................................... C-1

Appendix D – Draft GEIS and Proposed Rule Comment Summaries and Responses .... D-1

Appendix E – Analysis of Spent Fuel Pool Leaks ................................................................ E-1

Appendix F – Spent Fuel Pool Fires ....................................................................................... F-1

Appendix G – Spent Fuel Storage Facilities ......................................................................... G-1

Appendix H – Estimated Costs of Alternatives .................................................................... H-1

Appendix I – High-Burnup Fuel ............................................................................................... I-1

September 2014 xix 185(*௅

Figures 

ES-1 Three Storage Timeframes Addressed in this GEIS ........................................................ xxx 

1-1 Continued Storage Timeframes ..................................................................................... 1-14

1-2 NEPA Analyses for NRC Activities ................................................................................ 1-19

2-1 Dry Storage of Spent Fuel ............................................................................................. 2-14

2-2 Licensed/Operating ISFSIs by State .............................................................................. 2-16

2-3 Conceptual Sketches of a Dry Transfer System ............................................................ 2-22

2-4 Continued Storage Timeline .......................................................................................... 2-

3-1 Map of NRC Regions Showing Locations of Operating Reactors ................................... 3-2

September 2014 xxi 185(*௅

Tables 

ES-1 Affected Resource Areas for At-Reactor Spent Fuel Storage ...................................... xxxiv 

ES-2 Affected Resource Areas for Away-From-Reactor Spent Fuel Storage ........................ xxxv 

ES-3 Summary of Environmental Impacts of Continued At-Reactor Storage .......................... xlvii 

ES-4 Summary of Environmental Impacts of Away-From-Reactor Spent Fuel Storage ............. lix 

ES- Summary of Cumulative Effects for Continued Storage of Spent Fuel .............................. lx 

1-1 List of NEPA Documents Used in Preparation of this GEIS .......................................... 1-20

2-1 U.S. Pressurized Water Reactors with Shared Spent Fuel Pools ................................... 2-6

2-2 Stainless-Steel-Clad Fuel at Decommissioning Plants .................................................... 2-

3-1 Land Area Characteristics of Operating Nuclear Power Plants with Site-Specific 

ISFSI Licenses................................................................................................................. 3-4

3-2 Occupational Dose Limits for Adults Established by 10 CFR Part 20 ........................... 3-40

3-3 Average Annual Effective Dose Equivalent of Ionizing Radiation to a Member of 

the U.S. Population for 2006 .......................................................................................... 3-41

4-1 Reference Plant Withdrawal Rates and Heat Loads ..................................................... 4-30

4-2 Summary of Environmental Impacts of Continued At-Reactor Storage ......................... 4-98

-1 Summary of Environmental Impacts of Continued Away-from-Reactor Storage ........... -

6-1 General Trends and Human Activities Occurring at or near Storage Facilities ............... 6-

6-2 Comparison of Annual Carbon Dioxide Emission Rates ............................................... 6-22

6-3 Summary of Incremental Impacts from Continued Storage on Waste Management ..... 6-46

6-4 Summary of the Cumulative Impacts from Continued Storage When Added to 

Other Federal and Non-Federal Activities ..................................................................... 6-

-1 Estimated Costs of the Proposed Action ......................................................................... -9

-2 Constant and Discounted Estimated Costs of the Site-Specific Review Option .............. -9

-3 Constant and Discounted Estimated Costs of the GEIS-Only Option ........................... -11

-4 Constant and Discounted Estimated Costs of the Policy-Statement Option ................. -13

- Summary of Constant and Discounted Estimated Costs for the Proposed Action 

and NRC’s Potential Options in the Case of No Action (in millions of 2014 dollars) ..... -

-6 Summary of Unquantified Costs and Benefits of the Proposed Action and NRC’s 

Potential Options in Case of No Action .......................................................................... -16

8-1 Summary of Environmental Impacts of Continued At-Reactor Storage ........................... 8-2

8-2 Summary of Environmental Impacts of Continued Storage at an Away-fromReactor Independent Spent Fuel Storage Installation ..................................................... 8-3

8-3 Summary of the Cumulative Impacts from Continued Storage When Added to 

Other Federal and Non-Federal Activities ....................................................................... 8-4

9-1 List of Preparers—NRC ................................................................................................... 9-2

9-2 List of Preparers—CNWRA ............................................................................................. 9-

9-3 List of Preparers—PNNL ................................................................................................. 9-6

September 2014 xxiii 185(*௅

Executive Summary 

This summary describes the contents of the U.S. Nuclear Regulatory Commission’s (NRC’s) 

Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel (GEIS). 

It briefly discusses the proposed action (a rulemaking), alternatives to the proposed action, and 

the NRC’s recommendation to the Commission. It also describes the NRC’s determinations 

regarding the environmental impacts of at-reactor and away-from-reactor continued storage of 

spent nuclear fuel (spent fuel) over short-term, long-term, and indefinite timeframes, including 

the NRC’s analysis of spent fuel pool leaks and fires. 

ES.1 What is Waste Confidence? 

Historically, Waste Confidence has been the NRC’s generic 

determination regarding the technical feasibility and 

environmental impacts of safely storing spent fuel beyond 

the licensed life for operations of a nuclear power plant. The 

Commission incorporated the generic determination in its 

regulations at Title 10 of the Code of Federal Regulations

(CFR) ZKLFKVDWLVILHGWKH15&¶Vobligations under 

the National Environmental Policy Act of 1969, as amended (NEPA), with respect to the 

continued storage of spent fuel for commercial reactor licenses, license renewals, and spent 

fuel storage facility licenses and license renewals. 

ES.2 Why Did the NRC Change the Name of the Generic 

Environmental Impact Statement and Rule? 

During the public comment period on the draft GEIS and proposed Rule, the NRC asked four 

specific questions, one of which was, “Should the title of the rule be changed in light of a GEIS 

being issued instead of a separate Waste Confidence Decision?” The NRC received an 

overwhelming number of comments in favor of changing the name of the Rule; therefore, the 

title of the Federal Register Notice for the rulemaking has been changed to “Continued Storage 

of Spent Nuclear Fuel.” Further, the title of the GEIS has been changed to, “Generic 

Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel” to be consistent 

with the title of the rulemaking. Appendix D contains summaries of the public input received on 

the four specific questions on the proposed Rule and other comments received on the draft 

GEIS and proposed Rule as well as the NRC’s responses to those comments. 

Continued Storage applies to the 

storage of spent fuel after the end 

of the licensed life for operations of 

a nuclear reactor and before final 

disposal in a permanent repository. 
Executive Summary 

185(*௅ xxiv September 2014 

ES.3 Why Has the NRC Developed a Generic Environmental 

Impact Statement? 

Since the Waste Confidence Rule was originally developed in 1984, the NRC has periodically 

updated the Rule, with the last update completed in 2010. A number of parties challenged the 

2010 Waste Confidence Rule in court, and in June 2012, the Court of Appeals for the District of 

Columbia Circuit ruled that the 2010 Waste Confidence rulemaking did not satisfy the NRC’s 

NEPA obligations. The Court of Appeals identified deficiencies in the 2010 Waste Confidence 

rule related to the NRC’s environmental analysis of spent fuel pool fires and leaks, and the 

environmental impacts should a repository not become available. 

In response to the Court of Appeals' ruling, 

the Commission decided that the NRC would 

not issue any final licenses that relied upon 

the Waste Confidence Rule until the NRC 

addressed the deficiencies identified by the 

Court of Appeals (Commission Order CLI–

12–16). The Commission separately directed 

the staff to develop an updated Waste 

Confidence decision and Rule supported by an environmental impact statement (SRMCOMSECY-12-0016). The staff has prepared this GEIS to satisfy its NEPA obligations 

regarding the environmental impacts of continued storage of spent fuel in an efficient manner. 

The GEIS provides a regulatory basis for the revision of the Rule. Chapter 1 of the GEIS 

provides a more detailed discussion of the history of the Waste Confidence rulemaking. 

ES.4 What is the Proposed 

Action Being Addressed 

in this GEIS? 

The proposed Federal action is the adoption of a 

revised rule—10 CFR —that codifies the 

analysis in the GEIS of the environmental 

impacts of continued storage of spent fuel. 

To comply with The National Environmental 

Policy Act of 1969 (NEPA) Federal agencies: 

x assess the environmental impacts of major 

Federal actions, 

x consider the environmental impacts in making 

decisions, and 

x disclose the environmental impacts to the public.

Why is the NRC evaluating continued 

storage on a generic basis? 

The NRC considers the continued storage of 

spent fuel an activity that is similar for all 

commercial nuclear power plants and storage 

facilities. Therefore, a generic analysis is an 

appropriate, effective, and efficient method of 

evaluating the environmental impacts of 

continued storage. Other examples of NRC 

generic environmental evaluations include the 

License Renewal GEIS (NUREG௅WKH

Decommissioning GEIS (NUREG௅DQG

the In-Situ Leach Uranium Milling Facilities 

GEIS (NUREG௅1910).
Executive Summary 

September 2014 xxv 185(*௅

ES.5 What is the Purpose and Need for the Proposed 

Action? 

The need for the proposed action is to provide processes for use in NRC licensing to address 

the environmental impacts of continued storage. Historically, the NRC and license applicants 

KDYHUHOLHGRQ&)5WRFRQFOXVLYHO\DGGUHVVWKHHQYLURQPHQWDOLPSDFWVRIFRQWLQXHG

storage in environmental reports, environmental impact statements (EISs), environmental 

assessments (EAs), and hearings. The purpose of the proposed action is to preserve the 

efficiency of the NRC’s licensing processes with respect to the environmental impacts of 

continued storage. 

ES.6 Could the NRC Pursue Options Other Than This 

Rulemaking? 

Yes. As discussed in Section 1.6 of the GEIS, the NRC considered several different 

approaches for evaluating the environmental impacts of continued storage. The NRC looked at 

the three options that it could have pursued LILWFKRVHQRWWRDGRSWDUHYLVHG&)5. 

1. The Site-Specific Review Option. The NRC would take no action to generically address the 

environmental impacts of continued storage and, instead, would address the environmental 

impacts of continued storage in individual, site-specific licensing reviews. 

2. The GEIS-Only Option. The NRC would rely on the GEIS to analyze the environmental 

impacts of continued storage, which would then support site-specific licensing reviews. 

There would be no Rule, so site-specific EISs or EAs would incorporate the GEIS by 

reference or adopt the conclusions in the GEIS. 

 The Policy-Statement Option. The Commission would issue a policy statement that 

expresses the Commission's intent to either adopt or incorporate the environmental impacts 

in the GEIS into site-specific NEPA actions or to prepare a site-specific evaluation for each 

NRC licensing action. 

The NRC determined that the environmental impacts of these three options, in the case of no 

action, are essentially the same because they are merely different administrative approaches to 

addressing the environmental impacts of continued storage. Further, in both the proposed 

action and all of the NRC’s options in the case of no action, the NRC would analyze the 

environmental impacts of continued storage. The NRC’s conclusion is to adopt a revised 

10 &)5EHFDXVHRIWKHHIILFLHQFLHVWKDWZRXOGEHJDLQHGLQUHDFWRUDQGVSHQWIXHOVWRUDJH

facility licensing reviews. Adopting a revised Rule minimizes expenditures on site-specific 

reviews, limits the potential for lengthy project delays, and has the same environmental impacts 

as the NRC’s options in case of no action. 
Executive Summary 

185(*௅ xxvi September 2014 

During the scoping period and draft GEIS and proposed 

Rule comment period, the NRC received many 

suggested alternatives to the rulemaking, including calls 

for halting NRC licensing activities and shutting down 

operating reactors or imposing new requirements on 

nuclear power plants, such as storing spent fuel in 

special hardened onsite storage, reducing spent fuel 

pool density, and accelerating the transfer of spent fuel 

from pools to dry casks. The NRC determined that 

halting NRC licensing and closing nuclear reactors 

would not meet the purpose and need of the proposed 

action. The NRC also determined that additional 

requirements on spent fuel storage would not meet the purpose and need. Further, the GEIS is 

a NEPA review and does not authorize the initial or continued operation of any nuclear power 

plant, nor does it authorize storage of spent fuel; therefore, this GEIS would not be the 

appropriate activity in which to mandate new spent fuel storage requirements. 

ES.7 What is Covered in the GEIS? 

The GEIS analyzes the environmental impacts of continued storage of spent fuel. The NRC has 

looked at the direct, indirect, and cumulative effects of continued storage for three timeframes—

short-term, long-term, and indefinite. These timeframes are defined below and are discussed in 

more detail in Section 1.8.2 of the GEIS. The analyses contained in this GEIS provide a 

regulatory basis for the proposed revisions to 10 &)5 Appendix B addresses the 

technical feasibility of repository availability and continued safe storage of spent fuel while 

Appendices E and F address the consequences of spent fuel pool leaks and fires, respectively. 

ES.8 What is Not Covered in the GEIS? 

The NRC is evaluating the continued storage of commercial spent fuel in this GEIS. Thus, 

certain topics are not addressed because they are not within the scope of this review. These 

topics include: 

x noncommercial spent fuel (e.g., defense waste), 

x commercial high-level waste generated from reprocessing, 

x greater-than-class-C waste, 

x foreign spent fuel stored in the United States, 

x nonpower reactor spent fuel (e.g., test and research reactors, including foreign generated 

fuel stored in the United States), 

This rulemaking does not authorize 

the initial or continued operation of 

any nuclear power plant, nor does it 

authorize storage of spent fuel. It 

does not permit a nuclear power plant 

or any other facility to operate or store 

spent fuel. Every nuclear power plant 

or specifically licensed spent fuel 

storage facility must undergo an 

environmental review as part of its sitespecific licensing process.
Executive Summary 

September 2014 xxvii 185(*௅

x need for nuclear power, and 

x reprocessing of commercial spent fuel. 

ES.9 Did the NRC Involve the Public or Governmental 

Organizations? 

The NRC announced that it was planning to develop an EIS and requested comments on the 

proposed scope of the GEIS in a Federal Register Notice that was published on October 

)5Publication of this notice EHJDQD-day public comment period for 

scoping. The NRC also issued press releases, sent scoping letters to Tribal governments and 

State liaisons, and sent e-mails to approximately 1,VWDNHKROGHUVZKRKDGSUHYLRXVO\

expressed interest in matters related 

to high-level waste. The NRC 

conducted four public scoping 

meetings that were all accessible via 

Internet and telephone, so people from 

all over the country could participate 

and give their comments on the scope 

of the Waste Confidence GEIS. In 

November 2012, the NRC met with 

representatives of the U.S. 

Environmental Protection Agency 

(EPA) to discuss the Waste 

Confidence rulemaking. The NRC 

also held a government-to-government 

meeting with the Prairie Island Indian 

Community in June  There are 

no formal cooperating agencies 

identified in this environmental review. 

2Q6HSWHPEHUthe EPA published a notice of availability in the Federal Register

 FR VWDUWLQJWKH-day comment period on the draft GEIS. In response to the 

2FWREHUJRYHUQPHQWVKXWGRZQ, which caused the agency to reschedule several public 

PHHWLQJVWKH15&H[WHQGHGWKHFRPPHQWSHULRGWR'HFHPEHU FR The 

NRC also issued press releases, sent letters to Tribal governments and State liaison officers, 

produced a YouTube video, held multiple teleconferences, and sent e-mails to approximately 

VWDNHKROGHUVZKRKDGH[SUHVVHGLQWHUHVWLQWKLVSURMHFW During the comment period the 

15&KHOGSXEOLFPHHWLQJVWKURXJKRXWWKH8QLWHG6WDWHV7KHUHZHUHDSSUR[LPDWHO\

1,400 total participants at those meetings. Overall, the NRC received approximately 

$WWKHHQGRIWKH-day scoping period, the NRC 

summarized what it heard and responded to public 

comments in its Scoping Summary Report, which can be 

accessed at 

KWWSSEDGXSZVQUFJRYGRFV0/0/$SGI. 

A separate document at 

KWWSSEDGXSZVQUFJRYGRFV0/0/$SGI

lists the scoping comments the NRC received, organized 

by category. 

At the end of the draft GEIS and proposed Rule comment 

period, the NRC summarized the public comments and 

provided responses in Appendix D of this final GEIS. 

A separate document at 

KWWSSEDGXSZVQUFJRYGRFV0/0/$SGI

lists the comments the NRC received on the draft GEIS 

and proposed Rule.
Executive Summary 

185(*௅ xxviii September 2014 

100 pieces of correspondence (e.g., e-mails, letters, postcards, etc.) from the public and 

recorded over 1,600 pages of transcripts. 

GEIS 6HFWLRQ and Appendices A, C, and D discuss public and agency involvement in this 

environmental review and rulemaking. The Scoping Summary report provides information about 

the NRC’s scoping activities and what the NRC heard during the scoping process. Appendix D 

provides the NRC’s responses to comments received on the draft GEIS and proposed Rule as 

well as Agencywide Documents Access and Management System (ADAMS) accession 

numbers for public meeting summaries and transcripts. 

The ADAMS electronic public reading room is available at http://www.nrc.gov/readingrm/adams.html. If you encounter issues accessing ADAMS, call the NRC at 1-800--4209 or 

--RUVHQGDQ e-mail to pdr.resource@nrc.gov. 

ES.10 What Type of Comments Did the NRC Receive on the 

Draft GEIS? 

The NRC transcribed approximately 1,600 pages of comments from QHDUO\meeting 

participants GXULQJWKHSXEOLFPHHWLQJVDQGreceived approximately 100 written submittals 

during the comment period. The most common topics were general opposition to nuclear 

power, feasibility of safe storage and disposal, and alternatives. Other high-interest topics 

included spent fuel pool fires and leaks, institutional controls, high-burnup fuel, accidents, 

terrorism and security, expedited transfer of spent fuel to dry cask storage and hardened onsite 

storage of fuel, and general opposition to the Rule and GEIS. Detailed information on all 

correspondence, including authors and ADAMS accession numbers for submissions, is 

contained in a separate document titled, Comments on the Waste Confidence Draft Generic 

Environmental Impact Statement and Proposed Rule, which is located in ADAMS under 

Accession No. 0/$. Appendix D provides comment summaries and the NRC’s 

responses to comments. 

ES.11 What Were the Changes to the Final GEIS? 

As stated earlier, the NRC received thousands of comments on the draft GEIS and proposed 

Rule. The NRC made changes to the final GEIS and proposed Rule to address some of the 

concerns raised in those comments. The NRC also added a glossary (Chapter 11). Some of 

the changes to the final GEIS are listed below. 

High-Burnup Fuel. Because of interest from the public, the NRC added a new appendix 

(Appendix I) that provides background information on the licensing, storage, and transportation 

of high-burnup fuel. 
Executive Summary 

September 2014 xxix 185(*௅

Institutional Controls. Because of the volume of public comment on institutional controls, the 

NRC added additional information in Appendix B. 

Purpose of GEIS, Proposed Federal Action, Purpose and Need, and Alternatives. In response 

to public comments regarding the structure of the GEIS and the rulemaking, the NRC has 

revised several sections of Chapter 1. The purpose of the GEIS (see 6HFWLRQhas been 

simplified to more clearly focus on determining the environmental impacts of continued storage 

and determining whether those impacts can be generically addressed. The proposed Federal 

action (in Section 1.4) is the adoption of a revised Rule that codifies, or adopts into regulation, 

WKHHQYLURQPHQWDOLPSDFWVRIFRQWLQXHGVWRUDJH7KHSXUSRVHRIWKHUXOHPDNLQJLQ6HFWLRQ

is to preserve the efficiency of NRC’s licensing processes with respect to the environmental 

impacts of continued storage, and the need DOVRLQ6HFWLRQLVWRSURYLGHSURFHVVHVIRUXVH

in NRC licensing to address the environmental impacts of continued storage. Because only the 

proposed action preserves the efficiency of the NRC’s licensing processes with respect to the 

environmental impacts of continued storage, the NRC’s alternatives analysis (in Section 1.6) 

focuses on the processes—or options—that the NRC could use in the case of no action. These 

options include all of the approaches to considering the impacts of continued storage that the 

NRC considered as alternatives in the draft GEIS. Finally, the NRC has clarified that the NRC’s 

proposed action and its options in the case of no action are all different administrative 

approaches to addressing the environmental impacts of continued storage, and as such, their 

environmental impacts are not significant. 

Cost-Benefit Analysis. The NRC updated its cost-benefit analysis so that it contains current—

and reduced—costs for NRC staffing, as well as discounting that starts from a 2014 baseline 

LQVWHDGRIDEDVHOLQH$OOcost-benefit information is now presented in 2014 dollars. In 

addition, the cost-benefit analysis identifies costs associated with GEIS-development and 

rulemaking as past (or sunk) costs, but it retains them in the analysis to provide a complete 

picture of the costs associated with each activity. In addition, the NRC changed the 

DUUDQJHPHQWRIVHFWLRQVLQ&KDSWHUWRUHIOHFWWKHrevised approach to alternatives. 6HFWLRQ

now contains the proposed action, while subsequent sections (Sections DQGHDFK

contain NRC’s options in the case of no action. 

Cost of Continued Storage. Due to the large number of comments received on this topic the 

NRC added cost information for continued storage activities and facilities in Chapter 2. 

Technical Feasibility of Safe Storage. Additional information was provided in Appendix B on the 

role of a regulatory framework and institutional controls during continued storage. 

Substantive changes to the final GEIS are indicated by “change bars” in the margins of pages. 
Executive Summary 

185(*௅ xxx September 2014 

ES.12 How did the NRC Evaluate the Continued Storage of 

Spent Fuel in this GEIS? 

The NRC looked at potential environmental impacts of continued storage in three timeframes: 

short-term storage, long-term storage, and indefinite storage (see Figure ES-1). The short-term 

and long-term storage timeframes include an assumption that a permanent geologic repository 

becomes available by the end of those timeframes. The indefinite storage timeframe assumes 

that a repository never becomes available. For a detailed discussion of the three timeframes, 

see Section 1.8.2. 

The NRC has analyzed three timeframes that represent various scenarios for the length of 

continued storage that may be needed before spent fuel is sent to a repository. The first, most 

likely, timeframe is the short-term timeframe, which analyzes 60 years of continued storage after 

the end of a reactor’s licensed life for operation. The NRC acknowledges, however, that the 

short-term timeframe, although the most likely, is not certain. Accordingly, the GEIS also 

analyzed two additional timeframes. The long-term timeframe considers the environmental 

impacts of continued storage for an additional 100 years after the short-term timeframe for a 

total of 160 years after the end of a reactor’s licensed life for operation. Finally, although the 

NRC considers it highly unlikely, the GEIS includes an analysis of an indefinite timeframe, which 

assumes that a repository does not become available. 

 

Figure ES-1. Three Storage Timeframes Addressed in this GEIS 

Short-Term 

Storage

ͻTimeframe is 60 years beyond licensed life for reactor operations.

ͻAssumes a repository becomes available by the end of this timeframe.

Long-Term 

Storage

ͻTimeframe is for 100 years beyond the short-term storage timeframe.

ͻAssumes a repository becomes available by end of this timeframe.

Indefinite 

Storage

ͻAssumes no repository becomes available.

ͻIndefinite storage and handling of spent fuel. 
Executive Summary 

September 2014 xxxi 185(*௅

To guide its analysis, the NRC also relied on certain 

assumptions regarding the storage of spent fuel. A detailed 

discussion of these assumptions is contained in Section 

1.8.. Some of these assumptions are listed below: 

x Institutional controls would remain in place. 

x Spent fuel canisters and casks would be replaced 

approximately once every 100 years. 

x Independent spent fuel storage installation (ISFSI) and 

dry transfer system (DTS) facilities would also be 

replaced approximately once every 100 years. 

x A DTS would be built at each ISFSI location for fuel 

repackaging. 

x All spent fuel would be moved from spent fuel pools to 

dry storage by the end of the short-term storage 

timeframe (60 years). 

x In accordance with NEPA, the analyses in the GEIS are based on current technology and 

regulations. 

The NRC used previous environmental evaluations and technical reports to help inform the 

impact determinations in this GEIS. Chapter 1 includes a list of NEPA documents used in the 

development of the GEIS, and the end of each chapter includes a complete list of references. 

References are publicly available, and most are available in ADAMS. 

ES.13 What Facilities and Activities are Addressed in the 

GEIS? 

Chapter 2 describes typical facility characteristics and activities that the NRC used to assess the 

environmental impacts of continued storage of spent fuel. The GEIS looked at spent fuel 

storage at single- and multiple-reactor nuclear power plant sites, in spent fuel pools, at-reactor 

ISFSIs, and away-from-reactor ISFSIs. In addition to existing reactor designs and conventional 

spent fuel, the NRC also considered reactor and fuel technologies such as mixed oxide fuel 

(MOX) and small modular reactors. 

Section 2.2 describes the activities related to the storage of spent fuel that are expected to 

occur during the three storage timeframes (short-term, long-term, and indefinite). 

An ISFSI is a facility designed and 

constructed for the interim storage 

of spent fuel. Typically, spent fuel is 

stored in dry cask storage systems. 

NRC requirements state that dry 

cask storage must shield people 

and the environment from radiation 

and keep the spent fuel inside dry 

and nonreactive. 

DTSs would be built at ISFSI sites 

(at-reactor or away-from-reactor) in 

the long-term storage timeframe. A 

DTS would enable retrieval of spent 

fuel for inspection or repackaging 

without the need to return the spent 

fuel to a spent fuel pool.
Executive Summary 

185(*௅ xxxii September 2014 

x The short-term storage timeframe (60 years beyond the 

licensed life for operation of the reactor) includes routine 

maintenance and monitoring of the spent fuel pool and 

ISFSI and transferring spent fuel from pools to dry cask 

storage. Because decommissioning is required to be 

completed within 60 years after a reactor shuts down 

(unless additional time is necessary to protect public 

health and safety), the NRC assumes that all spent fuel 

will be moved from spent fuel pools to dry cask storage 

by the end of the short-term storage timeframe. For an 

away-from-reactor ISFSI, this timeframe includes 

construction and operation, including routine 

maintenance and monitoring, at the facility. 

x The long-term storage timeframe (100 years beyond the 

initial 60-year [short-term] storage timeframe) includes 

activities such as continued facility maintenance, 

construction and operation of a DTS, and replacement of ISFSI and DTS facilities, including 

casks. 

x The indefinite storage timeframe (no repository becomes available) assumes that the 

activities associated with long-term storage continue indefinitely, with ISFSI and DTS 

facilities being replaced at least once every 100 years. 

The NRC also looked at ongoing regulatory activities that could affect the continued storage of 

spent fuel, including regulatory changes resulting from lessons learned from the September 11, 

2001 terrorist attacks and the March 11, 2011 earthquake and tsunami that damaged the 

Fukushima Dai-ichi plant in Japan. Appendix B discusses a number of ongoing regulatory 

program reviews that ensure the safety and security of spent fuel storage and transportation. 

ES.14 How did the NRC Describe Environmental Impacts? 

NRC used terms from other NEPA documents, such as those for license renewal or new 

reactors, to define the standard of significance for assessing environmental issues.

SMALL—Environmental effects are not detectable or are so minor that they will 

neither destabilize nor noticeably alter any important attribute of the resource. 

MODERATE—Environmental effects are sufficient to alter noticeably, but not to 

destabilize, important attributes of the resource. 

MOX fuel is a type of nuclear 

reactor fuel that contains plutonium 

oxide mixed with either natural or 

depleted uranium oxide, in ceramic 

pellet form. This fuel differs from 

conventional nuclear fuel, which is 

made of pure uranium oxide. 

Small modular reactors are 

nuclear power plants smaller in 

VL]HHJ0:HWKan current 

generation baseload plants (e.g., 

1,000 MW(e) or higher). These 

compactly designed reactors are 

factory-fabricated and can be 

transported by truck or rail to a 

nuclear power plant site.
Executive Summary 

September 2014 xxxiii 185(*௅

LARGE—Environmental effects are clearly noticeable and are sufficient to destabilize 

important attributes of the resource. 

For risk-based determinations (such as in the NRC’s analyses of severe accidents such as 

spent fuel pool fires), the probability of occurrence as well as the potential consequences have 

been factored into the determination of significance. 

ES.15 What Environmental Resource Areas did the NRC 

Consider? 

&KDSWHUGLVFXVVHVWKHHQYLURQPHQWWhat exists at and around the facilities where spent fuel is 

stored in spent fuel pools and at-reactor ISFSIs. This description of resources provides 

information that is incorporated into the analyses of environmental impacts of continued storage 

in Chapter 4 (at-reactor impacts) and Chapter 6 (cumulative impacts). The License Renewal 

GEIS (NUREG௅ZDVWKHSULPDU\VRXUFHRILQIRUPDWLRQLQ&KDSWHUThe NRC also 

referenced information from site-specific environmental reviews, such as those for initial and 

renewal ISFSI licenses, the renewal of operating licenses, and combined licenses for new 

reactors. The affected resource areas and attributes discussed in the GEIS are listed in 

Table ES-1. 

The affected environment and potential impacts of continued storage at an away-from-reactor 

,6)6,DUHGLVFXVVHGLQ&KDSWHUDZD\-from-reactor impacts). The analysis of away-fromUHDFWRUVSHQWIXHOVWRUDJHLQ&KDSWHULVEDVHGLQJHQHUDORQWKHGHVFULSWLRQRIWKHDIIHFWHG

HQYLURQPHQWSURYLGHGLQ&KDSWHU+Rwever, some aspects of those discussions would not be 

applicable, or would not be applicable in the same way, for an away-from-reactor ISFSI. This 

generic analysis is based, in part, on the siting evaluation factors in &)53DUW6XESDUW(, 

which the location selected for the away-from-reactor ISFSI must meet. Further, for the analysis 

of continued storage at an away-from-reactor ISFSI, the term ISFSI refers to all of the original 

facilities that would be built (i.e., storage pads, casks, and canister transfer building). 

7KHDIIHFWHGUHVRXUFHDUHDVDQGDWWULEXWHVGLVFXVVHGLQ&KDSWHURIWKH*(,6DUHOLVWHGLQ

Table ES-2. 
Executive Summary 

185(*௅ xxxiv September 2014 

Table ES-1. Affected Resource Areas for At-Reactor Spent Fuel Storage 

Affected 

Resource Area Attributes 

Land Use Site areas and land requirements for operating nuclear power plants; land 

requirements for at-reactor ISFSIs; general land characteristics and coverage; 

land use in the vicinity of nuclear power plants; locations of nuclear power plants 

Socioeconomics Regional social, economic, and demographic conditions around nuclear power 

plant sites, including employment, taxes, public services, housing demand, and 

traffic 

Environmental 

Justice 

Human health and environmental effects; minority and low-income populations; 

subsistence consumption of fish and wildlife 

Climate and Air 

Quality 

Local and regional climate and air quality, including criteria pollutants and 

greenhouse gases 

Geology and Soils The physical setting of nuclear power plants and associated geologic strata and 

soils; different physiographic provinces in the United States 

Water Resources Surface-water and groundwater use and quality; existing radioactive leaks at 

nuclear power plants and tritium contamination of groundwater 

Ecological 

Resources 

Terrestrial and aquatic resources, including varied habitat such as wetlands and 

floodplains, wildlife, aquatic organisms, and threatened, endangered, and 

protected species and habitat 

Historic and Cultural 

Resources 

Historic and cultural resources that could be present at nuclear power plant sites 

Noise Ambient noise levels around existing spent fuel storage sites 

Aesthetics The existing scenic quality of spent fuel storage sites, including viewsheds with 

water bodies, topographic features, other visual landscape characteristics 

Waste Management Wastes generated by continued storage of spent fuel, including low-level 

radioactive waste, hazardous waste, mixed waste, nonradioactive/nonhazardous 

waste; pollution prevention and waste minimization; capacity of disposal facilities 

Transportation Transportation characteristics of reactor sites; workers involved in transportation 

activities; local, regional, and national transportation networks; populations that 

use them 

Public and 

Occupational Health 

NRC requirements for radiological protection of the public and workers from the 

continued storage of spent fuel; public radiation doses from natural and artificial 

sources; regulatory framework for occupational hazards 
Executive Summary 

September 2014 xxxv 185(*௅

Table ES-2. Affected Resource Areas for Away-From-Reactor Spent Fuel Storage 

Affected 

Resource Area Attributes 

Land Use Site areas and land requirements for an away-from-reactor ISFSI to store 

40,000 MTU; general land characteristics and coverage 

Socioeconomics Regional social, economic, and demographic conditions, including employment, 

taxes, public services, housing demand, and traffic 

Environmental 

Justice 

Human health and environmental effects; minority and low-income populations; 

subsistence consumption of fish and wildlife 

Climate and Air 

Quality 

Local and regional climate and air quality, including criteria pollutants and 

greenhouse gases 

Geology and Soils The physical setting and associated geologic strata and soils; the different 

physiographic provinces in the United States 

Water Resources Surface-water and groundwater use and quality 

Ecological Resources Terrestrial and aquatic resources, including varied habitat such as wetlands and 

floodplains, wildlife, aquatic organisms, and threatened, endangered, and 

protected species and habitat 

Historic and Cultural 

Resources 

Historic and cultural resources that could be present at an away-from-reactor 

ISFSI site 

Noise Ambient noise levels around general construction sites 

Aesthetics The existing scenic quality, including viewsheds with water bodies, topographic 

features, or other visual landscape characteristics 

Waste Management Wastes generated by continued storage of spent fuel, including low-level 

radioactive waste, hazardous waste, mixed waste, nonradioactive/nonhazardous 

waste; pollution prevention and waste minimization; capacity of disposal facilities 

Transportation Transportation characteristics; workers involved in transportation activities; local, 

regional, and national transportation networks and populations that use them 

Public and 

Occupational Health 

NRC requirements for radiological protection of the public and workers from the 

continued storage of spent fuel; public radiation doses from natural and artificial 

sources; the regulatory framework for occupational hazards 

ES.16 What are the Environmental Impacts of Continued 

Storage? 

Chapter 4 addresses potential environmental impacts of at-reactor continued storage in spent 

fuel pools and at-UHDFWRU,6)6,V&KDSWHUDGGUHVVHVLPSDFWVDWDZD\-from-reactor ISFSIs. 

As applicable for each resource area, impact determinations were made for each of the three 

spent fuel storage timeframes: short-term, long-term, and indefinite. The following pages 

provide a short synopsis of impacts, followed by summary tables (Tables ES-DQG(6-4). 

At-reactor impacts of continued storage are addressed first, followed by away-from-reactor 
Executive Summary 

185(*௅ xxxvi September 2014 

impacts. For some resource areas, the impact determination language is specific to the 

authorizing regulation, executive order, or guidance. 

ES.16.1 Environmental Impacts of At-Reactor Spent Fuel Storage 

ES.16.1.1 Land Use 

Short-Term Storage. Impacts would be SMALL. Continued at-reactor storage in a spent fuel 

pool or ISFSI would not require disturbance of any new land or result in operational or 

maintenance activities that would change land use. 

Long-Term Storage. Impacts would be SMALL. Long-term storage at an at-reactor ISFSI 

would not result in operational or maintenance activities that would change land-use conditions. 

Construction of a DTS and replacement of an ISFSI and a DTS after 100 years would impact a 

small fraction of the land committed for a nuclear power plant. 

Indefinite Storage. Impacts would be SMALL. Impacts would be similar to long-term impacts—

a small fraction of land would be impacted and land-use conditions would not change. Older 

ISFSIs and DTS facilities would be demolished, and that land would be reclaimed or reused as 

part of the cyclic replacements. 

ES.16.1.2 Socioeconomics 

Short-Term Storage. Impacts would be SMALL. A small number of workers would be required 

to maintain and monitor spent fuel pools and an at-reactor ISFSI, tax payments to local 

jurisdictions would continue, and there would be no increased demand for housing and public 

services. 

Long-Term Storage. Impacts would be SMALL. The construction of a DTS would take about 

1 to 2 years and the size of the construction and ISFSI replacement and operations workforce 

would be small. Tax payments would continue and would remain relatively constant at postreactor operations levels. Additionally, there would be no increased demand for housing and 

public services. 

Indefinite Storage. Impacts would be SMALL. Impacts would be similar to those described for 

long-term storage. The workforce required for monitoring and replacement of DTS facilities and 

ISFSIs would be small. Property tax revenue would continue as long as spent fuel remains 

onsite. 

 
Executive Summary 

September 2014 xxxvii 185(*௅

ES.16.1.3 Environmental Justice 

Short-Term Storage. Continued maintenance and monitoring of spent fuel pools and at-reactor 

ISFSIs would have minimal human health and environmental effects on all populations including 

minority and low-income populations. Overall human health and environmental effects from 

continued short-term spent fuel storage would be limited in scope and SMALL for all 

populations. Therefore, minority and low-income populations are not expected to experience 

disproportionately high and adverse human health and environmental effects from the continued 

short-term storage of spent fuel. 

Long-Term Storage. Continued maintenance and monitoring of spent fuel in at-reactor ISFSIs 

would have minimal human health and environmental effects on all populations including 

minority and low-income populations near these storage facilities. Overall human health and 

environmental effects from continued long-term spent fuel storage would be limited in scope and 

SMALL for all populations, except for historic and cultural resources, which would be SMALL to 

LARGE. Therefore, minority and low-income populations are not expected to experience 

disproportionately high and adverse human health and environmental effects from the continued 

long-term storage of spent fuel. 

Indefinite Storage. Indefinite maintenance and monitoring of spent fuel in at-reactor ISFSIs 

would have minimal human health and environmental effects on all populations including 

minority and low-income populations near these storage facilities. Overall human health and 

environmental effects during indefinite storage of spent fuel would be the same as those 

described for long-term storage, except for the effects of nonradioactive waste generation and 

disposal, which would be SMALL to MODERATE. Therefore, minority and low-income 

populations are not expected to experience disproportionately high and adverse human health 

and environmental effects from the indefinite storage of spent fuel. 

ES.16.1.4 Air Quality 

Short-Term Storage. Impacts would be SMALL. Air emission impacts from spent fuel storage 

activities from spent fuel pools and ISFSIs during short-term storage would be substantially 

smaller than air emissions during power generation. Air temperature changes near dry casks 

would be indistinguishable from temperature changes that occur naturally. 

Long-Term Storage. Impacts would be SMALL. Construction of a DTS, ongoing operation and 

maintenance of the storage facilities, and replacement of an ISFSI and DTS after 100 years 

would result in minor and temporary air emissions. 

Indefinite Storage. Impacts would be SMALL. Impacts would be similar to those for long-term 

storage ISFSI and DTS operations, and replacement activities would result in minor and 

temporary air emissions. 
Executive Summary 

185(*௅ xxxviii September 2014 

ES.16.1.5 Climate Change 

Short-Term Storage. Impacts would be SMALL. The 

annual level of greenhouse gases generated during 

continued storage is a small percentage of the annual 

levels generated in the United States. 

Long-Term Storage. Impacts would be SMALL. Impacts would be similar to short-term 

impacts, and greenhouse gas emissions would be a small fraction of the overall level in the 

United States. 

Indefinite Storage. Impacts would be SMALL. Greenhouse gas emissions would continue to 

be similar to long-term impacts; they would be a small fraction of the overall level in the 

United States. 

ES.16.1.6 Geology and Soils 

Short-Term Storage. Impacts would be SMALL. Continued spent fuel pool operation is not 

expected to increase impacts to soil and geology. Impacts to soil from small spills and leaks 

during operation and maintenance of ISFSIs would be minor because of monitoring and 

environmental protection regulations. No new land would be disturbed for continued operation 

of spent fuel pools and ISFSIs. 

Long-Term Storage. Impacts would be SMALL. Construction, operation, and replacement of 

the DTS and ISFSI would have minimal impacts to soils on the small fraction of land committed 

for the facilities, including soil compaction, soil erosion, and potential leaks of oils, greases, and 

other construction materials. Ongoing operation and maintenance of ISFSIs and DTSs would 

not be expected to have any additional impacts above those associated with construction. No 

impacts to geology would be expected. 

Indefinite Storage. Impacts would be SMALL. Impacts would be similar to those for long-term 

storage. Replacement of ISFSIs and DTS facilities would occur on previously disturbed land 

and would minimize impacts to soils and geology. 

ES.16.1.7 Surface-Water Quality and Use 

Short-Term Storage. Impacts would be SMALL. Although unlikely, groundwater contamination 

could affect surface-water quality (see discussion in Appendix E of the GEIS). Potential impacts 

to surface-water quality and consumptive use from the continued operation of spent fuel pools 

and ISFSIs would be less than for normal plant operations. 

Greenhouse gases are gases that trap 

heat in the atmosphere. The most 

common greenhouse gases are carbon 

dioxide, methane, nitrous oxide, and 

fluorinated gases. Greenhouse gases 

contribute to global climate change. 
Executive Summary 

September 2014 xxxix 185(*௅

Long-Term Storage. Impacts would be SMALL. Potential consumptive-use and surface-water 

quality impacts from construction and operation of a DTS would be minor, and replacement of 

the DTS and ISFSI would be less intense than assumed for initial construction of these facilities. 

Indefinite Storage. Impacts would be SMALL. Impacts would be similar to those for long-term 

storage. Replacement of ISFSIs and DTS facilities once every 100 years would result in 

temporary and minimal impacts to surface-water quality and use. 

ES.16.1.8 Groundwater Quality and Use 

Short-Term Storage. Impacts would be SMALL. Groundwater use would be significantly less 

than that used during reactor operations. Continued storage of spent fuel could result in 

nonradiological and radiological impacts to groundwater quality. In the unlikely event a spent 

fuel pool leak remained undetected for a long period of time, contamination of a groundwater 

source above a regulatory limit could occur (e.g., a Maximum Contaminant Level for one or 

more radionuclides). Appendix E of the GEIS contains additional supporting analysis of the 

environmental impacts from spent fuel pool leaks. The analysis concludes that (1) there is a low 

probability of a leak of sufficient quantity and duration to affect offsite locations and (2) physical 

processes associated with radionuclide transport, site hydrologic characteristics, and 

environmental monitoring programs ensure that impacts from spent fuel pool leaks would be 

unlikely. Impacts to groundwater from continued storage in ISFSIs would be minimal because 

ISFSI storage requires minimal water and produces minimal, localized, and easy-to-remediate 

liquid effluents on or near ground surface. 

Long-Term Storage. Impacts would be SMALL. Construction of a DTS would require minimal 

groundwater use. With regard to storage facility-replacement activities, groundwater 

consumptive use and quality impacts would be similar to those for initial construction of the 

facilities, and would be minor and temporary. 

Indefinite Storage. Impacts would be SMALL. Impacts would be similar to those for long-term 

storage. Once every 100 years, groundwater would be required for demolishing and replacing 

the ISFSI and DTS facilities. Consumptive use of groundwater and water-quality impacts would 

be minor and temporary. 

ES.16.1.9 Terrestrial Resources 

Short-Term Storage. Impacts would be SMALL. Impacts associated with the operation of spent 

fuel pools would likely be bounded by the impacts analyzed in the License Renewal GEIS for 

those issues that were addressed generically in the License Renewal GEIS. For the issue of 

water-use conflicts with terrestrial resources at plants with cooling ponds or cooling towers using 

makeup water from a river, the NRC determined that the impacts from operating the spent fuel 

pool during the short-term storage timeframe would be minimal, because the water withdrawal 
Executive Summary 

185(*௅ xl September 2014 

requirements for spent fuel pool cooling are considerably lower than those for a power reactor. 

Impacts associated with operating an at-reactor ISFSI would be minimal and similar to those 

described in EAs reviewed for preparation of the GEIS (see Table 1-1). 

Long-Term Storage. Impacts would be SMALL. Construction, repackaging, and replacement 

activities for the ISFSI and DTS would have minimal impacts on terrestrial resources. Normal 

operations and replacement of DTS and ISFSI facilities would not generate significant noise, 

would not significantly affect the area available for terrestrial wildlife, and would not adversely 

impact terrestrial environments or their associated plant and animal species. 

Indefinite Storage. Impacts would be SMALL. Impacts would be similar to long-term storage 

impacts. Replacement of the ISFSI and DTS facilities would occur on land near the existing 

facilities and could be sited on previously disturbed ground and away from terrestrial species 

and habitat. 

ES.16.1.10 Aquatic Ecology 

Short-Term Storage. Impacts would be SMALL. Impacts associated with the operation of spent 

fuel pools would likely be minimal and bounded by the impacts analyzed in the License Renewal 

GEIS because of the lower withdrawal rates, lower discharge rates, and smaller thermal plume 

for a spent fuel pool compared to an operating reactor with closed-cycle cooling. Impacts from 

operation of onsite ISFSIs would be minimal because ISFSIs do not require water for cooling, 

and ground-disturbing activities would have minimal impacts on aquatic ecology. 

Long-Term Storage. Impacts would be SMALL. Construction, repackaging, and replacement 

activities for the ISFSI and DTS would have minimal impacts on aquatic resources. The ISFSI 

and DTS would not require water for cooling, would produce minimal gaseous or liquid effluents, 

and would have minimal impacts on aquatic resources. 

Indefinite Storage. Impacts would be SMALL. Activities and impacts to aquatic resources 

would be similar to those described for long-term storage, although complete repackaging would 

occur once every 100 years. Replacement of ISFSI and DTS facilities would occur on land near 

existing facilities and could be sited on previously disturbed ground and away from sensitive 

aquatic features. 

ES.16.1.11 Special Status Species and Habitat 

Short-Term Storage. If continued operation of an ISFSI or spent fuel pool could affect Federally 

OLVWHGVSHFLHVRUGHVLJQDWHGFULWLFDOKDELWDWDQGLIWKHFULWHULDDUHPHWLQ&)5Part 402 for 

initiation or reinitiation of (QGDQJHUHG6SHFLHV$FW(6$6HFWLRQ consultation, the NRC 

ZRXOGEHUHTXLUHGWRLQLWLDWHRUUHLQLWLDWH(6$6HFWLRQFRQVXOWDWLRQZLWKWKHNational Marine 
Executive Summary 

September 2014 xli 185(*௅

Fisheries Services (NMFS) or U.S. Fish and 

Wildlife Service (FWS). With regard to spent 

fuel pools, impacts on State-listed species and 

marine mammals would most likely be less than 

those experienced during the licensed life for 

operation of the reactor because of the smaller 

size of the spent fuel pool’s cooling system and 

lower water demands when compared to those 

of an operating reactor. With regard to dry cask 

storage of spent fuel, given the small size and 

ability to site ISFSI facilities away from sensitive 

ecological resources, the NRC concludes that 

continued storage of spent fuel in at-reactor ISFSIs would likely have minimal impacts on Statelisted species, marine mammals, migratory birds, and bald and golden eagles. 

Long-Term Storage. In addition to routine maintenance and monitoring of ISFSIs, impacts from 

the construction of a DTS and replacement of the DTS and ISFSIs on special status species 

and habitat would be minimal because of the small size of the ISFSI and DTS facilities and 

because no water is required for cooling. The NRC assumes that the ISFSI and DTS facilities 

could be sited to avoid listed species and critical habitat because of the small size of the 

construction footprint and sufficient amount of previously disturbed areas on most nuclear power 

plant sites. Therefore, the NRC concludes that construction of a DTS and the replacement of 

the DTS and ISFSI would likely have minimal impacts on State-listed species, marine mammals, 

migratory birds, and bald and golden eagles. In the unlikely situation that the continued 

operation of an ISFSI could affect Federally listed species or designated critical habitat, and if 

WKHFULWHULDDUHPHWLQ&)5Part IRULQLWLDWLRQRUUHLQLWLDWLRQRI(6$6HFWLRQFRQVXOWDWLRQ

then WKH15&ZRXOGEHUHTXLUHGWRLQLWLDWHRUUHLQLWLDWH(6$6HFWLRQFRQVXOWDWLRQZLWKWKH

NMFS or FWS. 

Indefinite Storage. Impacts from indefinite storage on State-listed species, marine mammals, 

migratory birds, and bald and golden eagles would be minimal. The same consultation and any 

associated mitigation requirements described for the long-term storage timeframe would apply 

to the construction of the DTS and replacement of the DTS and ISFSI facilities during indefinite 

storage. In the unlikely situation that the continued operation of an ISFSI could affect Federally 

OLVWHGVSHFLHVRUGHVLJQDWHGFULWLFDOKDELWDWDQGLIWKHFULWHULDDUHPHWLQ&)5Part 402 for 

initiation or rHLQLWLDWLRQRI(6$6HFWLRQFRQVXOWDWLRQWKH15&ZRXOGEHUHTXLUHGWRLQLWLDWHRU

UHLQLWLDWH(6$6HFWLRQFRQVXOWDWLRQZLWKWKH10)6RU):6

Endangered Species Act, Section 7, called 

"Interagency Cooperation," is the mechanism by 

which Federal agencies ensure that the actions 

they take, including those they fund or 

authorize, do not jeopardize the existence of 

DQ\OLVWHGVSHFLHV8QGHU6HFWLRQWKH15&

must consult with the U.S. Fish and Wildlife 

Service or National Marine Fisheries Service 

when any action the NRC carries out, funds, or 

authorizes (such as through a permit) may affect

a listed endangered or threatened species.
Executive Summary 

185(*௅ xlii September 2014 

ES.16.1.12 Historic and Cultural Resources 

Short-Term Storage. Impacts would be SMALL. Because no ground-disturbing activities are 

anticipated during the short-term storage timeframe, impacts to historic and cultural resources 

associated with continued operations and maintenance would be SMALL. 

Long-Term Storage. Impacts would be SMALL to LARGE. Impacts from continued operations 

and routine maintenance are expected to be SMALL during the long-term storage timeframe, 

similar to those described in the short-term storage timeframe. NRC authorization to construct 

and operate a DTS and to replace a specifically licensed at-reactor ISFSI and DTS would 

constitute Federal actions under NEPA and would require site-specific environmental reviews 

and compliance with the National Historic Preservation Act of 1966 (NHPA) before making a 

decision on the licensing action. For generally licensed ISFSIs, impacts could be avoided, 

minimized or mitigated if the licensee has management plans or procedures that require 

consideration of these resources prior to ground-disturbing activities. The NRC assumes that 

the replacement of the at-reactor ISFSI and DTS would be constructed on land near the existing 

facilities. As discussed below, the NRC recognizes that there is uncertainty associated with the 

degree of prior disturbance and the resources, if any, present in areas where future grounddisturbing activities (i.e., initial and replacement DTS and replacement ISFSI) could occur. The 

NRC cannot eliminate the possibility that historic and cultural resources would be affected by 

construction activities during the long-term timeframe because the initial ISFSI could be located 

within a less-disturbed area with historic and cultural resources in close proximity. Further, 

resources may be present that would not have been considered significant at the time the initial 

facilities were constructed, but could become significant in the future. Therefore, the potential 

impacts to historic and cultural resources would be SMALL to LARGE. This range takes into 

consideration routine maintenance and monitoring (i.e., no ground-disturbing activities), the 

absence or avoidance of historic and cultural resources, and potential ground-disturbing 

activities that could impact historic and cultural resources. In addition, the analysis considers 

uncertainties inherent in analyzing this resource area over long timeframes. These 

uncertainties include any future discovery of previously unknown historic and cultural resources; 

resources that gain significance within the vicinity and the viewshed (e.g., nomination of a 

historic district) due to improvements in knowledge, technology, and excavation techniques; and 

changes associated with predicting resources that future generations will consider significant. If 

construction of a DTS and replacement of the ISFSI and DTS occurs in an area with no historic 

or cultural resource present or construction occurs in previously a disturbed area that allows 

avoidance of historic and cultural resources then impacts would be SMALL. By contrast, a 

MODERATE or LARGE impact could result if historic and cultural resources are present at a 

site and, because they cannot be avoided, are impacted by ground-disturbing activities during 

the long-term timeframe. 
Executive Summary 

September 2014 xliii 185(*௅

Indefinite Storage. Impacts would be SMALL to LARGE. Impacts regarding the replacement of 

the ISFSI and DTS would be similar to those described in the long-term storage timeframe. The 

NRC assumes that replacement at-reactor ISFSI and DTS would be constructed on land near 

the existing facilities. As stated in Section 1.8, the NRC assumes that the land where the 

original facilities were constructed will be available for replacement facility construction; 

however, the NRC cannot eliminate the possibility that historic and cultural resources would be 

affected by construction activities during the indefinite timeframe because the initial and 

replacement ISFSIs and DTS could be located within a less disturbed area with historic and 

cultural resources in close proximity. Further, resources may be present that would not have 

been considered significant at the time the initial or replacement facilities were constructed, but 

could become significant in the future. Impacts to historic and cultural resources would be 

SMALL to LARGE. This range takes into consideration routine maintenance and monitoring 

(i.e., no ground-disturbing activities), the absence or avoidance of historic and cultural 

resources, and potential ground-disturbing activities that could impact historic and cultural 

resources. The analysis also considers the uncertainties inherent in analyzing this resource 

area over long timeframes. These uncertainties include any future discovery of previously 

unknown historic and cultural resources; resources that gain significance within the vicinity and 

the viewshed (e.g., nomination of a historic district) due to improvements in knowledge, 

technology, and excavation techniques, and changes associated with predicting resources that 

future generations will consider significant. If construction of a DTS and replacement of the 

ISFSI and DTS occurs in an area with no historic or cultural resource present or construction 

occurs in previously a disturbed area that allows avoidance of historic and cultural resources 

then impacts would be SMALL. By contrast, a MODERATE or LARGE impact could result if 

historic and cultural resources are present at a site and, because they cannot be avoided, are 

impacted by ground-disturbing activities during the indefinite timeframe. 

ES.16.1.13 Noise 

Short-Term Storage. Impacts would be SMALL. Spent fuel pool and dry cask storage noise 

levels, noise duration, and distance between noise sources and receptors would generally not 

be expected to produce noise impacts noticeable to the surrounding community. 

Long-Term Storage. Impacts would be SMALL. Construction of the DTS and replacement of 

the DTS and ISFSI, although temporary and representing a small portion of the overall time 

period for spent fuel storage, would generate noise levels that exceed EPA-recommended noise 

levels. Noise from dry cask storage operations would be infrequent and at lower levels than for 

construction or replacement activities. Generally, for spent fuel storage, the noise levels, noise 

duration, and distance between the noise sources and receptors would not be expected to 

produce noise impacts noticeable to the surrounding community. 
Executive Summary 

185(*௅ xliv September 2014 

Indefinite Storage. Impacts would be SMALL. Most noise would be generated by construction 

equipment associated with the replacement of the ISFSI and DTS facilities; impacts would be 

similar to those during the long-term storage timeframe. 

ES.16.1.14 Aesthetics 

Short-Term Storage. Impacts would be SMALL. No changes to the visual profile are likely to 

occur as a result of the continued operation and maintenance of the existing spent fuel pool and 

at-reactor ISFSI. 

Long-Term Storage. Impacts would be SMALL. Periodic construction, replacement, and 

operation activities would not significantly alter the landscape of an ISFSI. 

Indefinite Storage. Impacts would be SMALL. Impacts would be similar to long-term storage 

and would not significantly alter the landscape of an ISFSI. 

ES.16.1.15 Waste Management 

Short-Term Storage. Impacts would be SMALL. Continued at-reactor storage of spent fuel 

would generate much less low-level, mixed, and nonradioactive waste than an operating facility, 

and licensees would continue to implement Federal and State regulations and requirements 

regarding proper management and disposal of wastes. 

Long-Term Storage. Impacts would be SMALL. 

The replacement of the ISFSI, repackaging of spent 

fuel canisters, and construction, operation, and 

replacement of the DTS would generate a fraction of 

the low-level waste (LLW) generated during reactor 

decommissioning, and LLW would continue to be 

managed according to Federal and State 

regulations. The quantity of mixed waste generated 

from long-term storage would be a small fraction of 

that generated during the licensed life of the reactor. 

Although large amounts of nonradioactive waste 

would be generated by replacement of dry cask 

storage facilities, it would still be less than the waste 

generated during reactor decommissioning and 

would not likely have a noticeable impact on local or regional landfill capacity and operations. 

Indefinite Storage. Impacts would be SMALL to MODERATE. It is expected that sufficient LLW 

disposal capacity would be made available when needed. A relatively small quantity of mixed 

waste would be generated from indefinite storage and proper management and disposal 

Low-level waste is a general term for a 

wide range of items that have become 

contaminated with radioactive material or 

have become radioactive through exposure 

to neutron radiation. The radioactivity in 

these wastes can range from just above 

natural background levels to much higher 

levels, such as seen in parts from inside the 

reactor vessel in a nuclear power reactor. 

Mixed waste contains two components: 

low-level radioactive waste and hazardous 

waste, as defined in EPA regulations. 
Executive Summary 

September 2014 xlv 185(*௅

regulations would be followed. The amount of nonradioactive waste that would be generated 

and impacts to nonradioactive waste landfill capacity are difficult to accurately estimate for the 

indefinite storage timeframe and therefore could result in SMALL to MODERATE impacts. 

ES.16.1.16 Transportation 

Short-Term Storage. Impacts would be SMALL. A low volume of traffic and shipping activities 

is expected with the continued storage of spent fuel in spent fuel pools and at-reactor ISFSIs. 

Long-Term Storage. Impacts would be SMALL. There would be small workforce requirements 

for continued storage and aging management activities (relative to the power plant workforce) 

and a low frequency of supply shipments and shipments of LLW from DTS activities, continued 

dry cask storage operations, and ISFSI and DTS replacement activities. 

Indefinite Storage. Impacts would be SMALL. There would be no significant changes to the 

annual magnitude of traffic or waste shipments that were identified for long-term storage. 

ES.16.1.17 Public and Occupational Health 

Short-Term Storage. Impacts would be SMALL. Annual 

public and occupational doses would be maintained below 

the annual dose limits established by 10 CFR Part IRU

the public and 10 CFR Part 20 for occupational personnel. 

Licensed facilities would also be required by the above 

regulations to maintain an as-low-as-is-reasonablyachievable (ALARA) program, which would likely reduce 

the doses even further. Appendix E of the GEIS provides additional information to support the 

environmental impact determination with respect to leaks from spent fuel pools on public health. 

Public health regulatory limits could be exceeded in the unlikely event a spent fuel pool leak 

remained undetected for a long period of time. Preventive maintenance activities would be 

conducted in accordance with Occupational Safety and Health Agency requirements and risks 

to occupational health and safety would be infrequent and minor. 

Long-Term Storage. Impacts would be SMALL. 

Public and occupational doses would be maintained 

well below the dose limits established by 10 CFR Part 

IRUWKHSXEOLFDQG&)53DUWIRURFFXSDWLRQDO

personnel. Licensed facilities would also be required 

by these regulations to maintain an ALARA program 

to ensure radiation doses are maintained as low as is 

ALARA is an acronym for "as low as 

(is) reasonably achievable," which 

means making every reasonable 

effort to maintain exposures to 

ionizing radiation as far below the 

dose limits as practical.

10 CFR Part 20 contains the NRC’s 

radiation protection regulations. 

10 CFR Part 72 contains the NRC’s 

regulations for licensing storage facilities 

for spent fuel and other radioactive waste.
Executive Summary 

185(*௅ xlvi September 2014 

reasonably achievable. Construction activities for the DTS would be conducted in accordance 

with Occupational Safety and Health Agency requirements, and once in operation, ISFSI 

preventive maintenance would be infrequent and minor. 

Indefinite Storage. Impacts would be SMALL. Impacts to public and occupation health are 

expected to be similar to those from long-term spent fuel storage activities. 

ES.16.1.18 Environmental Impacts of Postulated Accidents 

Because the accident risks for spent fuel pool storage only apply during the short-term 

timeframe and the accident risks for dry cask storage are substantially the same across the 

three timeframes, the GEIS does not present the various accident types by timeframe, but 

rather by accident type (i.e., design basis and severe) and storage facility type (i.e., spent fuel 

pool and dry cask storage system).

Design Basis Accidents in Spent Fuel Pools. Impacts 

would be SMALL. The postulated design basis 

accidents considered in this GEIS for spent fuel pools 

include hazards from natural phenomena, such as 

earthquakes, floods, tornadoes, and hurricanes; hazards 

from activities in the nearby facilities; and fuel handlingrelated accidents. In addition, potential effects of climate 

change are also considered. Based on the assessment 

in Section 4.18, the environmental impacts of these postulated accidents involving continued 

storage of spent fuel in pools are SMALL because all important safety structures, systems, and 

components involved with the spent fuel storage are designed to withstand these design basis 

accidents without compromising the safety functions. 

Design Basis Accidents in Dry Cask Storage Systems and Dry Transfer Systems. Impacts 

would be SMALL. All NRC-licensed dry cask storage systems are designed to withstand all 

postulated design basis accidents without any loss of safety functions. A DTS or a facility with 

equivalent capabilities may be needed to enable retrieval of spent 

fuel for inspection or repackaging. Licensees of DTS facilities are 

required to design the facilities so that all safety-related structures, 

systems, and components can withstand the design basis accidents 

without compromising any safety functions. Based on the 

assessment, the environmental impact of the design basis accidents 

is SMALL because safety-related structures, systems, and 

components are designed to function in case of these accidents. 

Severe Accidents in Spent Fuel Pools. Probability-weighted impacts would be SMALL. A spent 

fuel pool may encounter severe events, such as loss of offsite power or beyond design basis 

earthquakes. Although it is theoretically possible that these events may lead to loss of spent 

A design basis accident is a 

postulated accident that a nuclear 

facility must be designed and built to 

withstand without loss to the systems, 

structures, and components necessary 

to ensure public health and safety.

A severe accident is a 

type of accident that may 

challenge safety systems 

at a level much higher 

than expected.
Executive Summary 

September 2014 xlvii 185(*௅

fuel pool cooling function resulting in a spent fuel pool fire, the likelihood of such events is 

extremely small. Additional discussion about spent fuel pool fires can be found in Appendix F. 

Severe Accidents in Dry Cask Storage Systems. Probability-weighted impacts would be 

SMALL. Although some handling accidents such as a postulated drop of a canister could 

exceed NRC’s public dose standards, the likelihood of the event is very low. Therefore, the 

environmental impact of severe accidents in a dry storage facility is SMALL. 

ES.16.1.19 Potential Acts of Sabotage or Terrorism 

Although the NRC believes that NEPA does not require such an analysis and that it is only 

required for facilities within the Ninth Circuit, the NRC finds that even though the environmental 

consequences of a successful attack on a spent fuel pool beyond the licensed life for operation 

of a reactor are large, the very low probability of a successful attack ensures that the 

environmental risk is SMALL. Similarly, for an operational ISFSI or DTS during continued 

storage, the NRC finds that the environmental risk of a successful radiological sabotage attack 

is SMALL. 

Table ES-3. Summary of Environmental Impacts of Continued At-Reactor Storage 

Resource Area Short-Term Storage Long-Term Storage Indefinite Storage 

Land Use SMALL SMALL SMALL 

Socioeconomics SMALL SMALL SMALL 

Environmental Justice Disproportionately high and adverse impacts are not expected. 

Air Quality SMALL SMALL SMALL 

Climate Change SMALL SMALL SMALL 

Geology and Soils SMALL SMALL SMALL 

Surface Water 

 Quality SMALL SMALL SMALL 

 Consumptive Use SMALL SMALL SMALL 

Groundwater 

 Quality SMALL SMALL SMALL 

 Consumptive Use SMALL SMALL SMALL 

Terrestrial Resources SMALL SMALL SMALL 

Aquatic Ecology SMALL SMALL SMALL 

Special Status Species 

and Habitat 

Impacts for Federally listed threatened and endangered species and 

Essential Fish Habitat would be determined as part of the consultations 

for the ESA and the Magnuson–Stevens Fishery Conservation and 

Management Act. 
Executive Summary 

185(*௅ xlviii September 2014 

Table ES-3. Summary of Environmental Impacts of Continued At-Reactor Storage (cont’d) 

Resource Area Short-Term Storage Long-Term Storage Indefinite Storage 

Historic and Cultural 

Resources SMALL SMALL to LARGE SMALL to LARGE 

Noise SMALL SMALL SMALL 

Aesthetics SMALL SMALL SMALL 

Waste Management 

 Low-Level Waste SMALL SMALL SMALL 

 Mixed Waste SMALL SMALL SMALL 

 Nonradioactive Waste SMALL SMALL SMALL to MODERATE 

Transportation SMALL SMALL SMALL 

Public and Occupational 

Health SMALL SMALL SMALL 

Accidents SMALL SMALL SMALL 

Sabotage or Terrorism SMALL SMALL SMALL 

ES.16.2 Environmental Impacts of Away-From-Reactor Spent Fuel Storage 

No away-from-reactor ISFSIs of the size considered in ChapWHU metric tons uranium) 

have been constructed in the United States. For the analysis of environmental impacts in 

&KDSWHU, the NRC assumes that construction and operation of an away-from-reactor ISFSI 

would be similar to that proposed for the Private Fuel Storage Facility on the Reservation of the 

Skull Valley Band of Goshute Indians in Tooele County, Utah. The NRC previously analyzed 

the environmental impacts of constructing and operating the Private Fuel Storage Facility in 

NUREG௅ For the analysis of continued storage at an away-from-reactor ISFSI, the term 

ISFSI refers to all of the original facilities that would be built (i.e., storage pads, casks, and 

canister transfer building). 

ES.16.2.1 Land Use 

Short-Term Storage. Impacts would be SMALL. Construction of an ISFSI would change the 

nature of land use within the site boundary and along access corridors. While this change could 

be qualitatively substantial (e.g., from agricultural to industrial), the land parcel is assumed to be 

sufficiently remote and small that no quantitatively significant impact would occur. 

Long-Term Storage. Impacts would be SMALL. Construction of a DTS would disturb a small 

portion of the land committed for an away-from-reactor storage facility. To minimize land-use 

impacts from replacement of the ISFSI and DTS facilities, the replacement facilities would likely 

be constructed on land near the existing facilities, and the old facilities would likely be 

demolished and the land reclaimed. 
Executive Summary 

September 2014 xlix 185(*௅

Indefinite Storage. Impacts would be SMALL. Only a small portion of the total land committed 

for development of an away-from-reactor ISFSI is required to support continued operations, 

including periodic maintenance or replacement of equipment and repackaging of fuel. 

Replacement of the away-from-reactor ISFSI and DTS every 100 years would likely occur on 

land near the existing facilities. 

ES.16.2.2 Socioeconomics 

Short-Term Storage. Adverse impacts would be SMALL. Based on the small workforce 

required for construction and operations of an away-from-reactor facility, and any associated 

indirect impacts to public services and housing, the impacts of construction and operation of a 

storage facility on those resources would be minor. Beneficial impacts to the economy could be 

LARGE in some rural economies. 

Long-Term Storage. Adverse impacts would be SMALL. Construction of a DTS would require a 

workforce smaller than the workforce required for construction of an away-from-reactor ISFSI. 

The labor force required for maintenance and replacement activities of an ISFSI and DTS would 

not be expected to exceed the labor force required for construction of the storage facility as a 

whole. Beneficial impacts to the economy could be LARGE in some rural economies. 

Indefinite Storage. Adverse impacts would be SMALL. If no repository becomes available, 

operational and replacement activities would continue, beneficial impacts to the economy could 

be LARGE in some rural economies. 

ES.16.2.3 Environmental Justice 

Short-Term Storage. The process of siting an away-from-reactor ISFSI would be expected to 

ensure that environmental justice concerns are addressed prior to licensing. Overall human 

health and environmental effects from construction of the ISFSI and from continued storage 

during the short-term timeframe would be limited in scope and SMALL for all populations, 

except for air quality, terrestrial resources, aesthetics, historic and cultural resources, and 

socioeconomic and traffic conditions. Minority and low-income populations are not expected to 

experience disproportionately high and adverse human health and environmental effects from 

the construction and operation of an away-from-reactor ISFSI. Should the NRC receive an 

application for a proposed away-from-reactor ISFSI, a site-specific NEPA analysis would be 

conducted, and that analysis would include consideration of environmental justice impacts. 

Long-Term Storage. The impacts from constructing the DTS within the ISFSI protected area 

would be within the envelope of impacts from the construction of the away-from-reactor ISFSI. 

Overall human health and environmental effects of storing spent fuel during the long-term 

timeframe would be limited in scope and SMALL for all populations, except for aesthetics, 

historic and cultural resources, socioeconomic, and traffic conditions. Given the passive nature 

of storage operations, the short amount of time required for DTS construction and replacement 
Executive Summary 

185(*௅ l September 2014 

of the ISFSI and DTS and the ongoing monitoring and maintenance, minority and low-income 

populations are not expected to be experience disproportionately high and adverse human 

health and environmental impacts. 

Indefinite Storage. Overall human health and environmental effects of storing spent fuel during 

the indefinite timeframe would be the same as those described for long-term storage, except for 

nonradioactive waste generation and disposal. Based on this information, minority and lowincome populations are not expected to experience disproportionately high and adverse human 

health and environmental effects from the operation and replacement of the ISFSI and DTS. 

ES.16.2.4 Air Quality 

Short-Term Storage. Impacts would be SMALL to MODERATE. Construction of an away-fromreactor ISFSI would result in minimal emissions, but construction of the rail spur could produce 

temporary and localized impacts that would be noticeable. ISFSI operations generate minor 

levels of air emissions but not enough to be classified as a “major stationary source” of 

emissions as defined in Federal air quality regulations. Locomotives transporting spent fuel to 

an away-from-reactor ISFSI would emit exhaust pollutants in a distributed manner along the 

transport route. 

Long-Term Storage. Impacts would be SMALL. Operational activities are expected to be of 

relatively short duration and limited in extent. The DTS is a relatively small facility, and the air 

quality impacts associated with construction would be less than those associated with the 

original construction of the ISFSI. Replacement of the DTS and ISFSI and maintenance of the 

rail spur would involve only a fraction of the air emissions associated with initial construction of 

an ISFSI. Exhaust from vehicles would not be expected to noticeably affect air quality for the 

region. 

Indefinite Storage. Impacts would be SMALL. Indefinite storage would consist of the same 

short-duration and limited-extent activities and would result in the same impact magnitudes as 

described for long-term storage except that they would continue indefinitely into the future. 

ES.16.2.5 Climate Change 

Short-Term Storage. Impacts would be SMALL. Average annual greenhouse gas 

emissions associated with building and operating an ISFSI as well as transportation 

(e.g., commuters, supplies, waste materials, and spent fuel) would be equivalent to the 

annual emissions from about 1,640 passenger vehicles. 

Long-Term Storage. Impacts would be SMALL. Construction of a DTS, replacement of dry 

casks and pads, and maintenance activities would likely involve only a fraction of the 

greenhouse gas emissions associated with the original construction of the ISFSI. 
Executive Summary 

September 2014 li 185(*௅

Indefinite Storage. Impacts would be SMALL. Greenhouse gas emissions would continue to be 

similar to long-term impacts. 

ES.16.2.6 Geology and Soils 

Short-Term Storage. Impacts would be SMALL. The land required to construct an ISFSI would 

be relatively small, and soil erosion controls would minimize impacts. 

Long-Term Storage. Impacts would be SMALL. Construction of a DTS would have minimal 

impacts to geology and soil because of the small size of the facility. Replacement of the ISFSI 

pads and supporting facilities would likely occur on land near the existing facilities. The old 

facilities would likely be demolished, and the land would likely be reclaimed. 

Indefinite Storage. Impacts would be similar to long-term storage, SMALL. Replacement of 

ISFSI and DTS facilities would occur on previously disturbed land and would minimize impacts 

to soils and geology. 

ES.16.2.7 Surface-Water Quality and Use 

Short-Term Storage. Impacts would be SMALL. Best management practices would be 

implemented during construction of an ISFSI to address stormwater flows, soil erosion, and 

siltation. Stormwater control measures would be required to comply with State-enforced waterquality permits. Construction and operation of an ISFSI would require very little consumptive 

use of water. 

Long-Term Storage. Impacts would be SMALL. Given the relatively smaller size of a DTS as 

compared to an ISFSI, much less water would be required to build a DTS. Consumptive use 

and surface-water quality impacts would be no greater than those identified for initial 

construction of the storage facilities. 

Indefinite Storage. Impacts would be SMALL. Impacts would be similar to those for long-term 

storage. Replacement of ISFSIs and DTS facilities once every 100 years would result in 

temporary and minimal impacts to surface-water quality and use. 

ES.16.2.8 Groundwater Quality and Use 

Short-Term Storage. Impacts would be SMALL. Methods necessary to control impacts to 

groundwater quality during construction and operation of an ISFSI are well understood and 

State-issued permits typically require the implementation of such controls. Construction and 

operation of an ISFSI would require very little consumptive use of water. 

Long-Term Storage. Impacts would be SMALL. Impacts on groundwater from a DTS would be 

no larger than those considered for construction of the ISFSI. Likewise, the impacts of replacing 

portions of the ISFSI over time would be no more than the impacts of the initial construction of 

the facility, and would likely occur over a longer period of time. 
Executive Summary 

185(*௅ lii September 2014 

Indefinite Storage. Impacts would be SMALL. Impacts would be similar to those for long-term 

storage. Once every 100 years, groundwater may be required when demolishing and replacing 

the ISFSI and DTS facilities. Consumptive use of groundwater and water-quality impacts would 

be minor. 

ES.16.2.9 Terrestrial Resources 

Short-Term Storage. Impacts would be SMALL to MODERATE. Land area permanently 

disturbed for construction of an away-from-reactor dry cask storage facility would be relatively 

small, and any impacts to wetlands would be addressed under the Clean Water Act. However, 

construction could have some noticeable impacts to terrestrial resources, such as habitat loss, 

displacement of wildlife, and incremental habitat fragmentation. ISFSI operations would have 

minimal impacts on terrestrial resources. 

Long-Term Storage. Impacts would be SMALL. Impacts from construction of a DTS would be 

significantly less than those impacts expected from construction and operation of an ISFSI. 

Because of its relatively small construction footprint, the DTS could be sited on previously 

disturbed ground and away from sensitive terrestrial resources. Impacts from operational 

activities would be minor. Replacement activities would occur once about every 100 years, and 

would likely occur near existing facilities. 

Indefinite Storage. Impacts would be SMALL. Replacement activities are not expected to add 

additional impacts beyond those impacts expected for initial construction of the away-fromreactor ISFSI and DTS. Operation of away-from reactor ISFSIs would not require any additional 

land use beyond that set aside for original construction of the facility. 

ES.16.2.10 Aquatic Ecology 

Short-Term Storage. Impacts would be SMALL. Construction and operation of an away-fromreactor ISFSI would require limited water supplies, and effluents, if any, would be limited to 

stormwater and treated wastewater. Impacts to aquatic resources would tend to be limited by 

certain factors, including the land area permanently disturbed would be relatively small; water 

use for the construction and operation of the site would be limited; and any impacts from 

discharges to water bodies would need to be addressed under the Clean Water Act, which 

requires licensees to obtain a National Pollutant Discharge Elimination System permit for any 

discharges to water bodies. 

Long-Term Storage. Impacts would be SMALL. Building a DTS, and transferring, handling, and 

aging management of spent fuel at an away-from-reactor ISFSI could result in ground-disturbing 

activities that would have impacts similar to or less than impacts associated with the original 

construction of the ISFSI. Replacement activities would likely occur near existing facilities, and 

aquatic disturbances would result in relatively short-term impacts and aquatic environs would 

recover naturally. 
Executive Summary 

September 2014 liii 185(*௅

Indefinite Storage. Impacts would be SMALL. Activities associated with demolishing old 

facilities and building replacement facilities about once every 100 years could result in minimal, 

short-term impacts to aquatic resources. Impacts associated with ISFSI operation and 

maintenance would also be small. 

ES.16.2.11 Special Status Species and Habitat 

Short-Term Storage. Impacts from the initial construction and ongoing operation and 

maintenance of dry cask storage facilities to State-listed species, marine mammals, migratory 

birds, and bald and golden eagles would range from minimal to noticeable, which would be 

similar to those described for terrestrial and aquatic resources, with any noticeable impacts 

resulting from the construction of the ISFSI. An away-from-reactor ISFSI could be sited to avoid 

adversely affecting special status species and habitat. The NRC would assess the impacts to 

Federally listed species and designated critical habitat from an away-from-reactor ISFSI and 

DTS in a site-specific review before the facility is initially constructed and afterwards if an activity 

PHHWVWKHFULWHULDLQ&)5IRULQLWLDWLRQRUUHLQLWLDWLRQRI6HFWLRQFRQVXOWDWLRQ

Long-Term Storage. During the long-term storage timeframe, initial construction of the DTS and 

replacement of the casks, pads, and the DTS would result in impacts that would be less than 

initial construction impacts because replacement activities would occur within the facility’s 

operational area near existing facilities. The NRC would assess the impacts to Federally listed 

species and designated critical habitat from an away-from-reactor ISFSI and DTS in a sitespecific review before the facility is initially constructed and afterwards if an activity meets the 

FULWHULDLQ&)5Part 402 for initiation or reinitiDWLRQRI6HFWLRQFRQVXOWDWLRQ

Indefinite Storage. Impacts to special status species and habitat from continued operation of 

away-from-reactor ISFSIs if a repository never becomes available would be similar to those 

described for the long-term storage timeframe. The same operations and maintenance 

activities would occur repeatedly because the spent fuel remains at the facility indefinitely. The 

NRC would assess the impacts to Federally listed species and designated critical habitat from 

an away-from-reactor ISFSI and DTS in a site-specific review before the facility is initially 

FRQVWUXFWHGDQGDIWHUZDUGVLIDQDFWLYLW\PHHWVWKHFULWHULDLQ&)5Part 402 for initiation or 

reinitiation RI6HFWLRQFRQVXOWDWLRQ

ES.16.2.12 Historic and Cultural Resources 

Short-Term Storage. Impacts would be SMALL to 

LARGE. Impacts to historic and cultural resources would 

vary depending on what resources are present, but could 

be minimized because (1) the land area disturbed would 

be relatively small, (2) site selection and placement of 

facilities on the site could be adjusted to minimize or 

Section 106 of the National Historic 

Preservation Act of 1966 requires 

Federal agencies to take into account 

the effects of their undertakings on 

historic properties.
Executive Summary 

185(*௅ liv September 2014 

avoid impacts to historic and cultural resources because the facility does not depend on 

VLJQLILFDQWZDWHUVXSSO\DQGKDVOLPLWHGHOHFWULFDOSRZHUQHHGVDQGSRWHQWLDOimpacts could 

also be minimized through development of agreements, license conditions, and implementation 

of the licensees’ historic and cultural resource management plans and procedures to protect 

known historic and cultural resources and address inadvertent discoveries. Additionally, should 

the NRC receive an application for a proposed away-from-reactor ISFSI, the NRC would 

conduct a site-specific assessment of potential impacts to historic and cultural resources under 

Section 106 of the NHPA. Impacts from continued operations and routine maintenance during 

the short-term timeframe would be small because no ground-disturbing activities are expected; 

therefore, impacts would be SMALL. In most, but not all instances, placement of storage 

facilities on the site can be adjusted to minimize or avoid impacts on any historic and cultural 

resources in the area. However, the NRC recognizes that this is not always possible. 

Therefore, the NRC concludes that the potential impacts on historic and cultural resources could 

range from SMALL to LARGE, depending on site-specific factors. 

Long-Term Storage. Impacts would be SMALL to LARGE. Impacts from continued operations, 

routine maintenance, replacement of the facilities at an away-from-reactor ISFSI, and potential 

construction, operation, and replacement of a DTS would vary depending on what resources are 

present, proposed land disturbance, and if the licensee has management plans and procedures 

that are protective of historic and cultural resources. Additionally, the construction of a DTS and 

replacement of an ISFSI and the DTS would be Federal actions that would require the NRC to 

conduct a site-specific assessment of potential impacts to historical and cultural resources 

under Section 106 of NHPA. The NRC assumes that the replacement of the ISFSI and DTS 

would be constructed on land near the existing facilities. The NRC recognizes that there is 

uncertainty associated with the degree of prior disturbance and the resources, if any, are 

present in areas where future ground-disturbing activities could occur. The NRC cannot 

eliminate the possibility that historic and cultural resources would be affected by construction 

activities because the initial ISFSI could be located within a less-disturbed area with historic and 

cultural resources in close proximity. Further, resources may be present after initial construction 

of the away-from-reactor ISFSI that would not have been considered significant at the time the 

initial or replacement facilities were constructed, but could become significant in the future. This 

range takes into consideration routine maintenance and monitoring (i.e., no ground-disturbing 

activities), the absence or avoidance of historic and cultural resources, and potential grounddisturbing activities that impact historic and cultural resources. The analysis also considers 

uncertainties inherent in analyzing this resource over long timeframes. These uncertainties 

include any future discovery of previously unknown historic and cultural resources; resources 

that gain significance within the vicinity and the viewshed (e.g., nomination of a historic district) 

due to improvements in knowledge, technology, and excavation techniques; and changes 

associated with predicting resources that would be significant to future generations. If 

construction of a DTS and replacement of the ISFSI and DTS occurs in an area with no historic 

or cultural resource present or construction occurs in previously a disturbed area that allows 
Executive Summary 

September 2014 lv 185(*௅

avoidance of historic and cultural resources then impacts would be SMALL. By contrast, a 

MODERATE or LARGE impact could result if historic and cultural resources are present at a 

site and, because they cannot be avoided, are impacted by ground-disturbing activities during 

the long-term timeframe. 

Indefinite Storage. Impacts would be SMALL to LARGE. Impacts would be similar to those 

described for the long-term storage timeframe. The NRC assumes that the replacement of the 

ISFSI and DTS would be constructed on land near the existing facilities. As stated in Section 

1.8, the NRC assumes that the land where the original facilities were constructed will be 

available for replacement facility construction; however, the NRC cannot eliminate the possibility 

that historic and cultural resources will be affected by construction activities during the indefinite 

timeframe because there is uncertainty associated with the degree of prior disturbance and 

what resources, if any, are present in areas where future ground-disturbing activities (e.g., initial 

and replacement DTS and replacement ISFSI) could occur. Further, significant resources may 

be present that were not considered significant at the time the initial or replacement facilities 

were constructed. Potential impacts to historic and cultural resources during the indefinite 

storage timeframe would range from SMALL to LARGE. This range takes into consideration 

routine maintenance and monitoring (i.e., no ground-disturbing activities), the absence or 

avoidance of historic and cultural resources, and potential ground-disturbing activities that could 

impact historic and cultural resources. The analysis also considers uncertainties inherent in 

analyzing this resource area over long timeframes. These uncertainties include any future 

discovery of previously unknown historic and cultural resources; resources that gain significance 

within the vicinity and the viewshed (e.g., nomination of a historic district) due to improvements 

in knowledge, technology, and excavation techniques; and changes associated with predicting 

resources that future generations would consider significant. If construction of a DTS and 

replacement of the ISFSI and DTS occurs in an area with no historic or cultural resource 

present or construction occurs in previously a disturbed area that allows avoidance of historic 

and cultural resources then impacts would be SMALL. By contrast, a MODERATE or LARGE 

impact could result if historic and cultural resources are present at a site and, because they 

cannot be avoided, are impacted by ground-disturbing activities during the indefinite timeframe. 

ES.16.2.13 Noise 

Short-Term Storage. Impacts would be SMALL. Noise impacts for an away-from-reactor ISFSI 

could exceed EPA-recommended levels during some portions of construction and operation; 

however, noise impacts would be short in duration and intermittent. 

Long-Term Storage. Impacts would be SMALL. Noise impacts from continued operation and 

routine maintenance of an away-from-reactor ISFSI would be minimal. Impacts from 

construction of a DTS and replacement of the DTS and ISFSI would be similar to those for initial 

construction of an ISFSI. These construction and replacement activities would be intermittent 

and short in duration, and noticeable noise levels would be limited to the nearest receptors. 
Executive Summary 

185(*௅ lvi September 2014 

Indefinite Storage. Impacts would be SMALL. Impacts would be similar to those associated 

with the long-term storage timeframe. Ongoing operation, maintenance, and replacement 

activities would have minimal noise impacts. 

ES.16.2.14 Aesthetics 

Short-Term Storage. Impacts would be SMALL to MODERATE. Potential impacts to aesthetic 

resources would include visibility of facility buildings, dry storage pads and canisters, and the 

rail line and trains from across scenic water bodies, roadways, or from higher elevations. 

Lighting of the facility would increase visibility. If constructed in an area with no prior industrial 

development, the ISFSI could impact the local viewshed, and scenic appeal of the site would be 

noticeably changed when viewed from various locations. Impacts could be minimal if the ISFSI 

is built in a previously disturbed area. 

Long-Term Storage. Impacts would be SMALL to MODERATE. Aesthetic impacts from 

transferring and handling spent fuel and aging management activities at an away-from-reactor 

ISFSI are anticipated to be similar to the impacts for initial construction and short-term operation 

of the ISFSI. Periodic construction, demolition, and operation activities required for aging 

management would not significantly alter the pre-existing impacts on aesthetic resources. 

Indefinite Storage. Impacts would be SMALL to MODERATE. The same operations and 

maintenance activities that are described for the long-term storage timeframe occur repeatedly 

because the spent fuel remains at the facility indefinitely. 

ES.16.2.15 Waste Management 

Short-Term Storage. Impacts would be SMALL. Construction activities would generate 

excavation and construction debris, vegetation debris, and backfill. Operation of an away-fromreactor ISFSI would involve limited waste generating activities. Small quantities of LLW may be 

generated during routine operation and maintenance. Little to no mixed waste generation would 

be expected. Small quantities of nonradioactive waste would be generated. All wastes would 

be managed and disposed of according to regulatory requirements. 

Long-Term Storage. Impacts would be SMALL. Routine maintenance would generate minimal 

quantities of waste. Construction and operation of a DTS and replacement of ISFSI and DTS 

facilities at an away-from-reactor ISFSI would generate LLW and nonradioactive waste. 

Although the exact amount of LLW and nonradioactive waste depends on the level of 

contamination, the quantity of LLW generated from the replacement of the ISFSI and DTS is 

expected to be comparable to the LLW generated during reactor decommissioning, which was 

determined to have a SMALL impact in the License Renewal GEIS. Although a large amount of 

nonradioactive waste would be generated by replacement of the ISFSI and DTS, it would not 

likely have a noticeable impact on total nonradioactive waste disposal capacity. 
Executive Summary 

September 2014 lvii 185(*௅

Indefinite Storage. Impacts would be SMALL to MODERATE. LLW, mixed waste, and 

nonradioactive waste would continue to be generated indefinitely, and there could be noticeable 

impacts on the local and regional landfill capacity for nonradioactive waste disposal. 

ES.16.2.16 Transportation 

Short-Term Storage. Impacts would be SMALL to 

MODERATE. The environmental impacts of 

transportation include impacts to regional traffic from 

commuting workers, supply shipments, shipments of 

spent fuel to the ISFSI, and shipments of nonradioactive 

and radiological waste. Impacts to traffic from workers 

commuting to and from the away-from-reactor storage 

site depend on the size of the workforce, the capacity of 

the local road network, traffic patterns, and the availability 

of alternative commuting routes to and from the facility. 

The majority of impacts would be associated with the 

traffic during the initial construction of the ISFSI. 

Shipment of spent fuel from nuclear power plants to the 

ISFSI would be required to comply with NRC and the U.S. Department of Transportation 

regulations. Radiological impacts to the public and workers from spent fuel shipments from a 

reactor have previously been evaluated by the NRC (in Table S-4 of 10 &)52) and were 

found to be small. 

Long-Term Storage. Impacts would be SMALL to MODERATE. Construction of a DTS would 

require a smaller workforce than the initial construction of the ISFSI, so transportation impacts 

from workers commuting would be less, but may still be noticeable. Shipments of LLW 

generated by maintenance and replacement activities would be regulated by NRC and 

Department of Transportation requirements and impacts to traffic and to public and worker 

radiological and nonradiological safety would be minimal. 

Indefinite Storage. Impacts would be SMALL to MODERATE. Annual transportation activities 

and associated environmental impacts would be similar to that analyzed for the long-term 

storage timeframe. 

ES.16.2.17 Public and Occupational Health 

Short-Term Storage. Impacts would be SMALL. Nonradiological health impacts from the 

construction of an away-from-reactor ISFSI include normal hazards associated with 

construction, such as pollutants (e.g., dust), and fatal and nonfatal occupational injuries (e.g., 

falls and overexertion). Impacts would be minor and similar to an industrial facility of similar 

size. Public and occupation radiological doses would be maintained significantly below the 

Table S௅4 in 10 CFR 51.52

summarizes the environmental 

impacts of transportation of fuel and 

waste to and from a nuclear power 

plant. Data supporting the 

determinations in Table S௅4 is 

contained in the NRC’s Environmental 

Survey of Transportation of 

Radioactive Materials to and from 

Nuclear Power Plants, WASH௅

'HFHPEHUDQG6XSS

NUREG௅$SULO
Executive Summary 

185(*௅ lviii September 2014 

GRVHOLPLWVHVWDEOLVKHGE\&)53DUWDQG&)53DUW/LFHQVHGIDFLOLWLHVZRXOGDOVR

be required by those regulations to maintain an ALARA program, which would likely reduce the 

doses even further. 

Long-Term Storage. Impacts would be SMALL. Nonradiological health impacts associated with 

replacement activities would be similar those for the original construction of the facility, although 

replacement activities would take place over a longer period of time. Public and occupational 

radiological doses would be maintained significantly below the dose limits established by 

10 &)53DUWDQG&)53DUWIn addition, the dry cask storage facility would be required 

to maintain an ALARA program that would likely further reduce radiological doses. Operation of 

the DTS would involve increased doses to works and a very small increase in dose levels at the 

site boundary; however, the licensee would still be required to comply with regulations limiting 

dose. 

Indefinite Storage. Impacts would be SMALL. For the indefinite storage timeframe, the types of 

activities (construction, operation, and replacement) and associated health impacts would 

remain the same as those for the long-term storage timeframe. 

ES.16.2.18 Environmental Impacts of Postulated Accidents 

Impacts would be SMALL. Consideration of accidents at an away-from-reactor ISFSI for all 

three storage timeframes is similar to those for at-reactor ISFSIs (described in Chapter 4). The 

postulated accident analysis in the GEIS is applicable for all three timeframes (short-term, longterm, and indefinite). The 15&UHJXODWLRQVLQ&)53DUWUHTXLUHWKDWVWUXFWXUHVV\VWHPV

and components important to safety will be designed to withstand the effects of natural 

phenomena (such as earthquakes, tornadoes, and hurricanes) and human-induced events 

without loss of capability to perform those safety functions. The NRC siting regulations also 

require applicants to take into consideration, among other things, physical characteristics of 

sites that are necessary for the safety analysis or that may have an impact on plant design 

(such as the design basis earthquake). All these factors are considered in determining the 

acceptability of the site and design criteria of a proposed dry cask storage facility. The GEIS 

analysis considered an accident scenario in which wind-borne missiles damage the concrete 

overpack of a dry cask. This accident would result in only slightly higher occupational doses 

and only negligible increases in radiological doses at the boundary of the site. The analysis 

also considered an accident resulting in a dry cask leaking, and determined that radiological 

doses would still be below the limits in 10 CFR Part 20 and &)53DUW

ES.16.2.19 Potential Acts of Sabotage or Terrorism 

The consideration of acts of sabotage or terrorism at an away-from-reactor ISFSI for all three 

storage timeframes are similar to those for at-reactor ISFSIs (described in Chapter 4). The 
Executive Summary 

September 2014 lix 185(*௅

probability and consequences of a successful attack on an away-from-reactor ISFSI or DTS are 

low; therefore, the environmental risk is SMALL. 

Table ES-4. Summary of Environmental Impacts of Away-From-Reactor Spent Fuel Storage 

Resource Area 

Short-Term 

Storage 

Long-Term 

Storage 

Indefinite 

Storage 

Land Use SMALL SMALL SMALL 

Socioeconomics SMALL (adverse) to 

LARGE (beneficial) 

SMALL (adverse) to 

LARGE (beneficial) 

SMALL (adverse) to 

LARGE (beneficial) 

Environmental Justice Disproportionately high and adverse impacts are not expected. 

Air Quality SMALL to MODERATE SMALL SMALL 

Climate Change SMALL SMALL SMALL 

Geology and Soils SMALL SMALL SMALL 

Surface-Water Quality and Use SMALL SMALL SMALL 

Groundwater Quality and Use SMALL SMALL SMALL 

Terrestrial Resources SMALL to MODERATE SMALL SMALL 

Aquatic Ecology SMALL SMALL SMALL 

Special Status Species and 

Habitat 

Impacts for Federally listed threatened and endangered species and 

Essential Fish Habitat would be determined as part of the consultations 

for the ESA and the Magnuson–Stevens Fishery Conservation and 

Management Act. 

Historic and Cultural Resources SMALL to LARGE SMALL to LARGE SMALL to LARGE

Noise SMALL SMALL SMALL

Aesthetics SMALL to MODERATE SMALL to 

MODERATE 

SMALL to MODERATE 

Waste Management 

 Low-Level Waste SMALL SMALL SMALL 

 Mixed Waste SMALL SMALL SMALL 

 Nonradioactive Waste SMALL SMALL SMALL to MODERATE 

Transportation 

 Traffic SMALL to MODERATE SMALL to 

MODERATE 

SMALL to MODERATE 

 Health SMALL SMALL SMALL 

Public and Occupational Health SMALL SMALL SMALL 

Accidents SMALL SMALL SMALL 

Sabotage or Terrorism SMALL SMALL SMALL 
Executive Summary 

185(*௅ lx September 2014 

ES.17 Did the NRC Look at Cumulative Impacts? 

In Chapter 6, the NRC examined the incremental 

impact of continued storage on each resource area in 

combination with other past, present, and reasonably 

foreseeable actions. The introductory sections of 

Chapter 6 discuss the NRC's methodology for 

assessing cumulative impacts, including the spatial and temporal bounds on which the NRC 

based its analyses, and provide a table that describes national, regional, and local trends that 

informed the NRC’s consideration of reasonably foreseeable future actions. Trends that the 

NRC examined include increased energy demand, continued use of radiological materials, 

increased water demand, population growth and demographic shifts, increased urbanization, 

transportation, and other activities and environmental stressors. The spatial boundaries for the 

cumulative impact assessment are unique to each resource area and defined in resourcespecific analyses in Section 6.4. Each geographic area of analysis includes the area 

surrounding a single continued storage site and extends to where the resource would be 

affected by continued storage and could have overlapping impacts with other past, present, and 

reasonably foreseeable future actions. The temporal boundary for the cumulative effects 

analysis includes activities that could occur through decommissioning of at-reactor or awayfrom-reactor storage facilities. 

Table ES-SURYLGHVDVXPPDU\RIWKHGHWHUPLQDWLRQVPDGHLQ&KDSWHU7KHVHFRQGDQG

WKLUGFROXPQVOLVWUHVRXUFHLPSDFWGHWHUPLQDWLRQVPDGHLQ&KDSWHUVDQG7hese impacts are 

combined with the past, present, and reasonably foreseeable actions discussed in Chapter 6. 

The last column lists the cumulative impacts to resource areas. Discussions about impact 

differences resulting from cumulative effects can be found in Chapter 6. 

Table ES-5. Summary of Cumulative Impacts for Continued Storage of Spent Fuel 

Resource Area 

Incremental 

Impact from AtReactor Storage 

Incremental Impact 

from Away-fromReactor Storage 

Cumulative Impact from 

Continued Storage and 

Other Federal and NonFederal Activities 

Land Use SMALL SMALL SMALL to MODERATE 

Socioeconomics SMALL SMALL (adverse) to 

LARGE (beneficial) 

SMALL to LARGE 

Environmental Justice Disproportionately high and adverse impacts are not expected 

Air Quality SMALL SMALL to MODERATE SMALL to MODERATE 

Climate Change SMALL SMALL MODERATE 

Geology and Soils SMALL SMALL SMALL to MODERATE 

Surface-Water Quality and Use SMALL SMALL SMALL to LARGE 

Cumulative impacts result when the 

effects of an action are added to or 

interact with other effects in a particular 

place and within a particular time.
Executive Summary 

September 2014 lxi 185(*௅

Table ES-5. Summary of Cumulative Impacts for Continued Storage of Spent Fuel (cont’d) 

Resource Area 

Incremental 

Impact from AtReactor Storage 

Incremental Impact 

from Away-fromReactor Storage 

Cumulative Impact from 

Continued Storage and 

Other Federal and NonFederal Activities 

Groundwater Quality and Use SMALL SMALL SMALL to LARGE 

Terrestrial Resources(a) SMALL SMALL to MODERATE SMALL to MODERATE 

Aquatic Ecology(a) SMALL SMALL SMALL to LARGE 

Historic and Cultural Resources SMALL to LARGE SMALL to LARGE SMALL to LARGE 

Noise SMALL SMALL SMALL to MODERATE 

Aesthetics SMALL SMALL to MODERATE SMALL to MODERATE 

Waste Management SMALL to 

MODERATE 

SMALL to MODERATE SMALL to LARGE 

Transportation SMALL SMALL to MODERATE SMALL to MODERATE 

Public and Occupational Health SMALL SMALL SMALL 

Accidents SMALL SMALL SMALL 

(a) Cumulative impacts to Federally listed threatened and endangered species and Essential Fish Habitat would be 

determined as part of consultations for the ESA and the Magnuson–Stevens Fishery Conservation and Management 

Act. 

ES.18 What is the Purpose of Chapter 8 of the GEIS? 

Chapter 8 provides a summary of the environmental impacts and consequences of continued 

at-reactor and away-from-reactor storage. In addition, Chapter 8 addresses the following 

NEPA elements for use in future site-specific environmental reviews: (1) unavoidable adverse 

environmental impacts of continued storage; (2) irreversible and irretrievable resource 

FRPPLWPHQWVRIFRQWLQXHVWRUDJHDQGWKHUHODWLRQVKLSEHWZHHQVKRUW-term uses of the 

environment and the maintenance and enhancement of long-term productivity. 

ES.18.1 What are the Unavoidable Adverse Impacts of Continued Storage? 

Unavoidable adverse environmental impacts are those potential impacts of continued storage 

that cannot be avoided because of constraints inherent in using at-reactor and away-fromreactor spent fuel storage facilities for continued storage. The unavoidable adverse 

environmental impacts associated with continued storage would include impacts of (1) shortterm storage in a spent fuel pool, as well as (2) short-WHUPVWRUDJHORQJ-term storage, 

and (4) indefinite storage in at-reactor and away-from-reactor ISFSIs. These impacts are 

summarized in Table ES-DQG7DEOH(6-4. 
Executive Summary 

185(*௅ lxii September 2014 

ES.18.2 What are the Irreversible and Irretrievable Resource Commitments of 

Continued Storage? 

An irreversible resource commitment is a commitment of environmental resources—to a 

particular action—that cannot be restored. An irretrievable commitment of resources refers to 

a commitment of material resources that, once used, cannot be recycled or restored for other 

uses by practical means. Impacts on land use, terrestrial ecology, aquatic ecology, aesthetics, 

historic and cultural resources, and waste management would all result in irreversible 

commitments of resources. Replacement of ISFSI components and transportation would result 

in irretrievable commitments. 

ES.18.3 What is the Relationship between Short-Term Uses of the Environment and the 

Maintenance and Enhancement of Long-Term Productivity? 

The NRC recognizes the relationship between local short-term uses of the environment and the 

maintenance and enhancement of long-term productivity that occurs from continued storage, 

which may be authorized by future licensing actions. The local short-term use of the human 

environment is summarized in terms of the unavoidable adverse environmental impacts and 

irreversible and irretrievable commitments of resources. The long-term productivity period is the 

time period beyond continued storage. 

Decisions regarding dismantlement and decommissioning affect this relationship. The 

maximum long-term impact on productivity would result when an at-reactor or away-fromreactor ISFSI is not immediately dismantled at the end of storage operations, or, as with the 

indefinite storage timeframe, it remains in operation indefinitely. Consequently, the land 

occupied by an ISFSI would not be available for any other uses. By contrast, when site 

decommissioning is complete, and an NRC license is terminated, a site would be available for 

other uses. 

Other potential long-term impacts on productivity include the commitment of land and 

consumption of disposal capacity necessary to meet waste disposal needs. In addition, 

because loss of historic and cultural resources would constitute irreversible impacts, any loss 

of historic and cultural resources during continued storage would persist as long-term impacts. 

A small contribution to greenhouse gas emissions would add to the atmospheric burden of 

emissions that could contribute to potential long-term impacts. 
Executive Summary 

September 2014 lxiii 185(*௅

ES.19 How did the NRC Address Spent Fuel Pool Fires and 

Leaks? 

The NRC assessed the environmental impacts of spent fuel pool fires and leaks as part of the 

analysis in the GEIS. Appendix E describes the environmental impacts of spent fuel pool leaks 

during the short-term storage timeframe, and Appendix F describes the environmental impacts 

of a spent fuel pool fire during the short-term storage timeframe. In the GEIS, the NRC 

assumes that all spent fuel being stored in spent fuel pools will be transferred to dry casks by 

the end of the 60-year (short-term) storage timeframe. 

ES.19.1 Spent Fuel Pool Leaks 

A variety of factors work together to make it 

unlikely that a spent fuel pool leak would result in 

noticeable offsite environmental impacts during 

continued storage. These include the 

combination of spent fuel pool design and 

maintenance, operational and regulatory practices 

(e.g., leakage monitoring, NRC oversight, and 

groundwater monitoring), site hydrogeologic 

characteristics, and radionuclide transport 

properties. 

For impacts to groundwater resources, though 

unlikely, it is possible that a leak of sufficient quantity and duration could occur, resulting in 

noticeable, but not destabilizing impacts to groundwater resources. The factors that could lead 

to a significant leak are many and varied. These factors include the magnitude and duration of 

the leak, the radiological constituents of the leak, the hydrologic conditions of the site, and the 

distance to the offsite groundwater resource. All these factors, in addition to the assessment of 

past leaks and the promulgation of regulations requiring subsurface surveys to determine the 

presence and extent of subsurface contamination, leads NRC to conclude that the 

environmental impacts of a spent fuel pool leak during continued storage would be SMALL. 

Public health concerns would be related to groundwater contamination and would be limited to 

private wells nearest the site. In the event of uncontrolled and undetected discharges 

associated with long-term spent fuel pool leaks to nearby surface waters, the annual discharge 

would be comparable to normal discharges associated with operating reactors, and would likely 

UHPDLQEHORZOLPLWVLQ&)53DUW$SSHQGL[,If, in the unlikely event that a pool leak 

remained undetected for a long period of time, public health regulatory limits (i.e., EPA drinking 

water standards) could potentially be exceeded, and the public health impacts could be 

noticeable, but not destabilizing. However, it is unlikely that a leak of sufficient quantity and 

Tritium is a radioactive isotope of 

hydrogen. Water containing tritium is 

normally released from nuclear power plants 

under controlled, monitored conditions that the 

NRC mandates to protect public health and 

safety. The NRC evaluates abnormal releases 

of tritium-contaminated water. More 

information about tritium from nuclear power 

plants can be found at 

http://www.nrc.gov/reading-rm/doccollections/fact-sheets/tritium-radiation-fs.html.
Executive Summary 

185(*௅ lxiv September 2014 

duration could occur without detection, or that a leak would not be impeded by the inherent 

hydrologic characteristics typical at spent fuel pool locations. Therefore, based on the low 

probability that a long-duration leak exceeding effluent limits would go undetected and affect 

offsite groundwater sources to the extent that a public health limit would be exceeded, the NRC 

concludes that impacts during the short-term storage timeframe would be SMALL. 

ES.19.2 Spent Fuel Pool Fires 

The spent fuel pool fire environmental impacts 

described in Appendix F are based upon a summary 

of spent fuel pool fire risk studies the NRC has 

completHGVLQFH:KLOHPRVWRIWKHHDUOLHU

studies were concerned with spent fuel pool fire risk 

during the operating life of a reactor, the Technical 

Study of Spent Fuel Pool Accident Risk at 

Decommissioning Nuclear Power Plants (NUREG–

completed in 2001, examined the risk of spent 

fuel pool fires during the reactor decommissioning 

period, which is the same storage timeframe of continued storage of spent fuel on which this 

GEIS is focused. The GEIS assumes that all fuel will be removed from the spent fuel pool by 

the end of the 60-year decommissioning period, which corresponds to the end of the short-term 

timeframe. 

The conservative estimates used to assess spent fuel pool fire accidents, based on the NRC’s 

previous analyses, result in probability-weighted population doses and economic consequences 

that are comparable to the values calculated for a severe reactor accident, as estimated in the 

1996 DQGLicense Renewal GEIS. Furthermore, mitigation measures implemented by 

licensees as a result of NRC Orders and regulations have further lowered the risk of this class 

of accidents. As a result, the NRC finds that the environmental impacts from spent fuel pool 

fires are SMALL during the short-term timeframe. 

ES.20 Does the GEIS Address Costs? 

&KDSWHURIWKH*(,6DQDO\]HVDQGFRPSDUHVWKHEHQHILWVDQGFRVWVDVVRFLDWHGZLWKWKH

SURSRVHGDFWLRQDGRSWLQJDUHYLVHG&)5DQGWKH15&¶VRSWLRQVLQWKHFDVHRI

no action (site-specific review, GEIS-only, and policy statement). The no-action options do not 

alter the environmental impacts of continued storage that the NRC addresses in Chapters 4, 

DQG,QVWHDGWhe options considered provide different administrative approaches that the 

NRC could apply to future licensing reviews to satisfy the agency’s responsibility to consider the 

potential environmental impacts of continued storage in deciding whether to issue certain new 

DQGUHQHZHGOLFHQVHV6HFWLRQLncludes assumptions about financial costs and current and 

The NRC’s determination of SMALL for 

the environmental impacts of a spent fuel 

fire is based on a probability-weighted 

consequence. This means that the risk 

of a spent fuel fire informed the impact 

determination of SMALL. 

The risk of a spent fuel fire is low because 

even though the consequences would be 

high, the probability is extremely low.
Executive Summary 

September 2014 lxv 185(*௅

future licensing reviews that are the bases for the cost analysis, while the NRC addresses 

unTXDQWLILHGFRVWVDQGEHQHILWVWKURXJKRXW&KDSWHU

6HFWLRQVXPPDUL]HVDQGFRPSDUHVWKHHVWLPDWHGFRsts and benefits of the proposed action 

and the potential options in the case of no action. The cost for the proposed action (adopting a 

UHYLVHG&)5is significantly lower than the cost for any of the no-action options. This 

occurs primarily because the NRC does not undertake site-specific reviews of the continued 

storage issue in the course of individual licensing proceedings as part of the proposed action. 

In general, the potential options in the case of no action are more costly than the proposed 

action. 

The NRC provides cost information about continued storage facilities and activities in Chapter 2 

in response to a large number of public comments on the draft GEIS that requested this 

information. 

ES.21 What is the NRC’s Recommendation? 

Section RIWKH*(,6SURYLGHV15&¶VUHFRPPHQGDWLRQWKDWWKHSURSRVHGDFWLRQLVWKH

preferred alternative. The NRC recommendation is based on (1) the NRC’s analysis of the costbenefit balance of the proposed action and the options in the case of no action as presented in 

&KDSWHUWKH15&¶VFRQVLGHUDWLRQRISXEOLF-scoping and draft GEIS comments in the 

development of the final *(,6WKHODFNRIHQYLURQPHQWDOLPSDFWVDVVRFLDWHGZLWKHLWKHUWKH

proposed action or the NRC’s options in the case of no action; and (4) the determination that the 

environmental impacts of continued storage analyzed in the GEIS are unaffected by the NRC’s 

choice of a particular administrative approach for considering the environmental impacts of 

continued storage in NRC licensing processes. 

ES.22 How is the GEIS Related to the Rule? 

This GEIS provides a regulatory basis for the NRC’s revised Rule, &)5 

Appendix B of the GEIS contains detailed information about the previous Waste Confidence 

proceedings, and addresses two relevant topics from Waste Confidence proceedings: (1) the 

technical feasibility of continued safe storage and (2) repository availability. NRC’s conclusions 

regarding these topics continue to undergird the agency’s environmental analysis. 

The NRC recommendation is to select the proposed action—adopting a 

revision to &)5WKDWFRGLILHVWKHLPSDFWGHWHUPLQDWLRQVIURPWKH

GEIS—as the preferred alternative.
Executive Summary 

185(*௅ lxvi September 2014 

ES.23 Are There Any Areas of Controversy in the GEIS? 

There were two areas of controversy raised in the Court of Appeals’ remand of the 2010 Waste 

Confidence Rule. These areas of controversy are described below. 

1. The NRC has included detailed analyses of spent fuel pool leaks and spent fuel pool fires. 

Historically, the NRC has devoted considerable attention to these topics, and there has 

been intense public interest in these issues, as evidenced by comments received during the 

litigation on the 2010 Waste Confidence update, during the scoping period, and during the 

comment period on the draft GEIS and proposed Rule. The NRC therefore prepared 

separate appendices to provide additional detail regarding the studies and analyses that 

underlie the analyses of spent fuel pool fires and leaks. 

2. The NRC has included indefinite storage as one of the three timeframes analyzed in this 

GEIS. The NRC has devoted considerable attention to this timeframe in response to the 

intense public interest in this issue, as evidenced by comments received during the litigation 

on the 2010 Waste Confidence update, during the scoping period, and during the comment 

period on the draft GEIS and proposed Rule. Although the NRC believes it is likely that a 

repository will be available by 60 years after the end of a reactor’s licensed life for operation, 

it recognizes that the availability of a repository is a controversial issue and has included an 

analysis of indefinite storage in the GEIS. 

ES.24 Are There Any Remaining Issues to be Resolved? 

For the purposes of successfully completing the GEIS while meeting NEPA requirements, the 

NRC believes there are numerous sources of the requisite technical data and information 

available; therefore, there are no remaining issues that require resolution. In the reference 

section of each chapter, the NRC has listed technical documents and reports on pertinent 

issues that are used to support the analyses in the GEIS. The NRC relied on accurate and 

high-quality information to ensure the GEIS contains a thorough and rigorous environmental 

impact analysis. The NRC will continue to review health and environmental effects of spent fuel 

storage as part of its ongoing licensing, oversight, and research activities. Any new information, 

such as the performance of spent fuel during lengthy periods of time, will be used to update and 

improve the NRC's regulatory requirements as appropriate. 

ES.25 How Can I Obtain a Copy of the GEIS and Rule? 

The final GEIS can be accessed online at http://www.nrc.gov/reading-rm/doccollections/nuregs/staff/ or in ADAMS under Accession No. ML14198A440. The draft GEIS can 

be accessed in ADAMS at ML$. The final Rule will be published in the Federal 

Register and at www.regulations.gov. 
September 2014 lxvii NUREG௅2157 

Abbreviations/Acronyms 

ACHP Advisory Council on Historic Preservation 

ADAMS Agencywide Documents Access and Management System 

AEA Atomic Energy Act 

AEC U.S. Atomic Energy Commission 

ALARA as low as is reasonably achievable 

ANDRA French National Agency for Radioactive Waste Management 

ANS American Nuclear Society 

ANSI American National Standards Institute 

APA Administrative Procedure Act 

APS American Physical Society 

ASLBP Atomic Safety and Licensing Board Panel 

ASME American Society of Mechanical Engineers 

ATRI American Transportation Research Institute 

B billion 

BEIR biological effects of ionizing radiation 

BLS Bureau of Labor Statistics 

BMP best management practice 

BWR boiling water reactor 

CEDE committed effective dose equivalent 

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations 

CNWRA Center for Nuclear Waste Regulatory Analyses 

CO2 carbon dioxide 

CoC certificate of compliance 

COL combined license 

CPB U.S. Customs and Border Protection 

CPI Consumer Price Index 

D.C. District of Columbia 

dBA decibel(s) (acoustic) 

DBT design basis threat 

DBTT ductile-to-brittle transition temperature 
Abbreviations/Acronyms 

NUREG௅2157 lxviii September 2014 

DEC Department of Environmental Conservation 

DOE U.S. Department of Energy 

DOT U.S. Department of Transportation 

DTS dry transfer system 

EA Environmental Assessment 

EFH essential fish habitat 

EIS environmental impact statement 

EMF electromagnetic field 

EPA U.S. Environmental Protection Agency 

EPRI Electric Power Research Institute 

ESA Endangered Species Act of 1973, as amended 

ESP early site permit 

FEIS final environmental impact statement 

FONSI finding of no significant impact 

FR Federal Register

FSAR Final Safety Analysis Report 

FTE full-time equivalent 

FWS U.S. Fish and Wildlife Service 

GAO Government Accountability Office 

GCRP U.S. Global Change Research Program 

GEH General Electric-Hitachi 

GEIS Generic Environmental Impact Statement 

GHG greenhouse gases 

GTCC greater than class C 

HLW high-level waste 

HOSS hardened onsite storage 

HSM horizontal storage modules 

IAEA International Atomic Energy Agency 

INL Idaho National Laboratory 

iPWR integral pressurized water reactor 

ISFSI independent spent fuel storage installation 

LLW low-level waste 

LWR light water reactor 
Abbreviations/Acronyms 

September 2014 lxix NUREG௅2157 

M million 

MACCS MELCOR Accident Consequence Code System 

MCL maximum contaminant level 

MEI maximally exposed individual 

MOX mixed oxide 

MTU metric tons of uranium 

NA not applicable 

NAAQS National Ambient Air Quality Standards 

NAS National Academy of Sciences 

NEI Nuclear Energy Institute 

NEPA National Environmental Policy Act of 1969, as amended 

NHPA National Historic Preservation Act of 1966, as amended 

NMFS National Marine Fisheries Services 

NMSS Office of Nuclear Material Safety and Safeguards 

NPDES National Pollutant Discharge Elimination System 

NRC U.S. Nuclear Regulatory Commission 

NRDC Natural Resources Defense Council 

NRHP National Register of Historic Places 

NWPA Nuclear Waste Policy Act 

OMB Office of Management and Budget 

OSHA Occupational Safety and Health Administration 

PAG protective action guide 

PFS Private Fuel Storage, LLC 

PFSF Private Fuel Storage Facility 

PM particulate matter 

PM10 particulate matter with a diameter of 10 microns or less 

PM2.5 particulate matter with a diameter of 2.5 microns or less 

PRA probabilistic risk assessment 

PWR pressurized water reactors 

QA quality assurance 

RCRA Resource Conservation and Recovery Act of 1976, as amended 

REMP radiological environmental monitoring program 
Abbreviations/Acronyms 

NUREG௅2157 lxx September 2014 

SAMA severe accident mitigation alternatives 

SKB Swedish Nuclear Fuel and Waste Management Company 

SMR small modular reactor 

SOC Statement of Considerations 

TEDE total effective dose equivalent 

TMI-2 Three Mile Island Unit 2 

TN Transnuclear Inc. 

TRU transuranic (waste) 

TVA Tennessee Valley Authority 

USACE U.S. Army Corps of Engineers 

USC United States Code 

USCB U.S. Census Bureau 

WIPP Waste Isolation Pilot Plant 
September 2014 lxxi NUREG௅2157 

Units of Measure 

Metric Prefixes 

tera (T-) 1012 

giga (G-) 109 

mega (M-) 106 

kilo (k-) 103

hecto (h-) 102 

deci (d-) 10௅1 

centi (c-) 10௅2 

milli (m-) 10௅3 

mirco (μ-) 10௅6 

nano (n-) 10௅9 

pico (p-) 10௅12 

Radiological Units 

μCi/ml microcurie(s) per milliliter 

Bq becquerel(s) 

Ci curie(s) 

Ci/L curies per liter 

Ci/yr curie(s) per year 

mrem millirem 

mSv millisievert(s) 

pCi picocurie(s) 

pCi/L picocurie(s) per liter 

R roentgen 

rad special unit of absorbed 

dose 

rem roentgen equivalent man 

(a special unit of radiation 

dose) 

S siemens 

Sv sievert 

Length/Distance 

cm centimeter(s) 

ft foot or feet 

in. inch(es) 

km kilometer(s) 

m meter(s) 

mi mile(s) 

mm millimeter(s) 

yd yard(s) 

Volume 

m3 cubic meter(s) 

yd3 cubic yard(s) 

ft3 cubic foot(feet) 

L liter(s) 

gal gallon(s) 

gpd gallon(s) per day 

gpm gallon(s) per minute 

oz ounce(s) 

Area 

ha hectare(s) 

ac acre(s) 

ft2 square foot(feet) 

mi2 square mile(s) 

m2 square meter(s) 

Units of Time 

hr hour(s) 

mo month 

s second(s) 

yr year(s) 

min minute 

Ryr reactor year(s) 
Units of Measure 

NUREG௅2157 lxxii September 2014 

Units of Temperature 

°C degree(s) Celsius 

°F degree(s) Fahrenheit 

Units of Concentration 

ppm parts per million 

ppt parts per thousand 

Units of Speed 

mph mile(s) per hour 

Units of Weight 

MT metric ton(s) (or tonne[s]) 

MTU metric ton(s) of uranium 

T ton(s) 

Units of Power 

Btu British thermal unit(s) 

GWd gigawatt-day(s) 

MW megawatt(s) 

MW(e) megawatt(s) electrical 

Ci/L curies per liter 

L/d liter(s) per day 

L/min liter(s) per minute 

ml or mL milliliter(s) 
September 2014 1-1 185(*௅

1.0 Introduction 

Since the inception of commercial nuclear power, the United States has worked to find a 

disposal solution for spent nuclear fuel (spent fuel) generated by commercial nuclear power 

UHDFWRUV,QWKHODWHVWKH861XFOHDU5HJXODWRU\&RPPLVVLRQ15&UHH[DPLQHGDQ

underlying assumption used in licensing reactors to that time—that a repository could be 

secured for the ultimate disposal of spent fuel generated by nuclear reactors, and that spent fuel 

could be safely stored in the interim7KLVDQDO\VLVZDVFDOOHGWKH:DVWH&RQILGHQFH

proceeding. 

This Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel

(GEIS) addresses the environmental impacts of continuing to store spent fuel at a reactor site or 

at an away-from-reactor storage facility, after the end of the licensed life for operations of a 

reactor1 until final disposition in a geologic repository (“continued storage”), historically 

adGUHVVHGDVSDUWRIWKH15&¶VZDVWHFRQILGHQFHSURFHHGLQJ. This GEIS has been prepared to 

IXOILOOWKH&RPPLVVLRQ¶VREOLJDWLRQVXQGHUWKH1DWLRQDO(QYLURQPHQWDO3ROLF\$FWRIDV

DPHQGHG1(3$DQG15&UHJXODWLRQVLPSOHPHQWLQJ1(3$LQ7LWOHRIWKHCode of Federal 

Regulations &)53DUW 

1.1 History of Waste Confidence 

7KHILUVW:DVWH&RQILGHQFHUXOHPDNLQJEHJDQLQWKHODWHVLQUHVSRQVHWRWZRVLJQLILFDQW

OHJDOSURFHHGLQJV,QWKH&RPPLVVLRQGHQLHGDSHWLWLRQIRUUXOHPDNLQJILOHGE\WKH

NatXUDO5HVRXUFHV'HIHQVH&RXQFLO15'&WKDWDVNHGWKH15&WRGHWHUPLQHZKHWKHU

radioactive wastes generated in nuclear power reactors can be disposed of without undue risk 

to public health and safety and to refrain from granting pending or future requests for reactor 

RSHUDWLQJOLFHQVHVXQWLOWKH15&PDGHDGHWHUPLQDWLRQUHJDUGLQJGLVSRVDO7KH&RPPLVVLRQ

stated in its denial that, as a matter of policy, it “... would not continue to license reactors if it did 

not have reasonable confidence that the wastes can and will in due course be disposed of 

safely” (42 )5 7KH&RPPLVVLRQ¶VGHQLDORIWKH15'&SHWLWLRQZDVDIILUPHGXSRQ

judicial review (NRDC v. NRC6LQFHWKDWWLPHWKH)HGHUDOJRYHUQPHQWKDVDGRSWHGGHHS

geologic disposal as the national solutLRQIRUVSHQWIXHOGLVSRVDO1XFOHDU:DVWH3ROLF\$FWRI

5HFHQWO\WKH86'HSDUWPHQWRI(QHUJ\'2(UHDIILUPHGWKH)HGHUDOJRYHUQPHQW¶V

commitment to the ultimate disposal of spent fuel and predicted that a repository would be 

available by 2048 (DOE 2013).

 

1 $VXVHGLQWKH*(,6WKHWHUP3OLFHQVHGOLIHIRURSHUDWLRQ ́RIDUHDFWRULVWKHSHULRGUXQQLQJWRWKHHQGRI

the operating license term for a reactor, which may include the term of a revised or renewed license. 
Introduction 

185(*௅ 1-2 September 2014 

$WDERXWWKHVDPHWLPHWKH&RPPLVVLRQGHQLHGWKH15'&SHWLWLRQWKH6WDWHRI0LQQHVRWDDQG

WKH1HZ(QJODQG&RDOLWLRQRQ1XFOHDU3ROOXWLRQFKDOOHQJHGOLFHQVHDPHQGPHQWVWKDWSHUPLWWHG

H[SDQVLRQRIWKHFDSDFLW\RIVSHQWIXHOVWRUDJHSRROVDWWZRnuclear power plants, Vermont 

<DQNHHDQG3UDLULH,VODQG,QWKH&RXUWRI$SSHDOVIRUWKH'LVWULFWRI&ROXPELD'&

&LUFXLWLQMinnesota v. NRCUHPDQGHGWRWKH&RPPLVVLRQWKHTXHVWLRQRIZKHWKHUDQRIIVLWH

storage or disposal solution would be available for the spent fuel at the two facilities at the 

H[SLUDWLRQRIWKHLUOLFHQVHV—DWWKDWWLPHVFKHGXOHGIRUDQG—and, if not, whether the 

spent fuel could be stored safely at those reactor sites until an offsite solution was available. 

,QWKH15&LQLWLDWHGDJHQHULFUXOHPDNLQJWKDWVWHPPHGIURPWKHVHFKDOOHQJHVDQGWKH

&RXUWRI$SSHDOV¶ remand in Minnesota v. NRC7KH:DVWH&RQILGHQFHUXOHPDNLQJJHQHULFDOO\

DVVHVVHGZKHWKHUWKH&RPPLVVLRQFRXOGKDYHUHDVRQDEOHDVVXUDQFHWKDWVSHQWIXHOSroduced 

by nuclear power plants “...can be safely disposed of...when such disposal or offsite storage 

will be available, and...whether radioactive wastes can be safely stored onsite past the 

H[SLUDWLRQRIH[LVWLQJIDFLOLW\OLFHQVHVXQWLORIIVLWHGLVSRVDORUVWRUDJHLVDYDLODEOH ́)5

2Q$XJXVW WKH&RPPLVVLRQSXEOLVKHGWKH:DVWH&RQILGHQFHGHFLVLRQ)5 

(Decision) and a final RXOH)5which codified elements of the decision at 

10 &)5 5XOH DQGDGRSWHGUHYLVLRQVWR&)53DUWWKDWHVWDEOLVKHGSURFHGXUHVWR

“...confirm that there will be adequate lead time for whatever actions may be needed at 

individual reactor sites WRDVVXUHWKDWWKHPDQDJHPHQWRIVSHQWIXHOIROORZLQJWKHH[SLUDWLRQRI

the reactor operating license will be accomplished in a safe and environmentally acceptable 

manner” (49 )5),QDGGLWLRQWRDGGUHVVLQJWKH15&¶VDVVHVVPHQWRIWKHLVVXHV

presented by the &RXUWRI$SSHDOV¶ remand, the Decision provided an environmental 

DVVHVVPHQW($DQGILQGLQJRIQRVLJQLILFDQWLPSDFW)216,WRVXSSRUWWKH Rule 15&. 

7KHDQDO\VLVLQ&)5IRXQGWKDWIRUDWOHDVW\HDUVEH\RQGWKHH[SLUDWLRQRID

UHDFWRU¶VOLFHQVHGOLIHIRURSHUDWLRQs, no significant environmental impacts would result from 

VWRUDJHRIVSHQWIXHODQGH[SUHVVHGWKH&RPPLVVLRQ¶VUHDVRQDEOHDVVXUDQFHWKDWDUHSRVLWRU\

ZDVOLNHO\WREHDYDLODEOHLQWKHWRWLPHIUDPH7KH5XOHDOVRVWDWHGWKDWDVDUHVXOW

RIWKLVJHQHULFGHWHUPLQDWLRQWKH15&QHed not prepare any site-specific environmental 

analysis in connection with continuing storage when issuing a license or amended license for a 

QHZUHDFWRURULQGHSHQGHQWVSHQWIXHOVWRUDJHIDFLOLW\,6)6, &)5 E

The first review of the Decision and the Rule occurred in 1989 and 1990. This review resulted 

LQUHYLVLRQVWRWKH'HFLVLRQDQGWKH5XOHWRUHIOHFWUHYLVHGH[SHFWDWLRQVIRUWKHDYDLODELOLW\RIWKH

ILUVWUHSRVLWRU\DQGWRFODULI\WKDWWKHH[SLUDWLRQRIDUHDFWRU¶VOLFHQVHGOLIHIRURSHUDtions referred 

to the full 40-year initial license for operations and a 30-year revised or renewed license. On 

6HSWHPEHUWKH&RPPLVVLRQSXEOLVKHGWKHUHYLVHG'HFLVLRQ)5DQGILQDO

5XOH)5
Introduction 

September 2014 1-3 185(*௅

7KH&RPPLVVLRQFRQGXFWHGLWVVHFRQd review of the Decision and the Rule in 1999 and 

FRQFOXGHGWKDWH[SHULHQFHDQGGHYHORSPHQWVDIWHUKDGFRQILUPHGWKHILQGLQJVDQGPDGHD

FRPSUHKHQVLYHUHHYDOXDWLRQRIWKH'HFLVLRQDQG5XOHXQQHFHVVDU\7KH&RPPLVVLRQDOVR

stated that it would consider undertaking a comprehensive reevaluation when the pending 

repository development and regulatory activities had run their course or if significant and 

SHUWLQHQWXQH[SHFWHGHYHQWVRFFXUUHGWKDWUDLVHGVXEVWDQWLDOGRXEWDERXWWKHFRQWLQXLQJYDOLGLW\

of the :DVWH&RQILGHQFHGHFLVLRQ)5

,QWKH&RPPLVVLRQGHFLGHGWRFRQGXFWLWVWKLUGUHYLHZRIWKH'HFLVLRQDQGWKH5XOH7KLV

UHYLHZUHVXOWHGLQUHYLVLRQVWRUHIOHFWUHYLVHGH[SHFWDWLRQVIRUWKHDYDLODELOLW\RIWKHILUVW

repository and to encompDVVDWOHDVW\HDUVRIFRQWLQXHGVWRUDJH,Q'HFHPEHUWKH

&RPPLVVLRQSXEOLVKHGLWVUHYLVHG'HFLVLRQ)5DQGILQDO5XOH)5

,QUHVSRQVHWRWKHUXOHPDNLQJWKH6WDWHVRI1HZ<RUN1HZ-HUVH\&RQQHFWLFXWDQG

Vermont; severDOSXEOLFLQWHUHVWJURXSVDQGWKH3UDLULH,VODQG,QGLDQ&RPPXQLW\VRXJKWUHYLHZ

LQWKH&RXUWRI$SSHDOVFKDOOHQJLQJWKH&RPPLVVLRQ¶V1(3$DQDO\VLVWKDWVXSSRUWHGWKH5XOH

On June 8, 2012, the &RXUWRI$SSHDOV ruled that some aspects of the 2010 :DVWH&Rnfidence 

UXOHPDNLQJGLGQRWVDWLVI\WKH15&¶V1(3$REOLJDWLRQV7KH&RXUWRI$SSHDOV therefore vacated 

WKH'HFLVLRQDQGWKH5XOHDQGUHPDQGHGWKHFDVHWRWKH15&IRUIXUWKHUSURFHHGLQJV

consistent with the Decision (New York v. NRC). 

The &RXUWRI$SSHDOV FRQFOXGHGWKDWWKH:DVWH&RQILGHQFHUXOHPDNLQJSURFHHGLQJLVDPDMRU

)HGHUDODFWLRQQHFHVVLWDWLQJHLWKHUDQHQYLURQPHQWDOLPSDFWVWDWHPHQW(,6RUDQ($WKDW

UHVXOWVLQD)216,7KH&RXUWRI$SSHDOV LGHQWLILHGWKUHHGHILFLHQFLHVLQWKH15&¶V

environmental analysis: 

1. 5HODWHGWRWKH&RPPLVVLRQ¶VFRQFOXVLRQWKDWSHUPDQHQWGLVSRVDOZLOOEHDYDLODEOH3ZKHQ

necessary,” the &RXUWRI$SSHDOV KHOGWKDWWKH&RPPLVVLRQQHHGHGWRHYDOXDWHWKH

environmental effects of failing to secure permanent disposal, given the uncertainty about 

whether a repository would be built. 

2. 5HODWHGWR\HDUVRIFRQWLQXHGVWRUDJHWKH&RXUWRI$SSHDOV concluded that the 

&RPPLVVLRQKDGQRWDGHTXDWHO\H[DPLQHGWKHULVNRIVSHQWIXHOSRROOHDNVLQDIRUZDUGlooking fashion. 

3. $OVRUHODWHGWRFRQWLQXHGVWRUDJHWKH&RXUWRI$SSHDOV FRQFOXGHGWKDWWKH&RPPLVVLRQKDG

QRWDGHTXDWHO\H[DPLQHGWKHFRQVHTXHQFHVRISRWHQWLDOVSHQWIXHOSRROILUHV

In response to the &RXUWRI$SSHDOV¶ GHFLVLRQWKH&RPPLVVLRQVWDWHGLQ&RPPLVVLRQ2UGHU

&/,–12–WKDW LWZRXOGQRWLVVXHUHDFWRURU,6)6,OLFHQVHVGHSHQdent upon the Waste 

&RQILGHQFH5ule until the &RXUWRI$SSHDOV¶ UHPDQGLVDSSURSULDWHO\DGGUHVVHG15&D

7KLVGHFLVLRQLVQRWDQLQGLFDWLRQWKDWWKH&RPPLVVLRQODFNVFRQILGHQFHLQWKHDYDLODELOLW\RIDQ

XOWLPDWHGLVSRVDOVROXWLRQEXWUDWKHUUHIOHFWVWKH&RPPLVVLRQ¶VQHHGWRGHYHORSDQDQDO\VLVWKDW
Introduction 

185(*௅ 1-4 September 2014 

assesses the environmental impacts of continued storage in a manner addressing the &RXUWRI

$SSHDOV¶ remand.2 The &RPPLVVLRQVWDWHGKRZHYHUWKDWWKLVGHWHUPLQDWLRQH[WHQGVRQO\WR

LVVXDQFHRIWKHUHDFWRURU,6)6,OLFHQVHDQGWKDWDOOOLFHQVLQJUHYLHZVDQGSURFHHGings should 

continue to move forward. In 650–&206(&<–12–WKH&RPPLVVLRQGLUHFWHGWKH15&WR

GHYHORSD*(,6WRVXSSRUWDQXSGDWHG:DVWH&RQILGHQFHGHFLVLRQDQGUXOH15&E

1.2 Scope of the Generic Environmental Impact Statement 

This GEIS analyzes the environmental impacts of continued storage and provides a regulatory 

basis for the revision WRWKH15&¶V:DVWH&RQILGHQFH5ule. 

7KH:DVWH&RQILGHQFH5XOHRULJLQDOO\DGRSWHGE\WKH&RPPLVVLRQLQVDWLVILHVSDUWRIWKH

&RPPLVVLRQ¶V1(3$REOLJDWLRQWRSUHSDUHDQHQYLURQPHQWDODQDO\VLVin the course of a 

licensing proceeding for a commercial nuclear power reactor or a facility that will store the spent 

fuel generated by these reactors. 

)RU both power reactor and storage facilities1(3$UHTXLUHVWKDWWKH15&DGGUHVVGLUHFW

indirect, and cumulative impacts of its licensing actions. Thus, in issuing a power reactor 

OLFHQVHWKH15& must analyze the environmental impacts resulting from the generation of spent 

fuel by the reactor and its FRQWLQXHGVWRUDJHSHQGLQJXOWLPDWHGLVSRVDO/LNHZLVHIRUDQ,6)6,

WKH15&PXVWDQDO\]H the impacts of continued storage at the facility until ultimate disposal for 

the spent fuel is available. The environmental impacts addressed in this GEIS are limited to the 

environmental impacts of continued storage. 

This GEIS considers three possible continued storage timeframes: (1) short-term storage of no 

PRUHWKDQ\HDUVDIWHUWKHHQGRIDUHDFWRU¶VOLFHQVHGOLIHIRURSHUDWLRQs; (2) long-term storage 

RIQRPRUHWKDQ\HDUVDIWHUWKHHQGRIDUHDFWRU¶VOLFHQVHGOLIHIRURSHUDWLRQs; and 

(3) indefinite storage at a reactor site or at an away-from-UHDFWRU,6)6,7KHLQGHILQLWHVWRUDJH

scenario assumes that disposal in a repository never becomes available. 

$VGLVFXVVHGDERYHWKH15&KDVDQDO\]HGWKUHHWLPHIUDPHVWKDWUHSUHVHQWYDULRXVVFHQDULRV

for the length of continued storage that will be needed before spent fuel is sent to a repository. 

The first, most likely, timeframe is the short-term WLPHIUDPHZKLFKDQDO\]HV\HDUVRI

FRQWLQXHGVWRUDJHDIWHUWKHHQGRIDUHDFWRU¶VOLFHQVHGOLIHIRURSHUDWLRQs$VGLVFXVVHGLQPRUH

detail later in this GEIS DQGLQ$SSHQGL[%WRWKLVGEISWKH15&EHOLHYHVWKLVLVWKHPRVWOLNHO\

 

2 “Waste confidence undergirds certain agency licensing decisions, in particular new reactor licensing and 

reactor license renewal. %HFDXVHRIWKHUHFHQWFRXUWUXOLQJVWULNLQJGRZQRXUFXUUHQWZDVWHFRQILGHQFH

provisions, we are now considering all available options for resolving the waste confidence issue, which 

could include generic or site-VSHFLILF15&DFWLRQVRUVRPHFRPELQDWLRQRIERWK We have not yet 

determined a course of action. %XWLQUHFRJQLWLRQRIRXUGXWLHVXQGHUWKHODZZHZLOOQRWLVVXHOLFHQVHV

GHSHQGHQWXSRQWKH:DVWH&RQILGHQFH'HFLVLRQRUWKH7HPSRUDU\6WRUDJH5XOHXQWLOWKHFRXUW¶VUHPDQG

is appropriately addressed.” (15&D at 4 citations omitted. 
Introduction 

September 2014 1- 185(*௅

timeframe because thH'2(KDVH[SUHVVHGLWVLQWHQWLRQWRSURYLGHUHSRVLWRU\FDSDFLW\E\

which is about 10 years before the end of this timeframe for the oldest spent fuel within the 

VFRSHRIWKLVDQDO\VLV)XUWKHULQWHUQDWLRQDODQGGRPHVWLFH[SHULHQFHZLWKGHHSJHRORJic 

UHSRVLWRU\SURJUDPVVXSSRUWVDWLPHOLQHRI to \HDUVWRSURYLGHUHSRVLWRU\FDSDFLW\IRUWKH

GLVSRVDORIVSHQWIXHO7KH'2(¶VSUHGLFWLRQRILVLQOLQHZLWKWKLVH[SHFWDWLRQ7KH15&

acknowledges, however, that the short-term timeframe, although the most likely, is not certain. 

$FFRUGLQJO\two additional timeframes also are analyzed in this GEIS. The long-term timeframe 

FRQVLGHUVWKHHQYLURQPHQWDOLPSDFWVRIFRQWLQXHGVWRUDJHIRUDWRWDORI\HDUVDIWHUWKHHQG

RIDUHDFWRU¶VOLFHQVHGOLfe for operations)LQDOO\DOWKRXJKWKH15&FRQVLGHUVLWKLJKO\XQOLNHO\

this GEIS includes an analysis of an indefinite timeframe, which assumes that a repository does 

not become available. 

1.3 Purpose of the Generic Environmental Impact Statement 

The purpose of the GEIS is twofold: 

1. To determine the environmental impacts of continued storage, including those impacts 

identified in the remand by the &RXUWRI$SSHDOV in the New York v. NRC decision 

2. To determine whether those impacts can be generically analyzed. 

,QWKHGUDIW*(,6WKH15&SUHOLPLQDULO\LGHQWLILHGWKHHQYLURQPHQWDOLPSDFWVRIFRQWLQXHG

storage and determined that they could be addressed generically. In the process of developing 

this final GEIS, including considering and responding to the substantial volume of public 

FRPPHQWVWKH15&UHFHLYHGLQUHVSRQVHWRWKHGUDIW*(,6 and proposed Rule, WKH15&KDV

confirmed that the impacts of continued storage can be generically addressed. Therefore, the 

GEIS provides a regulatory basis for a revisiRQWR&)5WKDWDGGUHVVHVWKH

HQYLURQPHQWDOLPSDFWVRIFRQWLQXHGVWRUDJHIRUXVHLQIXWXUH15&HQYLURQPHQWDOUHYLHZV

1.4 Proposed Federal Action 

The )ederal action is the adoption of DUHYLVHG5XOH&)5which codifies (i.e., adopts 

into regulation) the analysis in the GEIS of the environmental impacts of continued storage of 

spent fuel. 

Having confirmed that the environmental impacts of continued storage can be analyzed 

JHQHULFDOO\WKH&RPPLVVLRQKDVGHFLGHGWRFRGLI\WKH*(,6LPSDFWGHWHUPLQDWLRQVLQDUHYLVHG

UXOH&)5 The rule states that, because the impacts of continued storage have been 

JHQHULFDOO\DVVHVVHGLQWKLV*(,61(3$DQDO\VHVIRUUHOHYDQWIXWXUHUHDFWRUDQGVSHQWIXHO

storage facility licensing actions will not need to separately consider the environmental impacts 

of continued storage. 
Introduction 

185(*௅ 1- September 2014 

$VFRGLILHGWKHLPSDFWGHWHUPLQDWLRQVLQWKH*(,6ZLOOLQIRUPWKHGHFLVLRQPDNHUVLQOLFHQVLQJ

proceedings of the reasonably foreseeable environmental impacts of continued storage. 

These determinatioQVZLOOEHZHLJKHGDORQJZLWKRWKHULPSDFWVGHWHUPLQHGE\WKH15&RQD

site-specific basis for a facility or an activity. Thus, in the course of an individual licensing 

proceeding, the decisionmaker will be able to compare all the environmental impacts of a 

proposed licensing action (e.g., licensing a nuclear power reactor), including continued storage 

impacts, to the environmental impacts of reasonable alternatives, including the no-action 

alternative. 

1.5 Purpose of and Need for the Proposed Action 

The neHGIRUWKHSURSRVHGDFWLRQLVWRSURYLGHSURFHVVHVIRUXVHLQ15&OLFHQVLQJWRDGGUHVV

WKHHQYLURQPHQWDOLPSDFWVRIFRQWLQXHGVWRUDJH+LVWRULFDOO\WKH15&DQGOLFHQVHDSSOLFDQWV

KDYHUHOLHGRQ&)5WRFRQFOXVLYHO\DGGUHVVWKHHQYLURQPHQWDOLPSDFts of continued 

VWRUDJHLQHQYLURQPHQWDOUHSRUWV(,6V($VDQGKHDULQJV

7KHSXUSRVHRIWKHSURSRVHGDFWLRQLVWRSUHVHUYHWKHHIILFLHQF\RIWKH15&¶VOLFHQVLQJ

processes with respect to the environmental impacts of continued storage. 

1.6 Alternatives 

The 15&KDVKLVWRULFDOO\DGGUHVVHGLWV1(3$REOLJDWLRQVIRUFRQWLQXHGVWRUDJHE\PHDQVRIDQ

($DQGD)216,DGRSWHGLQ&)57KXVLIWKH15&FKRRVHVQRWWRDGGUHVVWKH

HQYLURQPHQWDOLPSDFWVRIFRQWLQXHGVWRUDJHE\UXOHWKH&RPPLVVLRQZRXOGKDYHWRchoose a 

GLIIHUHQWSURFHVVWRPHHWLWV1(3$REOLJDWLRQV

7KH&RPPLVVLRQFRQVLGHUHGRWKHURSWLRQVDQGDSSURDFKHVFDOOHGWUDFNVZKHQLWUHVSRQGHGWR

&206(&<–12–15&FLQZKLFKWKH15&ZDVGHWHUPLQLQJKRZWRUHVSRQGWRWKH

remand of New York v. NRC,IWKH15&KDGGHWHUPLQHGGXULQJWKHFRXUVHRIWKHUXOHPDNLQJ

SURFHVVWKDWWKHSURSRVHGUHYLVLRQWR&)5ZDVXQWHQDEOHRUXQGHVLUDEOHWKHQ

the &RPPLVVLRQZRXOGKDYHUHFRQVLGHUHGZKHWKHUWRSXUVXHWKHRSWLRQVDQGWUDFNVLQ

&206(&Y–12– 15&E, elements of which are incorporated in SHFWLRQ. 

%HFDXVHQRQHRIWKHSRWHQWLDORSWLRQVWKH15&FRXOGSXUVXHLILWGLGQRWFRQWLQXHwith the 

rulemaking meets the purpose for the )ederal action (i.e., they do not preserve the efficiency of 

the 15&¶VOLFHQVLQJSURFHVVHV, they will be addressed as options under the no-action 

alternative. 

1.6.1 No-Action Alternative 

The no-action alternative ZRXOGEHIRUWKH15&QRWWRLVVXHWKHUHYLVLRQRI&)5DVD

final rule (i.e., not to codify the impact determinations from this GEIS). 
Introduction 

September 2014 1- 185(*௅

7KHSULRUYHUVLRQRI&)5ZDVYDFDWHGE\WKH&RXUWRI$SSHDOVin New York v. NRC. 

Therefore, adopting the no-action alternative ZRXOGUHTXLUHWKH15&WRVHOHFWDGLIIHUHQW

approach for addressing the environmental impacts of continued storage in its licensing 

SURFHHGLQJV7KH15&FRXOGSXUVXHDYDULHW\RIRSWLRQVLQWKHFDVHRIQRDFWLRQLQFOXGLQJWKH

following approaches. 

x )LUVWWKH15&FRXOGUHYLHZWKHHQYLURQPHQWDOLPSDFWVIURPFRQWLQXHGVWRUDJHRQDVLWHVSHFLILFEDVLVUDWKHUWKDQRQDJHQHULFEDVLVLQQXFOHDUSRZHUSODQWDQG,6)6,OLFHQVLQJ

proceedings. 

x 6HFRQGWKH15&FRXOGILQDOL]HWKH*(,6ZLWKRXWLQFRUSRUDting the results into a rule. This 

DSSURDFKZRXOGDOORZWKH15&WRDGRSWWKHVH*(,6ILQGLQJVLQWRHQYLURQPHQWDOUHYLHZVIRU

future licensing activities, but without the binding effect of a rule. 

x 7KLUGWKH&RPPLVVLRQFRXOGLVVXHDSROLF\VWDWHPHQWH[SODLQLQJKRZWKH&RPPLVVLRQ

LQWHQGVWRDGGUHVVWKH15&¶V1(3$REOLJDWLRQVZLWKUHVSHFWWRFRQWLQXHGVWRUDJH7KH

policy statement would not bind licensees and applicants like a rule, but it would provide 

notice of how, or whether, WKH&RPPLVVLRQLQWHQGVWRLQForporate the findings of the GEIS 

into environmental reviews for future licensing activities. 

1.6.1.1 Site-Specific Review Option 

,IWKH15&GHFLGHGQRWWRLQFRUSRUDWHWKHUHVXOWVRIWKLV*(,6LQWRDUHYLVLRQRI&)5

WKH15&FRXOGDGGUHVVWKHHQYLURQPHQWDOLPSDFWVRIFRQWLQXHd storage in site-specific reviews. 

7KHVHUHYLHZVZRXOGJHQHUDOO\WDNHSODFHZLWKLQWKHFRQWH[WRIH[LVWLQJHQYLURQPHQWDOUHYLHZ

SURFHVVHVIRUQHZUHDFWRUOLFHQVLQJUHDFWRUOLFHQVHUHQHZDODQG,6)6,OLFHQVLQJDQGUHQHZDOV

In some cases, these reviews could involve time- and resource-intensive considerations of 

issues that could readily be resolved on a generic basis. Therefore, this option is inconsistent 

ZLWK&RXQFLORQ(QYLURQPHQWDO4XDOLW\JXLGDQFHIRUDFKLHYLQJHIILFLHQF\DQGtimeliness under 

1(3$

In the site-specific review option, it is likely that the 15&ZRXOGincorporate as much of the 

analysis from this GEIS as possible into site-VSHFLILF1(3$UHYLHZV. /DWHUUHYLHZVZRXOGOLNHO\

incorporate, by reference, applicable findings from the first few published environmental 

documents that used the analyses. 

)URPDSURFHGXUDOSHUVSHFWLYHWKHPDLQHIIHFWRIWKHsite-specific review option LVWKDWWKH15&

would have to address the environmental impacts of continued storage for individual licensing 

proceedings on a site-by-site basis5HTXLULQJWKH15&WRSUHSDUHVLWH-specific discussions of 

generic issues, like those associated with continued storage, would result in the considerable 

H[SHQGLWXUHRISXEOLF15&DQGDSSOLFDQWUHVRXUFHV)XUWKHUOLFHQVLQJERDUGVFRXOGEH

required to hear nearly identical issues in each proceeding on these generic matters. $GRSWLQJ

the generic impacts of continued storage in a rule, on the other hand, DOORZVWKH15&DQGWKH

participants in its licensing proceedings to focus their limited resources on site-specific issues 

that are unique to each licensing action. 
Introduction 

185(*௅ 1-8 September 2014 

1.6.1.2 GEIS-Only Option 

,IWKH15&GHFLGHGQRWWRincorporate the results of this GEIS into a UHYLVLRQRI&)5

WKH15&FRXOG issue this GEIS for use in support of site-specific licensing reviews. This 

nonbinding, GEIS-only option ZRXOGDGGVRPHZKDWWRWKHHIILFLHQF\RI15&UHYLHZVE\

addressing issues that are similar at all sites or that otherwise are susceptible to generic 

FRQVLGHUDWLRQ)RUSDUWLFXODUOLFHQVLQJDFWLRQVWKH(,6RU($FRXOGLQFRUSRUDWHE\UHIHUHQFH

any finding or conclusion of the GEIS, but participants in a proceeding could still raise issues 

regarding continued storage. 

This approach would be FRQVLVWHQWZLWK&RXQFLORQ(QYLURQPHQWDO4XDOLW\JXLGDQFHUHJDUGLQJ

efficiency and timeOLQHVVXQGHU1(3$ However, while this approach would be beneficial in 

WHUPVRILPSURYHGHIILFLHQF\WKH*(,6¶VILQGLQJVDQGFRQFOXVLRQVZRXOGUHPDLQRSHQWR

challenge in site-VSHFLILFUHYLHZVIRUUHDFWRUDQG,6)6,OLFHQVLQJSURFHHGLQJV$OWKRXJKWKLV

incorporation-by-UHIHUHQFHDSSURDFKZRXOGVDWLVI\15&¶V1(3$REOLJDWLRQVWKLVoption could 

enable participants in contested licensing proceedings to raise issues that challenge the 

conclusions of the GEIS, an outcome that PD\UHVXOWLQFRQVLGHUDEOHH[SHQGLWXUHRISXEOLF

15&DQGDSSOLFDQWUHVRXUFHV. )XUWKHUOLFHQVLQJERDUGVPLJKWEHUHTXLUHGWRKHDUQHDUO\

identical contentions in individual licensing proceedings. Thus, although the “GEIS-only” 

approach would likely provide greater efficiencies than the site-specific review option, it would 

eliminate some of the efficiency and time-VDYLQJVWKDWWKH15&ZRXOGJDLQWKURXJKDELQGLQJ

generic analysis of continued storage. $GRSWLQJWKHJHQHULFLPSDFWVRIFRQWLQXHGVWRUDJHLQD

UXOHRQWKHRWKHUKDQGZRXOGDOORZWKH15&DQGSDUWLHVWRLWVOLFHQVLQJSURFHHGLQJVWRIRFXV

their limited resources on the site-specific issues that are unique to each licensing action. 

1.6.1.3 Policy-Statement Option 

Instead of issuing a rule to adopt the results of the GEISWKH&RPPLVVLRQFRXOGLVVXHDSROLF\

VWDWHPHQWWKDWH[SUHVVHVLWVLQWHQWWRHLWKHULQFRUSRUDWHWKHHQYLURQPHQWDOLPSDFWVGHWHUPLQHG

by the GEIS into site-VSHFLILF1(3$DQDO\VHVRUSUHSDUHD site-specific evaluation without 

regard to the GEIS for each 15&OLFHQVLQJDFWLRQ

In general, a policy statement suffers from many of the same shortcomings as the site-specific 

review and GEIS-only no-action options7KH15&ZRXOGVWLOOQHHGWRDGGUHVVWKHLPSDFWVRI

continued storage in site-VSHFLILF1(3$DQDO\VHVHLWKHUE\LQFRUSRUDWLQJWKHLPSDFWVIURPWKH

GEIS or through the consideration of the impacts on a site-specific basis if no GEIS is adopted. 

/LNHWKHsite-specific review and GEIS-only no-action options, the policy-statement no-action 

option ZRXOGUHGXFHWKHHIILFLHQFLHVWKDWWKH15&ZRXOGJDLQWKURXJKDUXOHin which 

incorporation of environmental impacts of continued storage would be binding in licensing 

proceedings, although it would at least provide notice to participants WKDWWKH&RPPLVVLRQPLJKW

HOHFWWRLQFRUSRUDWHE\UHIHUHQFHDOORUDSRUWLRQRIWKHH[LVWLQJ*(,6
Introduction 

September 2014 1-9 185(*௅

3UHSDUDWLRQRIVLWH-specific analyses of continuing storage impacts would result in considerable 

H[SHQGLWXUHRISXEOLF15&DQGDSSOLFDQWUHVRXUFHV)XUWKHUOLFHQVLQJERDUGVFRXOGEH

H[SHFWHGWRKHDUQHDUO\LGHQWLFDOissues in each proceeding on these generic matters. 

&RQYHUVHO\determining and adopting the generic impacts of continued storage would allow the 

15&DQGparticipants in its licensing proceedings to focus their limited resources on site-specific 

issues that are unique to each licensing action. 

1.6.2 Alternatives Considered but Eliminated 

Interested parties submitted numerous scoping comments suggesting that this GEIS should 

consider other actions as alternatives to adopting the proposed revision WR&)5,Q

this section, this GEIS considers and eliminates the most commonly suggested alternatives 

because they fail to meet the purpose and need for this proposed action. 

1.6.2.1 Cessation of Licensing or Cessation of Reactor Operation 

&HVVDWLRQRIOLFHQVLQJDFWLYLWLHVDQGFHVVDWLRQRIUHDFWRURSHUDWLRQVGRQRWVDWLVI\WKHVWDWHG

purpose and need for this proposed action. $EDQGRQPHQWRI reactor licensing and the closure 

RIH[LVWLQJSODQWVLVQRWDUHDVRQDEOHDOWHUQDWLYHWRWKHSURSRVHGDFWLRQEHFDXVHWKHVHDFWLRQV

ZRXOGQRWPHHWWKH15&¶VVWDWHGREMHFWLYHVLQSURSRVLQJWR adopt the revision to &)5 

7KURXJKWKH$WRPLF(QHUJ\$FW RIDVDPHQGHG DQGWKH(QHUJ\5HRUJDQL]DWLRQ$FWRI

DVDPHQGHG &RQJUHVV directed WKH15&to issue licenses for nuclear power plants and 

certain nuclear materials if there is, among other things, no undue risk (i.e., that there is 

reasonable assurance of adequate protection) to public health and safety and common defense 

and security,QWKHVHVWDWXWHV&RQJUHVVDOVRDXWKRUL]HGDQGGLUHFWHGWKH15&WRLVVXH

regulations establishing requirements for providing adequate protection to public health and 

safety and common defense and security (see $WRPLF(QHUJ\$FWE). In separate 

UXOHPDNLQJDFWLRQVWKH&RPPLVVLRQestablished criteria WKURXJKZKLFKWKH15&(1) satisfies its 

$WRPLF(QHUJ\$FWUHVSRQVLELOLW\WRensure reasonable assurance of adequate protection of 

public health and safety in the construction and operation of nuclear power plants; and 

(2) VDWLVILHVLWV1(3$UHVSRQVLELOLW\WRFRQVLGHUenvironmental impacts in the construction and 

operation of nuclear power plants. 7KHUHIRUHXQGHUFXUUHQWODZWKH15&ZLOOLVVXHDQXFOHDU

power plant or materials license (including a license authorizing storage of spent fuel) when the 

15&GHWHUPLQHVWKDWDOLFHQVHDSSOLFDQWKDVPHWWKH15&¶VUHJXODWRU\VWDQGDUGVIRULVVXDQFH

of a license, addressing adequate protection of public health and safety and common defense 

DQGVHFXULW\DQGWKH15&KDVQRUHDVRQWRGRXEWWKDWLVVXDQFHRIWhe license would provide 

adequate protection. )XUWKHULIWKH15&GHWHUPLQHVWKDWDQXFOHDUSRZHUSODQWRUWKHXVHRI

nuclear materials poses a threat to public health and safety or the common defense and 

VHFXULW\WKH15&ZLOODPHQGVXVSHQGRUUHYoke nuclear power plant or materials licenses. 
Introduction 

185(*௅ 1-10 September 2014 

$OWKRXJKFHVVDWLRQRIQXFOHDUSRZHUSODQWOLFHQVLQJDQGRSHUDWLRQVZRXOGKDOWWKHIXWXUH

generation of spent fuel, other environmental impacts could result from the required 

development of replacement power sources or demand reductions. Even then, the 

environmental impacts of continued storage would not cease until sufficient repository capacity 

becomes available. 

1.6.2.2 Implementing Additional Regulatory Requirements 

Imposing new regulatory requirements, such as requiring licensees to implement hardened 

at-UHDFWRUVWRUDJHV\VWHPVUHGXFHWKHGHQVLW\RIVSHQWIXHOLQSRROVRUH[SHGLWHWUDQVIHURI

VSHQWIXHOIURPSRROVWR,6)6,VLVRXWVLGHWKHVFRSHRIWKLVSURSRVHGDFWLRQZKLFKLQFOXGHV

actions that prHVHUYHWKHHIILFLHQF\RIWKH15&¶VOLFHQVLQJSURFHVVHVZLWKUHVSHFWWRWKH

environmental impacts of continued storage$GRSWLRQRIDUHYLVHG&)5VXSSRUWHGE\

this GEIS, is not a licensing action, and does not impose new requirements on licensees or 

DSSOLFDQWV7KHUHIRUHWKH15&FDQQRWLPSRVHQHZUHTXLUHPHQWVRUUHJXODWLRQVRQWKHGXUDWLRQ

of spent fuel storage in pools tKURXJKWKLVSURSRVHGDFWLRQ,QVHSDUDWHSURFHHGLQJVWKH15&

is considering DQXSGDWHWRLWV,6)6,VHFXULW\UHTXLUHPHQWVDVGHVFULEHGin the December 

2009, Federal Register Notice )53'UDIW7HFKQLFDO%DVLVIRU5XOHPDNLQJ5HYLVLQJ

6HFXULW\5HTXLUHPHQWVIRU)DFLOLWLHV6WRULQJ61)>VSHQWQXFOHDUIXHO@DQG+/:>KLJK-level 

ZDVWH@1RWLFHRI$YDLODELOLW\DQG6ROLFLWDWLRQRI3XEOLF&RPPHQWV ́ 7KH15&KDVSURYLGHG

UHVSRQVHVWRSXEOLFFRPPHQWVRQWKLVGUDIWWHFKQLFDOEDVLV15&a,QWKHFRQWH[WRIWKH

UXOHPDNLQJWKH15&LVDOVRFRQVLGHULQJDSHWLWLRQUHTXHVWLQJWKDWWKH15&UHTXLUHKDUGHQHG

onsite storage at all power plants and away-from-UHDFWRUVWRUDJHVLWHVVHH3HWLWLRQIRU

5XOHPDNLQJ6XEPLWWHGE\&–5HVHDUFKDQG(GXFDWLRQ)RXQGDWLRQ,QF)5

2FWREHU7KHSURSRVHGUXOH, VFKHGXOHGWREHSXEOLVKHGIRUFRPPHQWLQ, will 

formally address the 2012 petition. In additionWKH15&has separately considered H[SHGLWHG

transfer of spent fuel from pools into casks DVSDUWRIOHVVRQVOHDUQHGIURPWKH0DUFK, 

earthquake and subsequent tsunami that badly damageGWKH)XNXVKLPD,1XFOHDU3RZHU3ODQW

LQ-DSDQ15&2014a, 2013b, 2012d), and it will not be separately reconsidered in this 

proceeding. 

1.6.3 Comparison of Reasonable Alternatives 

The reasonable alternatives considered here include the proposed action (revising 

10 &)5  and no actionZKLFKPD\UHVXOWLQWKH15&SXUVXLQJDQ\RIVHYHUDORSWLRQV

site-specific reviews of the environmental impacts of continued storage in each licensing 

proceeding, a generic EIS without a rule, or D&RPPLVVLRQSROLF\VWDWHPHQW. 

The proposed action and the 15&¶VSRWHQWLDORSWLRQVLQFDVHRIQRDFWLRQ are simply different 

administrative approaches for addressing the environmental impacts of continued storage 
Introduction 

September 2014 1-11 185(*௅

in 15&OLFHQVLQJprocesses&RQVLVWHQWZLWKthe 15&¶VFDWHJRULFDOH[FOXVLRQ3 in 

10 &)5 (c)(3)(i), the proposed action has no significant environmental impacts. The 

no-action alternative—LQFOXGLQJDOORI15&¶VSRWHQWLDORSWLRQVLQWKHFDVHRIQRDFWLRQ—also has 

no significant environmental impacts. Therefore, the proposed action and the no-action 

DOWHUQDWLYHLQFOXGLQJ15&¶VSRWHQWLDORSWLRQVLQFDVHRIQRDFWLRQhave the same environmental 

impacts. In subsequent chapters of thiV*(,6WKH15&FRQVLGHUVWKHSRWHQWLDOHQYLURQPHQWDO

impacts that result from continued storage. In &KDSWHUWKH15& provides a cost-benefit 

analysis of the proposed action and the no-DFWLRQDOWHUQDWLYHLQFOXGLQJ15&¶VSRWHQWLDORSWLRQV

in case of no action. 

1.7 Public and Agency Involvement 

1.7.1 Scoping Process 

7KH15&EHJDQWKHHQYLURQPHQWDOUHYLHZSURFHVVE\SXEOLVKLQJD1RWLFHRI,QWHQWWRSUHSDUH

an EIS and conduct scoping in the Federal Register RQ2FWREHU)57KH

15&FRQGXFWHGOLYHDQGZHEFDVWSXEOLFPHHWLQJVRQ1RYHPEHU15&2012e), and 

FRQGXFWHGSXEOLFZHELQDUVRQ'HFHPEHU DQG15&2012f7KH15&WUDQVFULEHG

the discussions that took place during the scRSLQJPHHWLQJVDQGZHELQDUV7KH15&UHFHLYHG

DSSUR[LPDWHO\SLHFHVRIFRPPHQWFRUUHVSRQGHQFHSULPDULO\WKURXJKWKHZHEVLWHDW

www.regulationsJRYXVLQJ'RFNHW,'15&–2012–DQGWRDOHVVHUH[WHQWE\ID[DQG

mail. The scoping period formally closed on January 2, 2013, although staff considered 

FRPPHQWVUHFHLYHGDIWHUWKLVGDWHWRWKHH[WHQWSUDFWLFDO

Scoping participants included private citizens and representatives of Tribes and State 

JRYHUQPHQWVWKH86(QYLURQPHQWDO3URWHFWLRQ$JHQF\(3$), multiple environmental and 

advocacy groups, industry, and quasi-JRYHUQPHQWDORUJDQL]DWLRQV,QDOOWKH15&LGHQWLILHG

DSSUR[LPDWHO\FRPPHQWVIURPWKHPDWHULDOVVXEPLWWHG

7KH15&UHVSRQGHGWRFRPPHQWVLQLWVWaste Confidence Generic Environmental Impact 

Statement Scoping Process Summary Report 15&FZKLFKZDVSXEOLVKHGRQ0DUFK

2013. The summary report, in accordance with 10 &)5 EFRQWDLQHGDVXPPDU\RI

FRQFOXVLRQVUHDFKHGE\WKH15&DQGLVVXHVLGHQWLILHGDVDUHVXOWRIWKHVFRping process. 

$GGLWLRQDOLQIRUPDWLRQUHJDUGLQJWKHVXPPDU\UHSRUWLVSURYLGHGLQ$SSHQGL[$$VXPPDU\RI

RXWUHDFKDQGFRUUHVSRQGHQFHUHODWHGWRWKHHQYLURQPHQWDOUHYLHZLVSURYLGHGLQ$SSHQGL[&

 

3 $FDWHJRULFDOH[FOXVLRQUHIHUVWR3... a category of actions which do not individually or cumulatively have 

DVLJQLILFDQWHIIHFWRQWKHKXPDQHQYLURQPHQWDQGZKLFKWKH&RPPLVVLRQKDVIRXQGWRKDYHQRVXFK

HIIHFWLQDFFRUGDQFHZLWKSURFHGXUHVVHWRXWLQDQGIRUZKLFKWKHUHIRUHQHLWKHUDn environmental 

assessment nor an environmental impact statement is required” (&)5). 
Introduction 

185(*௅ 1-12 September 2014 

1.7.2 Public Comments Received on the Draft GEIS and Proposed Rule 

The (3$ published a Notice RI$YDLODELOLW\LQthe Federal Register on September 13, 2013 

( )5), ZKLFKVWDUWHGWKH-day public comment period on the draft GEIS. Due to the 

October 2013 government shutdown that caused the agency to reschedule several public 

meetings, the 15&H[WHQGHGWKHpublic comment period to December 20, 2013, for a total of 98 

days ()5'XULQJWKHSXEOLFFRPPHQWSHULRGWKH15&KRVWHG 13 public meetings 

throughout the United States WRGHVFULEHWKHUHVXOWVRIWKH15&¶VHnvironmental review, answer 

questions, and accept comments on the draft GEIS and proposed Rule. $SSUR[LPDWHO\

SDUWLFLSDQWVDWWKRVHPHHWLQJVSURYLGHGQHDUO\RUDOFRPPHQWVIn addition, tKH15&

received over 33,000 written submittals. Summaries of the public comments received on the 

draft GEIS and proposed Rule and the 15&¶VUHVSRQVHVDUHSURYLGHGLQ$SSHQGL['

6HSDUDWHO\WKH15&SXEOLVKHGDGRFXPHQWFRQWDLQLQJWKHWH[WRIDOOLGHQWLILHGXQLTXH

comments, Comments on the Waste Confidence Draft Generic Environmental Impact Statement 

and Proposed Rule 15&b). 

This final GEIS—ZLWKWKHH[FHSWLRQRI&KDSWHUVDQGDQG$SSHQGLFHV'DQGI—uses 

“change bars,” indicated by vertical lines in the page margins, to denote where information has 

been revised in response to public comments, or where changes, other than minor editorial 

changes, have been made. 

1.7.3 Cooperating Agencies 

7KH15&GLGQRWLGHQWLI\DQ\FRRSHUDWLQJDJHQFLHVIRUWKHHQYLURQPHQWDOUHYLHZQRUGLG the 

15&UHFHLYHDQ\IRUPDOUHTXHVWVIRUFRRSHUDWLQJDJHQF\VWDWXV

1.8 Analytical Approach 

7KH15&¶VPHWKRGRORJ\DQGDSSURDFKWRHYDOXDWLQJWKHHQYLURQPHQWDOLPSDFWVRIFRQWLQXHG

storage follows the guidance in NUREG–Environmental Review Guidance for Licensing 

Actions Associated with NMSS Programs: Final Report 15&ZKHUHDSSOLFDEOH

This GEIS evaluates the potential environmental impacts of continued storage after the licensed 

life for reactor operations DWUHDFWRUVLWHVLQ&KDSWHUDQGDWDway-from-reactor sites in 

&KDSWHU7KHHQYLURQPHQWDOLPSDFWVDUHHYDOXDWHGIRUWKUHHWLPHIUDPHVEDVHGRQZKHQD

repository would become available. This section outlines the approach, timeframes, 

DVVXPSWLRQVDQGSUHYLRXV1(3$DVVHVVPHQWVWKH15&XVHGLn its evaluation. 

1.8.1 Approach to Impact Assessment 

To evaluate the potential environmental impacts of continued storage at reactor sites 

&KDSWHU WKH15&DVVXPHVWKDWVSHQWIXHOLVVWRUHGLQDSRRODQGLQDQ,6)6,ERWKRIZKLFK
Introduction 

September 2014 1-13 185(*௅

have already been constructed and are operating during reactor operations. Therefore, many of 

the impacts of at-reactor continued spent fuel storage can be determined by comparing onsite 

activities that occur during reactor operations to the reduced activities that occur during 

continued storage. Where appropriate, the environmental impacts during reactor operations are 

GUDZQIURPWKH/LFHQVH5HQHZDO*(,615&G), which evaluates the impacts of continued 

reactor operation. In addition, this GEIS XVHVDQDO\VHVLQ($VSUHSDUHGIRU,6)6,VDQG

UHQHZDOVRIWKRVH,6)6,OLFHQVHV

)RUWKHLPSDFWVRIFRQWLQXHGVWRUDJHDWDQ-away-from-UHDFWRU,6)6, &KDSWHUWKH15&

HYDOXDWHGWKHLPSDFWVRIDQ,6)6,RIWKHVDPHVL]HDVGHVFULEHGLQWKHFinal Environmental 

Impact Statement for the Construction and Operation of an Independent Spent Nuclear Fuel 

Storage Installation on the Reservation of the Skull Valley Band of Goshute Indians and Related 

Transportation Facility in Tooele County, Utah 15&&KDSWHUFRQWDLQVDOLVWRIWKH

assumpWLRQVXVHGLQWKDWDQDO\VLV8QOLNHLQ&KDSWHUWKHJHQHULFDQDO\VLVIRUDZD\-fromUHDFWRUVWRUDJHDWDQ,6)6,LQFOXGHVDJHQHUDOGLVFXVVLRQRIWKHFRQVWUXFWLRQRIWKHIDFLOLW\

However, the site-specific impacts of the construction and operation of any proposed awayfrom-reactor ,6)6,ZRXOGEHHYDOXDWHGE\15&DVSDUWRIWKDW,6)6,¶VOLFHQVLQJSURFHVV

)RUERWKWKHDW-reactor and away-from-UHDFWRUVWRUDJHVLWHVWKH15&DVVXPHVWKDWWKH

construction, operation, and replacement of a dry transfer system (DTS) facility is necessary at 

some point to handle the transfer of fuel. The physical characteristics of a DTS, which is based 

on well-XQGHUVWRRGWHFKQRORJ\DUHH[SODLQHGLQPRUHGHWDLOLQ&KDSWHU(see Section 2.1.4). 

The GEIS accounts for the age of storage facilities in the evaluation of impacts. )RUH[DPSOHD

storage cask that was loaded with spent fuel 40 years prior to the end of the licensed life for 

reactor operations has already been in service for 40 years at the beginning of the short-term 

timeframe and is assumed to be replaced at the beginning of the long-term timeframe (40 years 

of service at the beginning of the short-WHUPWLPHIUDPHSOXV\HDUVRIVHUYLFHRYHUWKHVKRUWterm timeframe results in a total service time of 100 years, which is the assumed replacement 

period for dry cask storage facilities). 

1.8.2 Timeframes Evaluated 

7KH15&HYDOXDWHGWKHHQYLURQPHQWDOLPSDFWVRIFRQWLQXHGVWRUDJHLQWKUHHWLPHIUDPHVWKDW

begin once the licensed life of the reactor ends—short-term storage, long-term storage, and 

indefinite storage (see )LJXUH1-1). 
Introduction 

185(*௅ 1-14 September 2014 

 

Figure 1-1. &RQWLQXHG6WRUDJH7LPHIUDPHV

The first timeframe—short-term storage—ODVWVIRU\HDUVDQGEHJLQVDIWHUWKHHQGRID

UHDFWRU¶VOLFHQVHGOLIHIRURSHUDWLRQV7KH15&HYDOXDWHGWKHHQYLURQPHQWDOLPSDFWVUHVXOWLQJ

from the following activities that occur during the short-term storage timeframe: 

x continued storage of spent fuel in spent fuel pools (at-UHDFWRURQO\DQG,6)6,V

x routine maintenance of at-UHDFWRUVSHQWIXHOSRROVDQG,6)6,VHJPDLQWHQDQFHRI

concrete pads), 

x construction and operation of an away-from-UHDFWRU,6)6,LQFOXGLQJURXWLQHPDLQWHQDQFH

and 

x KDQGOLQJDQGWUDQVIHURIVSHQWIXHOIURPVSHQWIXHOSRROVWR,6)6,V

7KHQH[WWLPHIUDPH—long-term storage—is 100 years and begins immediately after the shortterm storage timHIUDPH7KH15&HYDOXDWHGWKHHQYLURQPHQWDOLPSDFWVUHVXOWLQJIURPWKH

following activities that occur during long-term storage: 

x FRQWLQXHGVWRUDJHRIVSHQWIXHOLQ,6)6,VLQFOXGLQJURXWLQHPDLQWHQDQFH

x one-WLPHUHSODFHPHQWRI,6)6,VDQGVSHQWIXHOFDQLVWers and casks, and 

x construction and operation of a DTS (including replacement). 

Short-Term 

Storage

ͻTimeframe is 60 years beyond licensed life for reactor operations.

ͻAssumes a repository becomes available by the end of this timeframe.

Long-Term 

Storage

ͻTimeframe is for 100 years beyond the short-term storage timeframe.

ͻAssumes a repository becomes available by end of this timeframe.

Indefinite 

Storage

ͻAssumes no repository becomes available.

ͻIndefinite storage and handling of spent fuel. 
Introduction 

September 2014 1- 185(*௅

)RUWKHORQJ-WHUPVWRUDJHWLPHIUDPHWKH15&DVVXPHVWKDWDOOVSHQWIXHOKDVDOUHDG\EHHQ

moved from the spent fuel pool to dry cask storage by the end of the short-term storage 

WLPHIUDPH7KHVSHQWIXHOSRROZRXOGEHGHFRPPLVVLRQHGZLWKLQ\HDUVafter permanent 

cessation of operation, as required E\&)5  RU&)5. 

The third timeframe—indefinite storage—assumes that a geologic repository does not become 

available. In this timeframe, at-reactor and away-from-UHDFWRU,6)6,VZRXOGFRQWLQXHWRVWRUH

VSHQWIXHOLQGU\FDVNVLQGHILQLWHO\)RUWKHHYDOXDWLRQRIHQYLURQPHQWDOLPSDFWVLIQRUHSRVLWRU\

becomes available, the following activities are considered: 

x cRQWLQXHGVWRUDJHRIVSHQWIXHOLQ,6)6,VLQFOXGLQJURXWLQHPDLQWHQDQFH

x UHSODFHPHQWRI,6)6,VDQGVSHQWIXHOFDQLVWHUVDQGFDVNVHYHU\\HDUV

x construction and operation of an away-from-UHDFWRU,6)6,LQFOXGLQJUHSODFHPHQWHYHU\

100 years), and 

x construction and operation of a DTS (including replacement every 100 years). 

These activities are the same as those that would occur for long-term storage, but without a 

repository, they would occur repeatedly. 

1.8.3 Analysis Assumptions 

To evaluate the potential environmental impacts of continued storage, this GEIS makes several 

assumptions. 

x $OWKRXJKWKH15&UHFRJQL]HVWKDWWKHSUHFLVHWLPHVSHQWIXHOLVVWRUHGLQSRROVDQGGU\FDVN

storage systems will vary from one reactor to another, this GEIS makes a number of 

reasonable assumptions regarding the length of time the fuel can be stored in a spent fuel 

pool and in a dry cask before the fuel needs to be moved or the facility needs to be 

replaced. :LWKUHVSHFWWRVSHQWIXHOSRROVWRUDJHWKH15&DVVXPHVWKDWDOOVSHQWIuel is 

UHPRYHGIURPWKHVSHQWIXHOSRRODQGSODFHGLQGU\FDVNVWRUDJHLQDQ,6)6,QRODWHUWKDQ

\HDUVDIWHUWKHHQGRIWKHUHDFWRU¶VOLFHQVHGOLIHIRURSHUDWLRQ:LWKUHVSHFWWRGU\FDVN

VWRUDJHWKH15&DVVXPHVWKDWWKHOLFHQVHHXVHVD'76GXULQJORQg-term and indefinite 

storage timeframes to move the spent fuel to a new dry cask every 100 years. Similarly, the 

15&DVVXPHVWKDWWKH'76DQGWKH,6)6,SDGDUHUHSODFHGHYHU\\HDUV)RUDQ,6)6,

that reaches 100 years of age near the end of the short-WHUPVWRUDJHWLPHIUDPHWKH15&

assumes that the replacement would occur during the long-term storage timeframe. 

x %DVHGRQLWVNQRZOHGJHRIDQGH[SHULHQFHZLWKWKHVWUXFWXUHDQGRSHUDWLRQRIWKHYDULRXV

facilities that will provide continued storage, including the normal life of those facilities, the 

15&EHOLHYHVWKDWVSHQWIXHOSRROVWRUDJHFRXOGODVWIRUDERXW\HDUVEH\RQGWKHOLFHQVHG

OLIHIRURSHUDWLRQRIWKHUHDFWRUZKHUHLWLVVWRUHGDQGWKDWHDFK,6)6,ZLOOODVWDERXW

100 years. 
Introduction 

185(*௅ 1- September 2014 

x The most reasonably foreseeable assumption is that institutional controls (i.e., the continued 

regulation of spent fuel) will continue. The assumption that institutional controls will continue 

enables an appropriate and reasonable evaluation of the environmental impacts of 

continued storage over an indefinite timeframe$EVHQWWKHVWDELOLW\DQGSUHGLFWDELOLW\WKDW

follows instiWXWLRQDOFRQWUROVLQFOXGLQJEXWQRWOLPLWHGWR15&OLFHQVLQJDQGUHJXODWRU\

controls, few impacts could be reliably forecast. )RU the purpose of the analyses in this 

*(,6WKH15&DVVXPHVWKDWUHJXODWRU\FRQWURORIUDGLDWLRQVDIHW\ZLOOUHPDLQDWWKHVDPe 

OHYHORIUHJXODWRU\FRQWURODVFXUUHQWO\H[LVWVtoday. 6HFWLRQ%RI$SSHQGL[%SURYLGHV

further discussion regarding institutional controls. 

x $'76ZLOOEHEXLOWDWHDFK,6)6,ORFDWLRQGXULQJ the long-term storage timeframe to facilitate 

spent fuel transfer and handling. 

x 7KH15&DVVXPHVD-year replacement cycle for spent fuel canisters and casks. 

This DVVXPSWLRQLVFRQVLVWHQWZLWKDVVXPSWLRQVPDGHLQWKH<XFFD0RXQWDLQ)LQDO(,6

(DOE 2008). 

x The 100-\HDUUHSODFHPHQWF\FOHDOVRDVVXPHVUHSODFHPHQWRIWKH,6)6,IDFLOLW\DQG'76

x %DVHGRQFXUUHQWO\DYDLODEOHLQIRUPDWLRQWKH-year replacement cycle provides a 

reasonably conservative assumption for a storage facility that would require replacement at 

a future point in time. However, this assumption does not mean that dry cask storage 

systems and facilities need to be replaced every 100 years to maintain safe storage. 

x 5HSODFHPHQWRIWKHHQWLUH,6)6,ZRXOGRFFXURYHUWKHFRXUVHRIHDFK-year interval, 

starting at the beginning of the long-term storage timeframe DSSUR[LPDWHO\0 years after 

spent fuel would have first been transferred from the spent fuel pool into a dry cask storage 

system, which would occur DERXW\HDUVLQWRDUHDFWRU¶Vlicensed life for operations). 

x 7KH15&DVVXPHVWKDWWKHODQGXVHGIRUWKH,6)6,SDGVDQG'TS would be reclaimed after 

the facilities are demolished and, therefore, would EHXVHGDJDLQLQWKHQH[W-year 

replacement cycle. 7KH15&DVVXPHVWKHLQLWLDOUHSODFHPHQW,6)6,DQG'76ZRXOGEHEXLOW

near WKHH[LVWLQJIDFLOLWLHVThe 15&EHOLHYHVWKLVDVVXPSWLRQLVUHDVRQDEOHEHFDXVHWKH

FKDUDFWHULVWLFVRIWKHSUHYLRXVO\GLVWXUEHGODQGDUHDOUHDG\NQRZQDQGDUHVXLWDEOHIRU,6)6,

and DTS design and construction. 

x 7KH15&DVVXPHVWKDWDJLQJPDQDJHPHQWLQFOXGLQJURXWLQHPDLQWHQDQFHDFWLYities and 

programs, occurs between replacements. These “routine” or planned maintenance activities 

are distinct from the “replacement” of facilities and equipment. 

x The spent fuel is moved from the spent fuel pool to dry cask storage within the short-term 

storage timeframe. 

x 8QGHU15&UHJXODWLRQVDQXFOHDUSRZHUSODQWWKDWRSHUDWHVIRUWKHWHUPVSHFLILHGLQLWV

OLFHQVHLVUHTXLUHGWRFRPSOHWHGHFRPPLVVLRQLQJZLWKLQ\HDUVDIWHUWKHOLFHQVHGOLIHIRU

RSHUDWLRQVLQDFFRUGDQFHZLWK&)5RU8nder these regulations, a plant 

that permanently ceases operation before the term specified in its operating license is 
Introduction 

September 2014 1- 185(*௅

UHTXLUHGWRFRPSOHWHGHFRPPLVVLRQLQJZLWKLQ years after the permanent cessation of 

RSHUDWLRQ&RQVLVWHQWZLWKWKLVUHTXLUHPHQWWKH15&DVVXPHVWKDW, by the end of the shortWHUPVWRUDJHWLPHIUDPHDOLFHQVHHZLOOHLWKHUWHUPLQDWHLWV3DUWRU3DUWOLFHQVHDQG

UHFHLYHDVSHFLILF3DUW,6)6,OLFHQVHVHH &)53DUW6XESDUW&RUDSSO\WRUHFHLYH

&RPPLVVLRQDSSURYDOXQGHU&)5DRUFWRFRQWLQXHGHFRPPLVVLRQLQJ

XQGHULWV3DUWRU3DUWOLFHQVH$FFRUGLQJO\WKH15&ZRXOGFRQGXFWDQ\DSSURSULDWH

site-VSHFLILF1(3$DQDO\VLVIRUHLWKHULVVXDQFHRID3DUW,6)6,OLFHQVHXSRQWHUPLQDWLRQ

of thHOLFHQVHH¶V3DUWRU3DUWOLFHQVHRUDSSURYDOWRFRQWLQXHGHFRPPLVVLRQLQJEH\RQG

\HDUVDIWHUFHDVLQJRSHUDWLRQVLQDFFRUGDQFHZLWK &)5DRUF

)XUWKHUWKH15&DVVXPHVWKDWUHSODFLQJDQ,6)6,DQGOLFHQVLQJD'76DUHOLFHQVLQJ actions 

that would be subject to separate site-VSHFLILF1(3$UHYLHZV7KH,6)6,DQG'76ZRXOGEH

decommissioned separately. 

x &RQVWUXFWLRQRSHUDWLRQDQGUHSODFHPHQWRIWKH'76DUHDVVXPHGWRRFFXUZLWKLQWKH

long-term storage timeframe. If the DTS is built at the beginning of the long-term storage 

timeframe, it could be near the end of its useful life by the end of that storage timeframe. 

To EHFRQVHUYDWLYHWKH15&LQFOXGHGWKHLPSDFWVRIUHSODFLQJWKH'76RQHWLPHGXULQJWKH

long-term storage timeframe. 

x %HFDXVHDQDZD\-from-UHDFWRU,6)6,FRXOGVWRUHIXHOIURPVHYHUDOGLIIHUHQWUHDFWRUVWKH

earliest an away-from-UHDFWRU,6)6,ZRXOGHQWHUWKHVKRUW-term timeframe is when the first of 

these reactors reaches the end of its licensed life for operation. 

x The amount of spent fuel generated is based on the assumption that the nuclear power 

plant operates for 80 years (40-year initial term plus two 20-year renewed terms).4

x $W\SLFDOVSHQWIXHOSRRORIPHWULFWRQVRIuranium storage capacity reaches its licensed 

capacity limit about \HDUVLQWRWKHOLFHQVHGOLIHIRURSHUDWLRQRIDUHDFWRU$WWKDWSRLQW

some of the spent fuel would need to be removed from the spent fuel pool and transferred to 

a dry cask storage system at either an at-reactor or away-from-UHDFWRU,6)6,

x The environmental impacts of constructing a “spent fuel pool island,” which allows the spent 

fuel pool to be isolated from other reactor plant systems to facilitate decommissioning, are 

considered within the analysis of cumulative effeFWVLQ&KDSWHU%HFDXVHDQHZVSHQWIXHO

pool cooling system would be smaller in size and have fewer associated impacts than 

H[LVWLQJVSHQWIXHOSRROFRROLQJV\VWHPVWKHHQYLURQPHQWDOLPSDFWVRIRSHUDWLQJWKHQHZ

spent fuel pool cooling system in support of continued storage in the spent fuel pool, would 

EHERXQGE\WKHLPSDFWVRIRSHUDWLQJWKHH[LVWLQJFRROLQJV\VWHPGHVFULEHGLQ&KDSWHU

x ,WLVDVVXPHGWKDWDQ,6)6,RIVXIILFLHQWVL]HWRKROGDOOVSHQWIXHOJHQHUDWHGZLOOEH

constructed during the licensed life for operation. 

 

4 7KH&RPPLVVLRQ¶VUHJXODWLRQVSURYLGHWKDWUHQHZHGRSHUDWLQJOLFHQVHVPD\EHVXEVHTXHQWO\UHQHZHG

although no licensee has yet submitted an application for such a subsequent renewal. This GEIS 

included two renewals as a conservative assumption in evaluating potential environmental impacts. 
Introduction 

185(*௅ 1-18 September 2014 

x Sufficient low-OHYHOZDVWH//:GLVSRVDOFDSDFLW\ZLOOEHPDGHDYDLODEOHZKHQQHHGHG

+LVWRULFDOO\WKHGHPDQGIRU//:GLVSRVDOFDSDFLW\KDVEHHQPHWE\SULYDWHLQGXVWU\The 

15&H[SHFWVWKDWWKLVWUHQGZLOOFRQWLQXHLQWKHIXWXUH)RUH[DPSOHLQUHVSRQVHWRGHPDQG

IRU//:GLVSRVDOFDSDFLW\:DVWH&RQWURO6SHFLDOLVWV//&RSHQHGD//:GLVSRVDOIDFLOLW\LQ

$QGUHZV&RXQW\7H[DV, RQ$SULO

The analyses in this GEIS DUHEDVHGRQFXUUHQWWHFKQRORJ\DQGUHJXODWLRQV$SSHQGL[%

provides further information supporting the analysis assumptions. These analyses are not 

intended to be, and should not be interpreted as, representative of any specific storage facility 

or site in the United States where spent fuel is currently stored or could be stored in the future. 

1.8.4 Other Environmental Analyses 

1XPHURXV15&SURFHHGLQJVUHJXODWLRQVRU1(3$GRFXPHQWVDGGUHVVWKHHQYLURQPHQWDO

LPSDFWVRIRWKHU15&-regulated activities: the licensed life for operation of a commercial 

nuclear poweUIDFLOLW\WKHOLFHQVHGOLIHRIDQ,6)6,VSHQWIXHOWUDQVSRUWDWLRQWKHQXFOHDUIXHO

cycle, license termination, and ultimate spent fuel disposal. This is depicted in )LJXUH 1-2. 

$ EULHIGHVFULSWLRQRIWKHVHRWKHU1(3$GRFXPHQWVDQGUHJXODWLRQV is presented below. 

1(3$ documents used to support the analyses in this GEIS are listed in Table 1-1. 

The storage of spent fuel during the initial licensed term for operation of a nuclear reactor is 

considered within the site-specific EIS for either a &)53DUW or 10 &)53DUW licensing 

review. 

The impacts from renewing the operating licenses for commercial nuclear power plants for up to 

an additional 20 years are evaluated in site-VSHFLILF(,6VZKLFKWLHURIIWKH/LFHQVH5HQHZDO

GEIS (15& 2013d)7KH/LFHQVH5HQHZDO*(,6DGGUHVVHVVSHQWIXHOVWRUDJHduring the 

OLFHQVHUHQHZDOWHUP7KHILQGLQJVIURPWKH/LFHQVH5HQHZDO*(,6ZLWKUHVSHFWWR

environmental impacts of continued nuclear power plant operations have been codified in 

regulation (in &)53DUW, 7DEOH%-RI$SSHQGL[%WR6XESDUW$). 

7KHLPSDFWVIURPVWRUDJHRIVSHQWIXHOGXULQJWKHLQLWLDODQGUHQHZHGOLFHQVHGWHUPVRIDQ,6)6,

are addressed in site-VSHFLILF1(3$UHYLHZVIRUOLFHQVHHVWKDWHOHFWWRFRQVWUXFW,6)6,VZLWK

VSHFLILFOLFHQVHVXQGHU&)53DUW)RUWKRVHOLFHQVHHVWKDWHOHFWWRFRQVWUXFWDQ,6)6,

under a general license, the environmental review has already been conducted and 

GRFXPHQWHGLQDQ($15&

The impacts from decommissioning nuclear power plants have previously been evaluated in 

Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities 

Supplement 1 Regarding the Decommissioning of Nuclear Power Reactors Main Report

(Decommissioning GEIS) (15& 2002). 
September 2014 1-19 185(*௅

Introduction Figure 1-21(3$$QDO\VHVIRU15&$FWLYLWLHV

Nuclear Power Plants and ISFSIs Licensed Life for Operations,QLWLDO/LFHQVLQJ(,6V/LFHQVH5HQHZDOV*(,6DQG6(,6VDQG

/LFHQVH$PHQGPHQWV($VIRUQXFOHDUSRZHUSODQWV

,QLWLDO/LFHQVLQJ(,6VDQG($VDQG/LFHQVH5HQHZDO($VIRU,6)6,VTransportation Impacts - &)5

8UDQLXP)XHO&\FOH- &)5

Nuclear Power Plant DecommissioningDecommissioning GEIS

Nuclear Power Plant License Termination /LFHQVH7HUPLQDWLRQ*(,6

Continued Storage of Spent Fuel$FWLYLW\FRYHUHGE\WKLV*(,6

Ultimate Disposal of Spent FuelWill be evaluated in a future EISGeneric Discussion of Impacts of a Repository - Table S-3
Introduction 

NU5(*௅ 1-20 September 2014 

Table 1-1/LVWRI1(3$ Documents Used LQ3UHSDUDWLRQRIWKLVGEIS

Document Agency Date Availability 

)LQDO(,6IRUD*HRORJLF5HSRVLWRU\IRUWKH

'LVSRVDORI6SHQW1XFOHDU)XHODQG+LJK-

/HYHO5DGLRDFWLYH:DVWHDW<XFFD

0RXQWDLQ1\H&RXQW\1HYDGDDQGLWV

supplements 

DOE June 2008 Online at www.energy.gov 

0/(a)

Generic EISs 

)LQDO*HQHULF(,6RQDecommissioning of 

1XFOHDU)DFLOLWLHV6XSSOHPHQW5HJDUGLQJ

WKH'HFRPPLVVLRQLQJRI1XFOHDU3RZHU

Reactors 

15& November 2002 NUREG–(b)

0/

)LQDO*HQHULF(,6RQ+DQGOLQJDQG

6WRUDJHRI6SHQW/LJKW:DWHU3RZHU

5HDFWRU)XHO

15& $XJXVW NUREG–(b)

0/

ISFSI Licensing 

($IRU&)53DUW/LFHQVLQJ

Requirements for the Independent Storage 

RI6SHQW)XHODQG+LJK-/HYHO5DGLRDFWLYH

Waste 

15& $XJXVW NUREG–1092(b)

0/

($IRU&)53DUW3URSRVHG5XOHRQ

6WRUDJHRI6SHQW1XFOHDU)XHOLQ15&-

$SSURYHG6WRUDJH&DVNVDW1XFOHDU3RZHU

Reactor Sites 

15& 0DUFK 0/

)LQDO(,6IRUWKH&RQVWUXFWLRQDQG

Operation of an Independent Spent 

1XFOHDU)XHO6WRrage Installation on the 

5HVHUYDWLRQRIWKH6NXOO9DOOH\%DQGRI

Goshute Indians and Related 

7UDQVSRUWDWLRQ)DFLOLW\LQ7RRHOH&RXQW\

Utah 

15& December 2001 NUREG–(b)

0/

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&RQVWUXFWLRQDQG2SHUDWLRQRIWKH

+% 5RELQVRQ,QGHSHQGHQW6SHQW)XHO

Storage Installation 

15& 0DUFK 0/(a)

(QYLURQPHQWDO$VVHVVPHQWIRUWKH7URMDQ

,QGHSHQGHQW6SHQW)XHO6WRUDJH

Installation 

15& 1RYHPEHU 0/(a)

(QYLURQPHQWDO$VVHVVPHQWIRUWKH/LFHQVH

5HQHZDORIWKH*HQHUDO(OHFWULF0RUULV

2SHUDWLRQ,QGHSHQGHQW6SHQW)XHO6WRUDJH

,QVWDOODWLRQLQ0RUULV,OOLQRLV

15& November 2004 0/(a)
Introduction 

September 2014 1-21 185(*௅

Table 1-1/LVWRI1(3$'RFXPHQWV8VHGLQ3UHSDUDWLRQRIWKLVGEIS FRQW¶G

Document Agency Date Availability 

)LQDO(QYLURQPHQWDO,PSDFW6WDWHPHQWIRU

WKH&RQVWUXFWLRQDQG2SHUDWLRQRIDQ

,QGHSHQGHQW6SHQW)XHO6WRUDJH

Installation WR6WRUHWKH7KUHH0LOH,VODQG

8QLW6SHQW)XHODWWKH,GDKR1DWLRQDO

(QJLQHHULQJDQG(QYLURQPHQWDO/DERUDWRU\

15& 0DUFK NUREG–(b)

0/

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&RQVWUXFWLRQDQG2SHUDWLRQRIWKH2FRQHH

1XFOHDU6WDWLRQ,QGHSHQGHQW6SHQW)XHO

Storage Installation - Redacted 

15& October 1988 0/(a) (Redacted) 

(QYLURQPHQWDO$VVHVVPHQW5HODWHGWRWKH

&RQVWUXFWLRQDQG2SHUDWLRQRIWKH&DOYHUW

&OLIIV,QGHSHQGHQW6SHQW)XHO6WRUDJH

Installation – Redacted 

15& 0DUFK 0/(a) (Redacted) 

(QYLURQPHQWDO$VVHVVPHQWIRU3URSRVHG

5HQHZDORI&DOYHUW&OLIIV1XFOHDU3RZHU

3ODQW,QGHSHQGHQW6SHQW)XHO6WRUDJH

Installation 

15& $SULO 0/(a)

(QYLURQPHQWDO$VVHVVPHQW5HODWHGWRWKH

&RQVWUXFWLRQDQG2SHUDWLRQRIWKH)RUW6W

9UDLQ,QGHSHQGHQW6SHQW)XHO6WRUDJH

Installation 

15& )HEUXDU\ 0/(a) (Redacted) 

(QYLURQPHQWDO$VVHVVPHQW5HODWHGWRWKH

&RQVWUXFWLRQDQG2SHUDWLRQRIWKH

+XPEROGW%D\,QGHSHQGHQW6SHQW)XHO

Storage Installation 

15& 2FWREHU 0/

Notice of Issuance of Environmental 

$VVHVVPHQWDQG)LQGLQJRI1R6LJQLILFDQW

Impact for the DiDEOR&DQ\RQ,QGHSHQGHQW

6SHQW)XHO6WRUDJH,QVWDOODWLRQ

15& October 2003 0/

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6HFR,QGHSHQGHQW6SHQW)XHO6WRUDJH

Installation 

15& $XJXVW 0/(a) (Redacted) 

(QYLURQPHQWDO$VVHVVPHQW5HODWHGWRWKH

&RQVWUXFWLRQDQG2SHUDWLRQRIWKH1RUWK

$QQD,QGHSHQGHQW6SHQW)XHO6WRUDJH

Installation 

15& 0DUFK 0/(a) (Redacted) 
Introduction 

NU5(*௅ 1-22 September 2014 

Table 1-1/LVWRI1(3$'RFXPHQWV8VHGLQ3UHSDUDWLRQRIWKLVGEIS FRQW¶G

Document Agency Date Availability 

Reactor License Renewals 

Generic Environmental Impact Statement 

IRU/LFHQVH5HQHZDORI1XFOHDU3ODQWV

Rev. 1 

15& 0D\ NUREG–(b)

9RO0/$

9RO0/$

9RO0/$

Supplemental Environmental Impact 

6WDWHPHQWIRU:ROI&UHHN*HQHUDWLQJ

6WDWLRQ/LFHQVH5HQHZDO

15& 0D\ NUREG–6XSSOHPHQW

32(b)

New Reactor Licensing 

Environmental Impact Statement for the 

&RPELQHG/LFHQVH&2/IRU(QULFR)HUPL

Unit 3 

15& January 2013 NUREG–(b)

9RO0/$

9RO0/$

9RO0/$

9RO0/$

Environmental Impact Statement for 

&RPELQHG/LFHQVHV&2/VIRU6RXWK

7H[DV3URMHFW(OHFWULF*HQHUDWLQJ6WDWLRQ

Units 3 and 4 

15& )HEUXDU\ NUREG–(b)

9RO0/

9RO0/$

Environmental Impact Statement for the 

&RPELQHG/LFHQVH&2/IRU&DOYHUW&OLIIV

1XFOHDU3RZHU3ODQW8QLW

15& 0D\ NUREG–(b)

0/$

)LQDO Environmental Impact Statement for 

&RPELQHG/LFHQVHV&2/VIRU:LOOLDP

6WDWHV/HH,,,1XFOHDU6WDWLRQ8QLWV

and 2 

15& December 2013 NUREG–2111

9RO0/3340$0

9RO0/3340$

9RO0/$

Previous Waste Confidence Rules and Decisions 

Federal Register Notice – 3&RQVLGHUDWLRQ

of Environmental Impacts of Temporary 

6WRUDJHRI6SHQW)XHO$IWHU&HVVDWLRQRI

5HDFWRU2SHUDWLRQ:DVWH&RQILGHQFH

'HFLVLRQ8SGDWH)LQDO5XOHV ́

15& December 2010 )5

Federal Register Notice – “Waste 

&RQILGHQFH'HFLVLRQ5HYLHZ6WDWXV ́

15& December 1999 )5

Federal Register Notice – 3&RQVLGHUDWLRQ

of Environmental Impacts of Temporary 

6WRUDJHRI6SHQW)XHO$IWHU&HVVDWLRQRI

5HDFWRU2SHUDWLRQDQG:DVWH&RQILGHQFH

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15& September 

1990 

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Introduction 

September 2014 1-23 185(*௅

Table 1-1/LVWRI1(3$'RFXPHQWV8VHGLQ3UHSDUDWLRQRIWKLVGEIS FRQW¶G

Document Agency Date Availability 

Federal Register Notice – “Waste 

&RQILGHQFH'HFLVLRQDQG5HTXLUHPHQWVIRU

/LFHQVHH$FWLRQV5HJDUGLQJWKH

'LVSRVLWLRQRI6SHQW)XHO8SRQ([SLUDWLRQ

RI5HDFWRU2SHUDWLQJ/LFHQVHV)LQDO

Rules” 

15& $XJXVW )5

(a) $'$06FDQEHDFFHVVHGonline$FFHVVLRQQXPEHUVDUHSURYLGHGIRU($V

(b) NUREGs can be found online at the 15& website. 

The environmental impacts of portions of the uranium fuel cycle that occur before new fuel is 

delivered to the plant and after spent fuel is sent to a disposal site have been evaluated and are 

codified in regulation (&)57DEOH6–3). 

Impacts from the transportation of fuel and waste to and from a nuclear power reactor are 

codified in regulation (&)57Dble S–4). 

The environmental impacts of residual radioactivity remaining after license termination are 

addressed in the Generic Environmental Impact Statement in Support of Rulemaking on 

Radiological Criteria for License Termination of NRC-Licensed Nuclear Facilities: Final Report

/LFHQVH7HUPLQDWLRQ5XOH*(,615&

The environmental impacts of a specific geologic repository will be addressed in the EIS that the 

DOE is required to submit for any geologic repository application that it submits. 

1.8.5 Significance of Environmental Impacts 

7KH15&KDVHVWDEOLVKHGDVWDQGDUGRIsignificance for assessing environmental issues. In 

15&HQYLURQPHQWDOUHYLHZVVLJQLILFDQFHLQGLFDWHVWKHLPSRUWDQFHRIOLNHO\HQYLURQPHQWDO

impacts and is determined by considering two variables: context and intensity&RQWH[WLVWKH

geographic, biophysical, and social setting in which the effects will occur. Intensity refers to the 

VHYHULW\RIWKHLPSDFWLQZKDWHYHUFRQWH[WLWRFFXUV7KH15&XVHVDWKUHH-level standard of 

VLJQLILFDQFHEDVHGXSRQWKH3UHVLGHQW¶V&RXQFLORQ(QYLURQPHQWDO4XDOLW\JXLGHOLQHV

(40 &)5 

60$//—Environmental effects are not detectable or are so minor that they will neither 

GHVWDELOL]HQRUQRWLFHDEO\DOWHUDQ\LPSRUWDQWDWWULEXWHRIWKHUHVRXUFH)RUWKHSXUSRVHV

RIDVVHVVLQJUDGLRORJLFDOLPSDFWVWKH&RPPLVVLRQKDVFRQFOXGHGWhat radiological 

LPSDFWVWKDWGRQRWH[FHHGSHUPLVVLEOHOHYHOVLQWKH&RPPLVVLRQ¶VUHJXODWLRQVDUH

considered small. 
Introduction 

NU5(*௅ 1-24 September 2014 

02'(5$7(—Environmental effects are sufficient to alter noticeably, but not to 

destabilize, important attributes of the resource. 

/$5*(—Environmental effects are clearly noticeable and are sufficient to destabilize 

important attributes of the resource. 

)RULVVXHVLQZKLFKWKHVLJQLILFDQFHGHWHUPLQDWLRQLVEDVHGRQULVNLHWKHSUREDELOLW\RI

occurrence as well as the potential consequences), the probability of occurrence, as well as the 

potential consequences, have been factored into the determination of significance. )RUVRPH

resource areas, the impact determination language is specific to the authorizing regulation, 

H[HFXWLYHRUGHU or guidance. 

1.8.6 Issues Eliminated from Review in this GEIS 

7KH15&LVHYDOXDWLQJWKHFRQWLQXHGVWRUDJHRIFRPPHUFLDOVSHQWIXHOLQWKLVGEIS. Thus, 

certain topics are not addressed because they are not within the scope of this review. These 

topics include: 

x noncommercial spent fuel (e.g., defense waste), 

x commercial +/: generated from reprocessing, 

x greater-than-class-&//:

x advanced reactors (e.g., high-temperature and gas-cooled reactors), 

x foreign spent fuel, 

x nonpower reactor (e.g., test and research reactors), 

x need for nuclear power, and 

x reprocessing of commercial spent fuel. 

The Waste Confidence Generic Environmental Impact Statement Scoping Process Summary 

Report (15&F) and $SSHQGL['provide additional details on topics that are considered 

out of scope for this GEIS. 

1.8.7 GEIS Contents 

The subsequent chapters of this GEIS DUHRUJDQL]HGDVIROORZV&KDSWHUGHVFULEHVW\SLFDO

facility characteristics and activities that are used to assess environmental impacts of continued 

VWRUDJH&KDSWHUGHVFULEHVWKHDIIHFWHGHQYLURQPHQW&KDSWHUVDQGLQFOXGHDQDO\VHVRI

potential environmental impacts of at-UHDFWRUVWRUDJH&KDSWHUDQGDZD\-from-reactor 

VWRUDJH&KDSWHU&KDSWHUHYDOXDWHVWKHFXPXODWLYHLPSDFWVRIFRQWLQXHGVWRUDJHZLWK

RWKHUUHDVRQDEOHSDVWSUHVHQWDQGUHDVRQDEO\IRUHVHHDEOHDFWLRQV&KDSWHUSURYLdes costbenefit analyses of the SURSRVHGDFWLRQDQGWKH15&¶VRSWLRQVLQWKHFDVHRIQRDFWLRQ as well 
Introduction 

September 2014 1- 185(*௅

as the 15&¶Vrecommendation on which alternative (the proposed action or no action) is the 

preferred alternative&KDSWHUVXPPDUL]HVWKH environmental impacts of continued storage 

analyzed in the preceding chapters&KDSWHUSURYLGHVDOLVWRIWKHVWDIIZKRDXWKRUHGthis 

GEIS. &KDSWHUSURYLGHVDQLQGH[RIWHUPVXVHGWKURXJKRXWthe *(,6DQG&KDSWHU

provides a glossary. 

$SSHQGLFHVWRWKLVGEIS provide the following additional information: 

x $SSHQGL[$– 6FRSLQJ&RPPHQWV

x $SSHQGL[%– 7HFKQLFDO)HDVLELOLW\RI&RQWLQXHG6WRUDJHDQG5HSRVLWRU\$YDLODELOLW\

x $SSHQGL[&– 2XWUHDFKDQG&RUUHVSRQGHQFH

x $SSHQGL['– 'UDIW*(,6DQG3URSRVHG5XOH&RPPHQW6XPPDULHVDQG5HVSRQVHV

x $SSHQGL[(– $QDO\VLVRI6SHQW)XHO3RRO/HDNV

x $SSHQGL[)– 6SHQW)XHO3RRO)LUHV

x $SSHQGL[*– 6SHQW)XHO6WRUDJH)DFLOLWLHV

x $SSHQGL[+– (VWLPDWHG&RVWVRI$OWHUQDWLYHV

x $SSHQGL[,– High-%XUQXS)XHO. 

1.9 Other Applicable Federal Requirements 

Atomic Energy Act of 1954, as amended - 7KH$WRPLF(QHUJ\$FWRIDVDPHQGHG

SURYLGHVIXQGDPHQWDOMXULVGLFWLRQDODXWKRULW\WRWKH'2(DQGWKH15&RYHUJRYHUQPHQWDODQG

FRPPHUFLDOXVHRIQXFOHDUPDWHULDOV7KLV$FWHQVXUHVSURSHUPDQDJHPHQWSURGXFWLRQ

possession, and use of UDGLRDFWLYHPDWHULDOV7RFRPSO\ZLWKWKH$FWthe 15&KDVHVWDEOLVKHG

requirements published in Title 10 of the Code of Federal Regulations. 

7KLV$FWJLYHVthe 15&DXWKRULW\WRUHJXODWHWKHSRVVHVVLRQWUDQVIHUVWRUDJHDQGGLVSRVDORI

nuclear materials, as well as aspects of transportation packaging design for radioactive 

PDWHULDOVWKDWLQFOXGHWHVWLQJIRUSDFNDJLQJFHUWLILFDWLRQ7KLV$FWJLYHVthe (3$WKHDXthority to 

develop standards for the protection of the environment and public health from radioactive 

material. 

National Environmental Policy Act of 1969, as amended – The 15&KDVSUHSDUHGWKLVGEIS 

LQDFFRUGDQFHZLWKWKH15&¶VLPSOHPHQWLQJUHJXODWLRQVIRU 1(3$&)53DUW

Energy Reorganization Act of 1974, as amended - 7KH(QHUJ\5HRUJDQL]DWLRQ$FWRI

$FWRIDVDPHQGHGHVWDEOLVKHGWKH15&8QGHUWKH$WRPLF(QHUJ\$FWRID

VLQJOHDJHQF\WKH$WRPLF(QHUJ\&RPPLVVLRQKDGUHVSRQVLEility for the development and 

production of nuclear weapons and for both the development and the safety regulation of the 

FLYLOLDQXVHVRIQXFOHDUPDWHULDOV7KH$FWRIVSOLWWKHVHIXQFWLRQVDVVLJQLQJWRRQH
Introduction 

NU5(*௅ 1- September 2014 

agency, now the DOE, the responsibility for the development and production of nuclear 

weapons, promotion of nuclear power, and other energy-UHODWHGZRUNDQGDVVLJQLQJWRWKH15&

WKHUHJXODWRU\ZRUNZKLFKGRHVQRWLQFOXGHUHJXODWLRQRIGHIHQVHQXFOHDUIDFLOLWLHV7KH$FWRI

JDYHWKH&RPPLVsion its collegial structure and established its major offices. The later 

DPHQGPHQWWRWKH$FWRIDOVRSURYLGHGSURWHFWLRQVIRUHPSOR\HHVZKRLGHQWLI\QXFOHDU

safety concerns. 

Nuclear Waste Policy Act of 1982, as amended - 7KH1XFOHDU:DVWH3ROLF\$Ft provides for 

the research and development of repositories for the disposal of high-level radioactive waste, 

spent fuel, and low-OHYHOUDGLRDFWLYHZDVWH7KH$FWDVVLJQVUHVSRQVLELOLW\IRUWKHFRQVWUXFWLRQ

of a deep geologic repository to the DOE. 

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petition an agency for the issuance, amendment, or repeal of a rule. It also provides standards 

for judicial review of agency actions. 

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statements of policy, instructions to staff that affect a member of the public, and, upon request, 

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certain H[FHSWLRQVIRUPHHWLQJVRQPDWWHUVVXFK DVQDWLRQDOVHFXULW\7KH3ULYDF\$FWOLPLWV

release of certain information about individuals. 

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effective, and that, before being made effective, every "majoUUXOHVLWEHIRUH&RQJUHVVIRU

 days, during which time the rule can be subjected to an accelerated process that can lead 

to a statutory modification or disapproval of the rule. 
Introduction 

September 2014 1- 185(*௅

1.10 References 

&)53DUWCode of Federal Regulations, Title 10, Energy, 3DUW3'RPHVWLF/LFHQVLQJRI

3URGXFWLRQDQG8WLOL]DWLRQ)DFLOLWLHV ́:DVKLQJWRQ'&

&)53DUWCode of Federal Regulations, Title 10, Energy, 3DUW3(QYLURQPHQWDO

3URWHFWLRQ5HJXODWLRQVIRU'RPHVWLF/LFHQVLQJDQG5HODWHG5HJXODWRU\)XQFWLRQV.” 

:DVKLQJWRQ'&

&)53DUWCode of Federal Regulations, Title 10, Energy, 3DUW3/LFHQVHV

&HUWLILFDWLRQVDQG$SSURYDOVIRU1XFOHDU3RZHU3ODQWV ́:DVKLQJWRQ'&

&)53DUWCode of Federal Regulations, Title 10, Energy, 3DUW3/Lcensing 

5HTXLUHPHQWVIRUWKH,QGHSHQGHQW6WRUDJHRI6SHQW1XFOHDU)XHO+LJK-/HYHO5DGLRDFWLYH

Waste, and Reactor-5HODWHG*UHDWHU7KDQ&ODVV&:DVWH ́:DVKLQJWRQ'&

&)53DUWVWKURXJKCode of Federal Regulations, Title 40, Protection of 

Environment3DUWV33XUSRVH3ROLF\DQG0DQGDWH ́WKURXJK37HUPLQRORJ\DQG

,QGH[ ́:DVKLQJWRQ'&

)5-XO\3'HQLDORI3HWLWLRQIRU5XOHPDNLQJ ́Federal Register, U.S. Nuclear 

5HJXODWRU\&RPPLVVLRQ:DVKLQJWRQ'&

)52FWREHU36WRUDJHDQG'LVSRVDORI1XFOHDU:DVWH ́Federal Register, 

861XFOHDU5HJXODWRU\&RPPLVVLRQ:DVKLQJWRQ'&

)5$XJXVW3:DVWH&RQILGHQFH'HFLVLRQDQG5HTXLUHPHQWVIRU/LFHQVHH

$FWLRQV5HJDUGLQJWKH'LVSRVLWLRQRI6SHQW)XHO8SRQ([SLUDWLRQRI5HDFWRU2SHUDWLQJ

/LFHQVHV)LQDO5XOHV ́Federal Register861XFOHDU5HJXODWRU\&RPPLVVLRQ

Washington, '&

)5$XJXVW3:DVWH&RQILGHQFH'HFLVLRQ ́Federal Register, U.S. Nuclear 

5HJXODWRU\&RPPLVVLRQ:DVKLQJWRQ'&

)56HSWHPEHU3&RQVLGHUDWLRQRI(QYLURQPHQWDO,PSDFWVRI7HPSRUDU\

6WRUDJHRI6SHQW)XHO $IWHU&HVVDWLRQRI5HDFWRU2SHUDWLRQDQG:DVWH&RQILGHQFH'HFLVLRQ

5HYLHZ)LQDO5XOHV ́Federal Register861XFOHDU5HJXODWRU\&RPPLVVLRQ

Washington, '&

)56HSWHPEHU3:DVWH&RQILGHQFH'HFLVLRQ5HYLHZ ́Federal Register, 

U.S1XFOHDU5HJXODWRU\&RPPLVVLRQ:DVKLQJWRQ'&
Introduction 

NU5(*௅ 1-28 September 2014 

)5'HFHPEHU3:DVWH&RQILGHQFH'HFLVLRQ5HYLHZ6WDWXV.” Federal 

Register861XFOHDU5HJXODWRU\&RPPLVVLRQ:DVKLQJWRQ'&

)5'HFHPEHU3'UDIW7HFKQLFDO%DVLVfor Rulemaking Revising Security 

5HTXLUHPHQWVIRU)DFLOLWLHV6WRULQJ61)DQG+/:1RWLFHRI$YDLODELOLW\DQG6ROLFLWDWLRQRI

3XEOLF&RPPHQWV.” Federal Register861XFOHDU5HJXODWRU\&RPPLVVLRQ:DVKLQJWRQ'&

)5'HFHPEHU3&RQVLGHration of Environmental Impacts of Temporary 

6WRUDJHRI6SHQW)XHO$IWHU&HVVDWLRQRI5HDFWRU2SHUDWLRQ:DVWH&RQILGHQFH'HFLVLRQ

8SGDWH)LQDO5XOHV ́Federal Register861XFOHDU5HJXODWRU\&RPPLVVLRQ

Washington, '&

)5'HFHPEHU3:DVWH&RQILGHQFH'HFLVLRQ8SGDWH ́Federal Register, 

861XFOHDU5HJXODWRU\&RPPLVVLRQ:DVKLQJWRQ'&

)52FWREHU33HWLWLRQIRU5XOHPDNLQJ6XEPLWWHGE\&-10 Research and 

(GXFDWLRQ)RXQGDWLRQ,QF ́Federal Register, U.S. NuclHDU5HJXODWRU\&RPPLVVLRQ

:DVKLQJWRQ'&

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Storage of Spent )XHO $IWHU&HVVDWLRQRI5HDFWRU2SHUDWLRQ ́Federal Register, U.S. Nuclear 

5HJXODWRU\&RPPLVVLRQ:DVKLQJWRQ'&

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Federal Register, U.S. (QYLURQPHQWDO3URWHFWLRQ$JHQF\:DVKLQJWRQ'&

)51RYHPEHU3:DVWH&RQILGHQFH—&RQWLQXHG6WRUDJHRI6SHQW1Xclear 

)XHO ́Federal Register, U.S. 1XFOHDU5HJXODWRU\&RPPLVVLRQ:DVKLQJWRQ'&

$GPLQLVWUDWLYH3URFHGXUHV$FW, as amended86&et seq. 

$WRPLF(QHUJ\$FWRI, as amended. 86&et seq. 

&RQJUHVVLRQDO5HYLHZ$FW86&–808. 

DOE (U.S. Department of Energy). 2008. Final Supplemental Environmental Impact Statement 

for a Geologic Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive 

Waste at Yucca Mountain, Nye County, Nevada. DOE EIS–)–S1, Office of &LYLOLDQ

5DGLRDFWLYH:DVWH0DQDJHPHQW/DV9HJDV1HYDGD$FFHVVLRQ1R0/

DOE (U.S. Department of Energy). 2013. Strategy for the Management and Disposal of Used 

Nuclear Fuel and High-Level Radioactive Waste:DVKLQJWRQ'&$FFHVVLRQ

No. 0/$
Introduction 

September 2014 1-29 185(*௅

(QHUJ\5HRUJDQL]DWLRQ$FWRIDVDPHQGHG86& et seq. 

)UHHGRPRI,QIRUPDWLRQ$FW86&

*RYHUQPHQWLQWKH6XQVKLQH$FWRI86&E

Minnesota v. NRC (U.S. Nuclear Regulatory Commission). )G'&&LU. 1

1DWLRQDO(QYLURQPHQWDO3ROLF\$FWRI 1(3$DVDPHQGHG. 42 86& et seq. 

New York v. NRC (State of New York et al. v. U.S. Nuclear Regulatory Commission). )d 

'&&LU 2012). $FFHVVLRQ1R0/$

15&861XFOHDU5HJXODWRU\&RPPLVVLRQEnvironmental Assessment for 10 CFR 

Part 72 “Licensing Requirements for the Independent Spent Fuel and High-Level Radioactive 

Waste.” NUREG–1092, :DVKLQJWRQ'&0/

15&861XFOHDU5HJXODWRU\&RPPLVVLRQEnvironmental Assessment and Finding of 

No Significant Impact for Proposed Rule Entitled, “Storage of Spent Nuclear Fuel in NRCApproved Storage Casks at Nuclear Power Reactor Sites. ́:DVKLQJWRQ'&$FFHVVLRQ

No. 0/

15&861XFOHDU5HJXODWRU\&RPPLVVLRQGeneric Environmental Impact Statement 

in Support of Rulemaking on Radiological Criteria for License Termination of NRC-Licensed 

Nuclear Facilities: Final Report. NUREG–9ROXPH:DVKLQJWRQ'&$Fcession 

No. 0/

15&861XFOHDU5HJXODWRU\&RPPLVVLRQFinal Environmental Impact Statement for 

the Construction and Operation of an Independent Spent Nuclear Fuel Storage Installation on 

the Reservation of the Skull Valley Band of Goshute Indians and Related Transportation Facility 

in Tooele County, Utah. NUREG–9ROXPH:DVKLQJWRQ'& $FFHVVLRQ

No. 0/.

15&861XFOHDU5HJXODWRU\&RPPLVVLRQFinal Generic Environmental Impact 

Statement on Decommissioning of Nuclear Facilities Supplement 1 Regarding the 

Decommissioning of Nuclear Power Reactors Main Report. NUREG–6XSSOHPHQW

9ROXPH:DVKLQJWRQ'&$FFHVVLRQ1R0/

15&861XFOHDU5HJXODWRU\&RPPLVVLRQEnvironmental Review Guidance for 

Licensing Actions Associated with NMSS Programs: Final Report. NUREG–

Washington, '&$FFHVVLRQ1R0/

15&861XFOHDU5HJXODWRU\&RPPLVVLRQD0HPRUDQGXPDQG2UGHUGDWHG$XJXVW

UHJDUGLQJ33HWLWLRQWR6XVSHQG)LQDO'HFLVLRQRQ$OO3HQGLQJ5HDFWRU/LFHQVLQJ
Introduction 

NU5(*௅ 1-30 September 2014 

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No. 0/$

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GDWHG-XO\UHJDUGLQJ3$SSURDFKIRU$GGUHVVLQJ3ROLF\,VVXHV5HVXOWLQJIURP&RXUW

Decision to VaFDWH:DVWH&RQILGHQFH'HFLVLRQDQG5XOH ́&206(&<-12-:DVKLQJWRQ

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15&861XFOHDU5HJXODWRU\&RPPLVVLRQ2012d. Program Plans for Tier 3 

Recommendations6(&<-12-:DVKLQJWRQ'&$FFHVVLRQ1RV0/$6(&<

0/$(QFORVXUH0/$(QFORVXUH0/$(QFORVXUH

15&861XFOHDU5HJXODWRU\&RPPLVVLRQ2012e. Summary of Public Scoping Meetings for 

Environmental Impact Statement to Support Waste Confidence Rulemaking. WasKLQJWRQ'&

$FFHVVLRQ1R0/$

15&861XFOHDU5HJXODWRU\&RPPLVVLRQ2012f. Summary of Public Scoping Webinars for 

the Environmental Impact Statement to Support the Waste Confidence Rulemaking. 

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15&861XFOHDU5HJXODWRU\&RPPLVVLRQE “Staff Evaluation and Recommendation 

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15& 861XFOHDU5HJXODWRU\&RPPLVVLRQFWaste Confidence Generic 

Environmental Impact Statement Scoping Process Summary Report. Washington, '&

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15&861XFOHDU5HJXODWRU\&RPPLVVLRQGGeneric Environmental Impact Statement 

for License Renewal of Nuclear Plants. NUREG–5HYLVLRQ:DVKLQJWRQ'&

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Introduction 

September 2014 1-31 185(*௅

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SaWRULXVGDWHG0D\3Staff-Requirements—&206(&<-13-0300—Staff Evaluation and 

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NRDC v. NRC (Natural Resources Defense Council v. U.S. Nuclear Regulatory Commission). 

)G2d &LU.  

Nuclear Waste 3ROLF\$FWRI, as amended86&et seq. 

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5HJXODWRU\)OH[LELOLW\$FWRI86&– 

September 2014 2-1 185(*௅

2.0 Generic Facility Descriptions and Activities 

This chapter describes typical facility characteristics and activities that are within the scope of 

this GEIS. The U.S. Nuclear Regulatory Commission (NRC) relied upon available information 

for facilities and activities similar to those described in this chapter to assess environmental 

impacts that may occur from continued storage of spent nuclear fuel (spent fuel) beyond the 

licensed life for operation of a reactor (continued storage). 

2.1 Generic Facility Descriptions 

Most commercial spent fuel is stored at reactor sites in spent fuel pools and at-reactor 

independent spent fuel storage installations (ISFSIs). Some commercial spent fuel is stored 

under NRC regulatory oversight at away-from-reactor ISFSIs such as the GE-Hitachi Nuclear 

Energy Americas, LLC, Morris wet storage facility in Morris, Illinois, (GEH Morris) and the 

U.S. Department of Energy’s (DOE) Three Mile Island, Unit 2, Fuel Debris ISFSI at the Idaho 

National Engineering Laboratory.1,2 The remainder of the commercial spent fuel has either been 

reprocessed at the former Nuclear Fuel Services reprocessing facility in western New York 

State or removed from reactor sites by the DOE, or its predecessor agencies, and is no longer 

regulated by the NRC. The spent fuel addressed by the generic analysis in this generic 

environmental impact statement (GEIS) is the commercial spent fuel regulated by the NRC. 

Spent fuel or commercial high-level waste derived from reprocessing of spent fuel under the 

control of other agencies of the Federal government is not included in this generic analysis. 

Additional information on the scope of this GEIS is presented in Chapter 1. 

The following sections provide generic descriptions of NRC-licensed facilities that store 

commercial spent fuel, with an emphasis on characteristics relevant to continued storage. 

These descriptions provide physical context for the generic activities described in Section 2.2. 

In addition, this section provides construction costs for continued storage facilities, as well as 

costs (e.g., rail spurs) for transporting spent fuel to an away-from-reactor ISFSI during 

 

1 The DOE holds three ISFSI licenses from the NRC: (1) the Fort St. Vrain at-reactor ISFSI in Platteville, 

Colorado; (2) the away-from-reactor Three Mile Island ISFSI; and (3) the yet-to-be-constructed awayfrom-reactor Idaho Spent Fuel Facility. 

2 In 2006, the NRC granted a license to Private Fuel Storage, LLC (PFS), to construct and operate an 

away-from-reactor ISFSI in Skull Valley, Utah. PFS has not constructed the proposed ISFSI. See 

Section 2.1.3 for additional information regarding this project. 
Generic Facility Descriptions and Activities 

185(*௅ 2-2 September 2014 

continued storage (analyzed LQ&KDSWHU). The estimated costs presented in this chapter 

are expressed in 2014 dollars.3

2.1.1 At-Reactor Continued Storage Site Descriptions 

The following sections describe the general characteristics of at-reactor continued storage sites, 

which are identical to nuclear power plant sites. 

2.1.1.1 General Description of Single-Unit Nuclear Power Plant Site 

This section describes a generic single-unit nuclear power plant site, which is where continued 

storage will occur in spent fuel pools and at-reactor ISFSIs. Key differences between a singleunit site and multiple-unit site, relevant to continued storage, are described in Section 2.1.1.2. 

A nuclear power plant site, including its associated ISFSI, contains a number of buildings or 

structures. Among them are a containment building or reactor building, turbine building, 

auxiliary building, vent stacks, meteorological towers, and cooling systems (which may include 

cooling towers). A nuclear power plant also includes large parking areas, security fencing, 

switchyards, water-intake and -discharge facilities, and transmission lines.4 While reactor, 

turbine, and auxiliary buildings are often clad or painted in colors that are intended to reduce or 

mitigate their visual presence, the heights of many of the structures, coupled with safety lights, 

make power plants visible from many directions and from great distances. Typical heights of 

structures found on these facilities are as follows: reactor buildings are 90 m (300 ft), turbine 

buildings are 30 m (100 ft), stacks are 90 m (300 ft), meteorological towers are 60 m (200 ft), 

QDWXUDOGUDIWFRROLQJWRZHUVDUHKLJKHUWKDQ P ft), and mechanical draft cooling towers 

 

3 Estimated costs from sources older than 2014 are adjusted to 2014 dollars following the Bureau of 

Labor Statistics (BLS) inflation calculator method (BLS 2014a), which uses the annual average Consumer 

Price Index (CPI) for a given year. The BLS CPI inflation calculator uses the following formula: 

2014 cost = ቆ March 2014 CPI

year "X" annual average CPIቇ year "X" cost 

The following annual average CPI values (BLS 2014b) were used to calculate estimated costs in 2014 

dollars in this chapter: 236.293 (March 

(2004DQG The NRC recognizes that the CPI may not fully capture the changes in costs 

for various construction, operation, design, procurement, and licensing activities; however, using the CPI 

provides the NRC with a means of developing more comparable estimates than using non-adjusted 

figures from disparate years. 

4 The term “power block” is sometimes used to refer to the buildings and components directly involved in 

generating electricity at a power plant. At a nuclear power plant, the components of the power block vary 

with the reactor design, but always include the reactor and turbine building, and usually include several 

other buildings that house access, reactor auxiliary, safeguards, waste processing, or other nuclear 

generation support functions. 
Generic Facility Descriptions and Activities 

September 2014 2-3 185(*௅

are 30 m (100 ft) tall. Transmission-OLQHWRZHUVDUHEHWZHHQDQG PDQG ft) in 

height, depending on the voltage being carried (NRC 2013a). 

There are two types of power reactors currently in use in the United States—boiling water 

reactors (BWRs) and pressurized water reactors (PWRs). In general, all nuclear power plant 

sites, when operating, are similar in terms of the types of onsite structures; however, the layout 

of buildings and structures varies considerably among the sites. In addition, while these 

buildings and structures are necessary during operations, many of the structures may be 

removed, mothballed, or entombed as a result of the decommissioning process, depending on 

several factors, including the decommissioning option licensees choose and other operational 

considerations. Many of these structures will be present at the beginning of continued storage 

analyzed in this GEIS. As decommissioning of the reactor facility progresses, the number of 

onsite structures will decline until only continued storage-related structures are present at the 

beginning of the long-term storage timeframe. The following list describes typical structures 

located on most sites following the permanent cessation of reactor operations (NRC 2013a): 

x Containment or reactor building. The containment or reactor building of a PWR is a massive 

concrete or steel structure that houses the reactor vessel, reactor coolant piping and pumps, 

steam generators, pressurizer, pumps, and associated piping. In general, the reactor 

building of a BWR includes a containment structure and a shield building. The reactorcontainment building is a massive steel and concrete structure that houses the reactor 

vessel, the reactor coolant piping and pumps, and the suppression pool. It is located inside 

a shield building. 

x Fuel building. For PWRs, the fuel building has a fuel pool that is used to store and service 

spent fuel and prepare new fuel for insertion into the reactor. This building is connected to 

the reactor-containment building by a transfer tube or channel that is used to move new fuel 

into the reactor and move spent fuel out of the reactor for storage. For plants with a 

BWR/6 reactor, spent fuel is stored in an adjacent Fuel Building or Fuel-Handling Building. 

x Turbine building. The turbine building houses the turbine generators, condenser, feedwater 

heaters, condensate and feedwater pumps, waste-heat rejection system, pumps, and 

equipment that support those systems. 

x Auxiliary buildings. Auxiliary buildings house support systems (e.g., the ventilation system, 

emergency core cooling system, laundry facilities, water treatment system, and waste 

treatment system). An auxiliary building may also contain the emergency diesel generators 

and, in some PWRs, the diesel fuel storage facility. 

x Diesel generator building. Often a separate building houses the emergency diesel 

generators if they are not located in the auxiliary building. 

x Pump houses. Various pump houses for circulating water, standby service water, or 

makeup water may be onsite. 
Generic Facility Descriptions and Activities 

185(*௅ 2-4 September 2014 

x Cooling towers. Cooling towers are structures designed to remove excess heat from the 

condenser without dumping the heat directly into waterbodies (e.g., lakes or rivers). The 

two principal types of cooling towers are mechanical draft towers and natural draft towers. 

Most nuclear plants with once-through cooling do not have cooling towers. However, seven 

facilities with once-through cooling also have cooling towers that are used to reduce the 

temperature of the water before it is released to the environment. 

x Radwaste facilities. Radioactive waste facilities may be contained in an auxiliary building or 

located in a separate radwaste building. 

x Ventilation stack. Many older nuclear power plants, particularly BWRs, have ventilation 

stacks to discharge gaseous waste effluents and ventilation air directly to the outside. 

These stacks can be 90 m (300 ft) tall or higher and contain monitoring systems to ensure 

that radioactive gaseous discharges are below fixed release limits. 

x Switchyard and transmission lines. Facilities typically contain a large switchyard that 

connects the site to the regional power distribution system. 

x Administrative, training, and security buildings. In most cases, administrative, training, and 

security buildings are located outside the protected area of the plant. 

x Independent spent fuel storage installations. An ISFSI is designed and constructed for the 

interim storage of spent fuel pending permanent disposal. ISFSIs are used by operating 

plants to add spent fuel storage capacity beyond that available in spent fuel pools. 

Nuclear power plant facilities are large industrial complexes with land-use requirements 

generally amounting to 40 WR ha (100 WR ac) for the reactor-containment building, 

auxiliary buildings, cooling system structures, administration and training offices, and other 

facilities (e.g., switchyards, security facilities, and parking lots). Areas disturbed during 

construction of the power plant generally have been returned to prior uses or were ecologically 

restored when construction ended. Site areas range from 34 KD ac) for the San Onofre 

pODQWLQ&DOLIRUQLDWR ha (14,000 ac) for the Clinton plant in Illinois. Almost 60 percent of 

SODQWVLWHVHQFRPSDVVWR KD WRDFZLWKVLWHDUHDVUDQJLQJIURP to 

400 KD to 1,000 ac) and an additional 12 sites encompassing 400 WRKDWR

2,000 ac). Larger land areas are often associated with elaborate man-made closed-cycle 

cooling systems that include cooling lagoons, spray canals, reservoirs, artificial lakes, and buffer 

areas (NRC 2013a). 

Nuclear power plant sites are located in a range of political jurisdictions, including towns, 

townships, service districts, counties, parishes, and states. Typically, the nearest resident lives 

about 0.4 NPPLIURPDQXFOHDUSRZHUSODQW. $WPRUHWKDQ percent of the sites, the 

population density within an -NP-PLUDGLXVLVIHZHUWKDQ persons/km2

(200 persons/mi2DQGDWPRUHWKDQ SHUFHQWRIWKHVLWHVWKHGHQVLW\ZLWKLQ NP mi) is 

fewer than 193 persons/km2  persons/mi2). The largest population density is around the 

Indian Point Nuclear Generating Station in upper Westchester County, New York, which has a 
Generic Facility Descriptions and Activities 

September 2014 2- 185(*௅

SRSXODWLRQGHQVLW\ZLWKLQNPPLRIPRUHWKDQSHUVRQVNP2 SHUVRQVPL2). 

:LWKLQWKH-NP-mi) radius, State, Federal, and Native American lands are present to 

various extents (NRC 2013a). 

The nuclear power plant structures that are used for continued storage of spent fuel, namely 

spent fuel pools and at-reactor ISFSIs, are described in more detail in Section 2.1.2 of this 

GEIS. Power plant-specific data on spent fuel pools and ISFSIs is provided in Appendix G of 

this GEIS. As shown in Appendix G, spent fuel pool licensed capacities at single-unit 

PWR SRZHUSODQWVUDQJHIURPDVVHPEOLHVDW+%5RELQVRQ6WHDPElectric Plant, Unit 2, to 

2,363 assemblies at the Callaway Plant and Wolf Creek Generating Station. At BWR plants, 

VSHQWIXHOSRROFDSDFLWLHVUDQJHIURPDVVHPEOLHVDWWKH%UXQVZLFN6WHDP(OHFWULF

*HQHUDWLQJSODQWWRDVVHPEOLHVDW)HUPL8QLW. 

2.1.1.2 General Description of Multiple-Unit Nuclear Power Plant Sites 

During continued storage at a multiple-unit site, other onsite reactors may be in different 

stages of their life cycles: under construction; operating; or decommissioning. Subject to 

NRC regulations that ensure independence of safety systems, multiple reactors may share 

systems, structures, and components (e.g., a spent fuel pool). Existing nuclear power 

plants with shared spent fuel pools are summarized in Table 2-1. Dresden Units 2 and 3 

and Comanche Peak Units 1 and 2 do not share a pool, but have two pools in one structure. 

Other common structures at multiple-unit sites include cooling system infrastructure, 

VZLWFK\DUGVDQG,6)6,V6DLORUHWDO

As noted in the Decommissioning GEIS (NRC 2002a), licensees that choose to shut down one 

reactor at a multi-reactor site usually choose a decommissioning option that allows the 

shutdown reactor to be placed in a safe, stable condition (SAFSTOR) and maintained in that 

state until the other reactors shut down, so that all reactors at a site can be decommissioned 

simultaneously. In these cases, a licensee may opt to store spent fuel in the shutdown 

reactor’s spent fuel pool until all reactors undergo decommissioning. Alternatively, the licensee 

may transfer some or all of the spent fuel in the shutdown reactor’s spent fuel pool to spent fuel 

pools for the other operating reactors or to an at-reactor or away-from-reactor ISFSI, and begin 

some dismantlement activities in the shutdown reactor’s spent fuel pool. As discussed in 

Chapter 1, the NRC assumes that, in compliance with current decommissioning requirements, 

all of a reactor’s spent fuel will have been removed from the spent fuel pool within 60 years after 

the end of the reactor’s licensed life for operation. 

 

 See Section 2.2 below for a description of the SAFSTOR option. 
Generic Facility Descriptions and Activities 

185(*௅ 2-6 September 2014 

Table 2-1. U.S. Pressurized Water Reactors with Shared Spent Fuel Pools 

Power Plant(a)

Shared Pool Capacity 

Assemblies (cores) 

Braidwood 

Byron 

Calvert Cliffs 

D.C. Cook 

North Anna 

Oconee(b) 

Point Beach 

Prairie Island 

Sequoyah 2,091 (

Surry 1,044 (6.6) 

Watts Bar(c) ) 

Zion(d) 

(a) Source: Individual plant operating licenses or safety evaluation reports, 

www.nrc.gov.

(b) Oconee Units 1 and 2 share a pool. Unit 3 has a separate pool. 

(c) Watts Bar Unit 1 will share a pool with Unit 2, which is not yet operational. 

(d) Zion Units 1 and 2 were permanently shut down on )HEUXDU\

2.1.1.3 Reactor and Fuel Technologies 

Several commercial reactor designs have been built and operated in the United States. As 

described below, the generic analysis in this GEIS is focused on past, present, and future spent 

fuel types that will be subject to a future NRC licensing action. These fuel types, discussed in 

more detail below, include: fuel types that have been used in the past and continue to be stored 

under an NRC license; fuel types that are presently used; and fuel types for which the 

characteristics are similar to fuel used today, are well understood, and may be used in the near 

future. See Appendix I, High-Burnup Fuel, for additional information regarding spent fuel. 

Light Water Reactors 

The majority of reactors that have been licensed for commercial operation in the United States, 

including the currently operating nuclear power plants and those under construction, are light 

water reactors. Light water reactors use ordinary water as coolant and a neutron moderator to 

initiate and control the nuclear reaction. The two light water reactor designs in use are PWRs 

and BWRs. There are 6 3:5VDQG%:5VRSHUDWLQJLQWKH8QLWHG6WDWHVWRGD\6 This is 

 

6 The licensee for the Vermont Yankee Nuclear Power Station has informed the NRC that the plant will 

permanently cease operations at the end of the current operating cycle, estimated to be in the fourth 

calendar quarter of 2014 (Entergy 2013). Vermont Yankee is included in the current count because it is 

still operating. 
Generic Facility Descriptions and Activities 

September 2014 2- 185(*௅

important for the generic analysis of continued storage because these reactors all use similar 

fuel, which allows the NRC to generically consider the environmental impacts of continuing to 

store spent fuel after the licensed life for operation of a reactor. 

The nuclear fuel typically used in both types of 

reactors is uranium enriched to a concentration of 

WRSHUFHQWRIWKHXUDQLXP-LVRWRSH7KH

fuel is in the form of cylindrical uranium dioxide 

(UO2) pellets, approximately 1 cm (0.4 in) in 

diameter and 1 WR cm (0.4 to 0.6 in) in height. 

The fuel pellets are stacked and sealed inside a 

hollow cylindrical fuel rod made of zirconium alloy. As described further below, a small amount 

of stainless-steel-clad fuel was used in the past and is still being stored under NRC licenses. 

Fuel rods are approximately 4.3 m (14 ft) long. They are bundled into fuel assemblies that 

JHQHUDOO\FRQVLVWRI× RU× URGVIRU3:5VDQG × RU× 10 rods for BWRs. 

)RU3:5VWKHUHDUHW\SLFDOO\WRIXHODVVHPEOLHVFRQWDLQLQJEHWZHHQDQGIXHO

rods per assembly, loaded into the core when operating. For BWRs, there are typically between 

DQGIXHODVVHPEOLHVFRQWDLQLQJEHWZHHQ62 and 96 fuel rods per assembly, loaded into 

the core when operating. The mass of uranium fuel in a typical light water reactor core is 

approximately 100 MTU. 

As shown in Table 2-2, fuel with stainless-steel cladding was used at five plants that are all shut 

down. LaCrosse was the last decommissioning plant to transfer its stainless-clad fuel from its 

pool into an at-reactor dry storage ISFSI in September 2012 (UxC 2013). Some of the Haddam 

Neck and San Onofre Unit 1 stainless-clad fuel is stored at the GEH Morris away-from-reactor 

ISFSI and the remainder is in at-reactor dry storage. The continued storage of this fuel is an 

NRC-licensed activity. 

Table 2-2. Stainless-Steel-Clad Fuel at Decommissioning Plants 

Plant 

Discharged 

Stainless-Clad 

Assemblies(a)

Stored at GEH 

Morris ISFSI(b)

Haddam Neck (c) 

Indian Point Unit 1 160 --- 

LaCrosse 333 --- 

San Onofre Unit 1  

Yankee Rowe  --- 

Total 2,179 352 

Sources: 

(a) EIA 1994. 

(b) NRC 2004a. 

(c) 6&RKHQ	$VVRFLDWHV,QF

Enrichment: Enriching uranium 

increases the proportion of uranium atoms 

that can be “split” by fission to release 

energy (usually in the form of heat) that 

can be used to produce electricity.
Generic Facility Descriptions and Activities 

185(*௅ 2- September 2014 

The amount of spent fuel accumulated at a reactor over its licensed life depends on factors such 

as how long the reactor operates each year, the duration of outages, spent fuel burnup, and 

operating lifetime. For purposes of analysis in this GEIS, the NRC assumes reactors operate 

with high capacity factors and short outages, which results in the generation of more spent fuel. 

Spent fuel burnup describes the extent to which energy has been extracted from nuclear fuel 

and is one factor in how often a reactor’s fuel needs to be replaced. Burnup is the actual energy 

released per mass of initial fuel in GWd/MTU. Spent fuel is considered to have low burnup if the 

EXUQXSLVOHVVWKDQ GWd/MTU. At low burnups, about one-fourth to one-third of the spent 

IXHODVVHPEOLHVDUHUHPRYHGIURPWKHUHDFWRUDQGUHSODFHGHYHU\WRPRQWKV7KHUHIore, 

the amount of spent fuel discharged from a typical light water reactor operating at low burnups 

LVDERXW078SHU\HDU$IWHU\HDUVRIUHDFWRURSHUDWLRQ at low burnups, this amounts to 

about 1,600 MTU of spent fuel. A reaFWRUFRXOGRSHUDWHIRU\HDUVLIWKHOLFHQVHHUHTXHVWHG

and the NRC granted, two 20-year renewals of its initial 40-year operating license. 

&XUUHQWO\WKHDYHUDJHGLVFKDUJHEXUQXSIRU3:5VDQG%:5VLVDSSUR[LPDWHO\DQG

43 GWd/MTU, respectively (EPRI 2012). By 2020 it is projected that the maximum discharge 

EXUQXSVIRU3:5VDQG%:5VZLOOEH DQG*:G078UHVSHFWLYHO\(35,7KH

FXUUHQWWUHQGWRZDUGH[WHQGHGLUUDGLDWLRQF\FOHVDQGKLJKHUIXHOHQULFKPHQWVRIXSWR weight 

percent uranium-KDVOHGWRDQLQFUHDVHRIWKHEXUQXSUDQJHIRUGLVFKDUJHGQXFOHDUIXHO

assemblies in the United States that is expected to eventually exceed 60 GWd/MTU. For plants 

at which higher fuel burnups are authorized, the period between outages may be extended to 

24 PRQWKVDQGWKHDQQXDOGLVFKDUJHRIVSHQWIXHOUHGXFHGWRDERXW078SHU\HDU6KRXOGD

QXFOHDUSRZHUSODQWRSHUDWHIRUXSWR\HDUVZLWKKLJK-burnup fuel, it would generate about 

1,200 MTU of spent fuel. 

For purposes of analysis in this GEIS, the NRC relies on the larger reactor lifetime amount of 

spent fuel discharged at low burnups (i.e., 1,600 MTU). This is because many of the 

environmental impacts (e.g., land use, geology and soils, and terrestrial resources) will depend 

upon the greater amount of space needed to store the larger amounts of spent fuel that would 

be generated at low burnups. In cases where high-burnup fuel is a consideration in the impact 

determination, this is explained in the supporting analysis. Appendix I provides further 

discussion on the characteristics, storage, and transportation of high-burnup uranium oxide and 

mixed oxide (MOX) spent fuel. 

Mixed Oxide Fuel 

MOX fuel is a type of nuclear reactor fuel that contains plutonium oxide mixed with either natural 

or depleted uranium oxide in ceramic pellet form. Using plutonium reduces the amount of 

enriched uranium needed to produce a controlled reaction in commercial light water reactors. 

MOX fuel was produced and used in the United States prior to the mid-VGXULQJWKDWWLPH

the United States reprocessed nuclear fuel and recovered plutonium for reuse as MOX fuel in 
Generic Facility Descriptions and Activities 

September 2014 2-9 185(*௅

light water reactors. MOX fuel was used at Quad Cities, San Onofre, Big Rock Point, Dresden 

8QLWDQGDVUHFHQWO\DV–&DWDZED8QLW&DWDZED8QLWXVHGIRXU02;OHDG

test assemblies that were part of a nonproliferation project conducted by the National Nuclear 

Security Administration. Because the MOX fuel is substantially similar to existing uranium oxide 

light water reactor fuel and was, in fact, used in existing light water reactors in the United States, 

it is within the scope of this GEIS. 

MOX fuel is not currently being produced in the United States; however, an application is 

pending before the NRC for Shaw AREVA MOX Services (formerly Duke COGEMA Stone & 

Webster) to manufacture MOX fuel at the Mixed Oxide Fuel Fabrication Facility at the Savannah 

River Site in South Carolina as part of the National Nuclear Security Administration’s ongoing 

nonproliferation project. The MOX fuel proposed to be manufactured by Shaw AREVA MOX 

Services is a blend of plutonium dioxide, extracted from retired nuclear weapons and other 

sources of surplus plutonium, and depleted uranium dioxide, which is a byproduct of the 

uranium enrichment process. Because the MOX fuel that would be generated at the Mixed 

Oxide Fuel Fabrication Facility is substantially similar to existing light water reactor fuel and is, 

in fact, intended for use in existing light water reactors in the United States, MOX fuel from this 

project is within the scope of this GEIS. 

Integral Pressurized Water Reactors 

The NRC is preparing to review a number of integral pressurized water reactor (iPWR) designs 

that are currently under development. An iPWR is a small modular reactor that uses light water 

reactor technology. Current iPWR designs employ light water reactor technology with current 

design fuel and secondary loop steam generators, but also incorporate a number of advanced 

features and characteristics (NRC 2012). The NRC is currently engaged in preapplication 

activities with several applicants for light water small modular reactors. 

Because the light water reactor fuel that would be used in iPWR designs is substantially similar 

to existing light water reactor fuel (i.e., zirconium-clad, low-enriched uranium oxide pellets in 

square fuel rod arrays), it is within the scope of this GEIS. 

Other Commercial Reactor and Fuel Designs 

In addition to light water reactors, two other reactor technologies are sufficiently well developed 

to be deployed for use as commercial nuclear power plants: the high-temperature gas-cooled 

reactor and the liquid metal fast reactor. As described in more detail below, spent fuel 

generated by these technologies is not within the scope of the analysis in this GEIS, with the 

exception of high-temperature gas reactor fuel stored in the Fort Saint Vrain ISFSI, because 

neither technology is in commercial use or under development in the United States at this time. 
Generic Facility Descriptions and Activities 

185(*௅ 2-10 September 2014 

High-Temperature Gas-Cooled Reactors 

A high-temperature gas-cooled reactor is a type of nuclear fission reactor that typically operates 

at a very high temperature, is graphite-moderated, and uses an inert gas such as helium as its 

primary coolant. Fuel may be loaded in the core in a prismatic or pebble bed design. In the 

United States, there have been two high-temperature gas-cooled reactors built and 

commercially operated: Fort Saint Vrain and Peach Bottom Unit 1. Fort Saint Vrain has been 

decommissioned, and Peach Bottom Unit 1 is in the process of decommissioning. The 

Fort Saint Vrain spent fuel continues to be stored at an NRC-licensed ISFSI in Plattesville, 

Colorado, and is within the scope of this GEIS. Peach Bottom Unit 1 fuel is under Federal 

government control at the Idaho National Laboratory and is not within the scope of this GEIS 

because it is no longer regulated by the NRC. 

The NRC was participating in preapplication reviews of the DOE’s Next Generation Nuclear 

Plant. The Next Generation Nuclear Plant would use nuclear fuel comprised of tristructuralisotropic-coated fuel particles contained in either fuel pebbles or prismatic fuel assemblies. The 

uranium oxycarbide kernels in each particle would be encapsulated in successive layers of 

silicon carbide and pyrolitic carbon. 

Because this fuel type has not completed fuel qualification testing, it is not yet a commercially 

viable technology. If this technology should become viable and the NRC is asked to review one 

or more license applications for a high-temperature gas-cooled reactor facility, then the 

environmental impacts of continued storage of that spent fuel will be considered in individual 

licensing proceedings unless the NRC updates the GEIS and corresponding rule to include the 

environmental impacts of storing this type of fuel after a reactor’s licensed life for operation. 

Liquid Metal Fast Reactor 

Liquid metal fast reactors use a molten metal (e.g., sodium) as their primary coolant. Fuel for a 

liquid metal fast reactor varies by concept, but typically consists of a mix of uranium and 

zirconium or a mix of uranium, plutonium, and zirconium. In the United States, Enrico Fermi 

Unit 1 was a liquid-sodium-FRROHGIDVWUHDFWRUWKDWRSHUDWHGEHWZHHQDQG)HUPL

Unit 1 is in the process of decommissioning and all spent fuel has been removed from the site 

and is now the responsibility of the DOE. 

The NRC is engaged in preliminary preapplication discussions with the designers of three liquid 

metal fast reactors—Toshiba Corporation's Super-Safe, Small, and Simple design; General 

Electric Hitachi’s Power Reactor Innovative Small Module design; and Gen4 Energy’s Gen4 

 

 The NRC renewed the license for the Fort St. Vrain ISFSI in May 2011, after completing an 

HQYLURQPHQWDODVVHVVPHQWDQGILQGLQJRIQRVLJQLILFDQWLPSDFW)5
Generic Facility Descriptions and Activities 

September 2014 2-11 185(*௅

Module design. The fuel types in these designs range from a mix of uranium-zirconium or 

uranium-plutonium-zirconium metal alloys to stainless-steel-clad uranium nitride. 

These fuel types have not completed fuel qualification testing and are not yet commercially 

viable technologies. If these technologies should become viable and the NRC is asked to 

review one or more license applications for a liquid metal fast reactor facility, then the 

environmental impacts of continued storage of that spent fuel will be considered in individual 

licensing proceedings unless the NRC updates the GEIS and corresponding rule to include the 

environmental impacts of storing this type of fuel after a reactor’s licensed life for operation. 

2.1.2 Onsite Spent Fuel Storage and Handling 

As of the end of 2011, the amount of commercial spent fuel in storage at commercial nuclear 

power plants was DQHVWLPDWHG0787KHDPRXQWRIVSHQWIXHOLQVWRUDJHDW

commercial nuclear power plants is expected to increase at a rate of approximately 2,000 MTU 

per year (CRS 2012). 

Licensees have designed spent fuel pools to temporarily store spent fuel in pools of 

continuously circulating water that cool the spent fuel assemblies and provide shielding from 

radiation. When the nuclear power industry designed the current fleet of operating nuclear 

power plants, it expected that, after a few years, the plant operators would transport spent fuel 

to one or more reprocessing plants. However, as a result of historic decision-making on 

reprocessing no commercial spent fuel reprocessing facilities are currently operating or 

planned in the United States (Copinger et al. 2012).

2.1.2.1 Spent Fuel Pools 

Spent fuel pools are designed to store and cool spent fuel following its removal from a reactor. 

Spent fuel pools are massive and durable structures constructed from reinforced-concrete walls 

DQGVODEVWKDWYDU\EHWZHHQDQGPDQGIWWKLFNTypically, spent fuel pools are at 

least 12 m (40 ft) deep, allowing the spent fuel to be covered by at least 6 m (20 ft) of water, 

which provides adequate shielding from the radiation for anyone near the pool. All spent fuel 

pools currently in operation are lined with stainless-steel liners that vary in thickness from 

6 to PPWRLQCopinger et al. 2012). Further, all spent fuel pools have either a 

leak-detection system or administrative controls to monitor the spent fuel pool liner. Typically, 

leak-detection systems are made up of several individually monitored channels or are designed 

 

 In furtherance of anti-proliferation policies, the Federal government declared a moratorium on 

UHSURFHVVLQJVSHQWIXHOLQ7KLVPRUDWRULXPZDVOLIWHGLQEXWLQ3UHVLGHQW&OLQWRQ

issued a policy statement that the United States does not encourage civil use of plutonium, including 

reprocessing. In 2001, President Bush’s National Energy Policy encouraged research into reprocessing 

technologies. Currently, there is no Federal moratorium on reprocessing. 
Generic Facility Descriptions and Activities 

185(*௅ 2-12 September 2014 

so that leaked water empties into monitored drains. Leaked water is directed to a sump, liquid 

radioactive waste treatment system, or other cleanup or collection system. 

Reactor designers originally anticipated that spent fuel would be stored for less than 1 year 

before being shipped to a reprocessing plant for separation of the fissile isotopes. For this 

reason, currently operating reactors originally had storage capacity for one full core plus one or 

two additional discharged batches of spent fuel. When the United States abandoned spent fuel 

reprocessing and spent fuel pools began to fill up, licensees expanded fuel storage capacity by 

replacing the original storage racks with higher density fuel racks. Licensees achieved the 

higher density by taking into account in their safety assessments the neutron-absorbing 

characteristics of the stainless-steel structure of the storage racks and incorporating plates or 

VKHHWVFRQWDLQLQJDQHXWURQDEVRUEHUPDWHULDOIRUUHDFWLYLW\FRQWURO(35,$VDUHVXOWD

typical spent fuel pool at a light water reactor can hold the equivalent of about seven reactor 

FRUHORDGVRUDERXW078VHH$SSHQGL[*

On this basis, a typical spent fuel pool has about MTU storage capacity that reaches its 

OLFHQVHGFDSDFLW\OLPLWLQDERXW\HDUVLQWROLFHQVHGOLIHIRURSHUDWLRQRIDUHDFWRU$WWKDW

point, some of the spent fuel would need to be removed from the spent fuel pool and transferred 

to a dry cask storage system at either an at-reactor or away-from-reactor ISFSI. 

Spent fuel pools are constructed with the reactor, not during continued storage. Therefore, the 

cost of building a spent fuel pool facility is not included in this GEIS. However, operating the 

spent fuel pool is a continued storage activity, and those costs are presented in Section 2.2.1.2. 

Two events have resulted in changes to NRC requirements for physical security and the safe 

operation of spent fuel pools. The first was the terrorist attacks on September 11, 2001, after 

which the NRC ordered all operating nuclear power plants to immediately implement 

compensatory security measures. In addition, the NRC issued Orders to decommissioning 

reactor licensees that imposed additional security measures associated with access 

authorization, fitness for duty, and behavior observation. In 2009, the NRC completed a 

rulemaking that codified generally applicable security requirements for operating power plants 

 FR 13926). 

Second, in response to the March 11, 2011 severe earthquake and subsequent tsunami that 

resulted in extensive damage to the six nuclear power reactors at Japan’s Fukushima Dai-ichi 

site, the NRC established a task force of senior agency experts (Near-Term Task Force). On 

July 12, 2011, the Near-Term Task Force issued its report, which concluded that there was no 

imminent risk from continued operation and licensing activities (NRC 2011a). Based on its 

analysis, the Near-Term Task Force made 12 overarching recommendations for changes to 

ensure the continued safety of U.S. nuclear power plants. 
Generic Facility Descriptions and Activities 

September 2014 2-13 185(*௅

Several of these recommendations addressed spent fuel pool integrity and assurance of 

adequate makeup water in the event of a serious accident. In response to the Near-Term Task 

Force’s recommendations, the NRC issued multiple Orders and a request for information to all 

of its operating power reactor licensees and holders of construction permits in active or deferred 

status on March 12, 2012. The Orders addressed (1) mitigating strategies for beyond-design 

basis external events and (2) reliable spent fuel pool instrumentation. In addition, the NRC 

issued the request for information to assist the agency in reevaluating seismic and flooding 

hazards at operating reactor sites and determining whether appropriate staffing and 

communication can be relied upon to coordinate event response during a prolonged station 

blackout event, as was experienced at Fukushima Dai-ichi. The NRC will use the information 

collected to determine whether to update the design basis and systems, structures, and 

components important to safety, including spent fuel pools. However, because the NRC has not 

yet decided whether any license needs to be modified, suspended, or revoked, for purposes of 

analysis in this GEIS, the NRC assumes that the related existing regulatory framework remains 

unchanged. Further, the NRC has initiated a rulemaking to address a condition known as 

station blackout, a situation that involves the loss of all onsite and offsite alternating current 

power at a nuclear power plant. The advance notice of proposed rulemaking was published on 

0DUFK)5, and the draft regulatory basis was published on April 10, 2013 

)5Among other issues being considered as part of the rulemaking, the NRC is 

evaluating whether to require additional equipment (e.g., backup power supplies and 

instrumentation) to ensure the safety of spent fuel pools. Current information regarding the 

status of this proposed rule can be found on the regulations.gov website (www.regulations.gov) 

under Docket ID NRC-2011-0299. 

2.1.2.2 At-Reactor Independent Spent Fuel Storage Installations 

Spent fuel pools, as discussed above, have limited capacity to store a reactor’s spent fuel. As 

noted, a typical spent fuel pool has a storage capacity of about MTU that reaches its 

OLFHQVHGFDSDFLW\OLPLWDERXW\HDUVLQWROLFHQVHGOLIHIRURSHUDWLRQRIDUHDFWRU$WWKDWSRLQW

the licensee needs a dry cask storage system to store older fuel that has cooled sufficiently and 

can be removed safely from the pool. These dry cask storage systems are located in ISFSIs at 

reactor sites and are licensed by the NRC. Dry cask storage systems shield people and the 

environment from radiation and keeps the spent fuel dry and nonreactive (NRC 2013b). 

There are many different dry cask storage systems, but most fall into two main categories based 

on how they are loaded. The first is the bare fuel, or direct-load, casks, in which spent fuel is 

loaded directly into a basket that is integrated into the cask. Bare fuel casks, which tend to be all 

metal construction, are generally bolted closed. The second is a canister-based system in which 

spent fuel is loaded into a basket inside a cylinder called a canister. The canister is usually 

loaded while inside a transfer cask, then welded and transferred vertically into either a concrete 

or metal storage overpack or horizontally into a concrete storage module (e.g., NUHOMS) 

(Hanson et al. 2012). Typical dry cask storage systems are shown in Figure 2-1. 
Generic Facility Descriptions and Activities 

NUREG௅2157 2-14 September 2014 

 

Figure 2-1. Dry Storage of Spent Fuel (Source: NRC 2013b) 
Generic Facility Descriptions and Activities 

September 2014 2- 185(*௅

Dry cask storage systems are licensed by the NRC for storage only or for storage and 

transportation. Storage-RQO\FDVNVDUHQRWFHUWLILHGIRUWUDQVSRUWDWLRQXQGHU&)53DUW

“Packaging and Transportation of Radioactive Material.” Casks and canisters licensed for both 

storage and transportation are generally referred to as dual-purpose casks and dual-purpose 

canisters. Some vendors refer to their dual-purpose casks or canisters as “multipurpose” 

canisters, which implies that it would be suitable for storage, transportation, and disposal. 

However, in the absence of a repository program, there are no specifications for disposal 

canisters and, therefore, no dual-purpose casks or canisters have been certified as 

multipurpose (Hanson et al. 2012). 

As of June 2014, there were operational ISFSIs at 64 sites. One operational ISFSI, at the GEH 

Morris site, is a wet storage facility. The remaining ISFSIs store spent fuel in over 1,900 loaded 

dry casks. Two licenses have been issued for ISFSIs, the PFS facility and the Idaho Spent Fuel 

Facility, neither of which have been constructed. Figure 2-2 shows the locations of U.S. ISFSIs. 

Information on ISFSIs is presented in Appendix G of this GEIS. 

The NRC authorizes construction and operation of ISFSIs by general and specific licenses. 

A general license is created by regulation and confers the right upon the general licensee to 

proceed with the licensed activity without further review or approval by the NRC. A specific 

license, by contrast, requires an application to perform the licensed activity and NRC review and 

approval to proceed with the licensed activity. 

As these concepts apply to ISFSIs, every nuclear power reactor licensee, by virtue of the 

general license in &)53DUW6XESDUW.is authorized to store spent fuel in casks whose 

design has been approved by the NRC. Licensees must evaluate the safety of using the 

approved casks at the ISFSI for site-specific conditions, including man-made and natural 

hazards, and must conform to all requirements under Subpart K for use of the approved design. 

In addition, licensees must review their programs for operating the reactor (e.g., physical 

security, radiation protection, and emergency planning) to determine if those programs are 

affected by use of the casks and, if so, to seek approval from the NRC for any necessary 

changes to those programs. 

Further, a reactor licensee can seek a specific license to construct and operate an ISFSI, which 

requires NRC’s review of the safety, environmental, and physical security aspects of the 

proposed facility and the licensee’s financial qualifications. If the NRC concludes the proposed 

ISFSI meets licensing criteria, then the NRC grants the specific license. This license contains 

various conditions (e.g., leak testing and monitoring) and specifies the quantity and type of 

material the licensee is authorized to store at the site. A specific license runs for a term of up to 

40 years and may be renewed in accordance with all applicable requirements. 
Generic Facility Descriptions and Activities 

NUREG௅2157 2-16 September 2014 

Figure 2-2. Licensed/Operating ISFSIs by State (Source: NRC 2014) 
Generic Facility Descriptions and Activities 

September 2014 2- 185(*௅

As described in more detail in Section 2.2.1, nuclear power plant licensees will undertake major 

decommissioning activities during the 60 years following permanent cessation of reactor 

operations. During major decommissioning activities, the licensees will transfer spent fuel from 

spent fuel pools to either an at-reactor or away-from-reactor ISFSI. When decommissioning of 

the reactor and related facilities is completed and the at-reactor ISFSI is the only spent fuel 

storage structure left onsite, the facility is referred to as an “ISFSI-only site.” Existing ISFSI-only 

sites include Big Rock Point, Haddam Neck, Fort St. Vrain, Maine Yankee, Rancho Seco, 

Trojan, and Yankee Rowe. 

The NRC requires licensees to develop spent fuel management plans that include specific 

consideration of a plan for removal of spent fuel stored under a general license, and spent fuel 

management before decommissioning systems and components needed for moving, unloading, 

and shipping spent fuel (10 CFR EEDQG9

Construction of a replacement at-reactor ISFSI is a continued storage activity in the long-term 

and indefinite timeframes. The Electric Power Research Institute (EPRI) developed a formula 

for estimating the cost to design, license, and construct a dry cask storage facility (EPRI 2012). 

EPRI’s cost estimate is based in part on the number of casks at the facility. For cost estimates 

in this GEIS, the NRC uses the EPRI value of 10 MTU per cask (EPRI 2009), which translates 

to 160 casks for a 1,600 MTU at-reactor ISFSI. Based on EPRI’s formula and its 2012 data, a 

single 1,600 MTU storage capacity facility costs $10,000,000 ($10M) to design, license, and 

construct. 

Following the terrorist attacks on September 11, 2001, the NRC issued Orders to ISFSI 

licensees to require certain compensatory measures. For example, on May 23, 2002, the NRC 

issued an Order to the GEH Morris wet storage ISFSI (NRC 2002b). On October 16, 2002, the 

NRC also issued Orders to specifically licensed and generally licensed dry storage ISFSIs 

(including those with near-term plans to store spent fuel in an ISFSI under a general license). 

The details of these Orders are withheld from the public for security reasons. 

In addition to NRC licensing requirements, licensees may also be subject to individual State 

requirements. For example, the State of Minnesota Public Utilities Commission requires an 

applicant to receive a “certificate of need” prior to constructing an ISFSI. 

Example of At-Reactor ISFSIs 

Dry cask storage systems in use in the United States are summarized in Appendix G. Two 

common systems are described below. 

 

9 The regulations reference “irradiated-fuel-management plans.” For the purposes of this discussion 

there is no difference between irradiated fuel and spent fuel. 
Generic Facility Descriptions and Activities 

185(*௅ 2- September 2014 

A common vertical dry cask storage system currently in use in at-reactor ISFSIs is Holtec 

International’s HI-STORM 100. The HI-STORM cylindrical overpack is stored on an ISFSI pad 

with its longitudinal axis in a vertical orientation and could contain, for example, a single Holtec 

MPC-32 multipurpose canister, which can hold up to 32 PWR fuel assemblies. Compatible 

canisters are also available for BWR spent fuel. As a result, dry storage of the entire 

1,600 MTU of spent fuel generated by a typical reactor, assuming all spent fuel is eventually 

transferred from the spent fuel pool, would require about 100 casks. Each storage cask is about 

3.4 m (11 ft) wide and 6.1 m (20 ft) tall. The layout of casks on an ISFSI pad is guided by 

operational considerations at each site. However, a nominal layout involves casks separated by 

DERXW PIW7KHUHIRUHDW\SLFDO,6)6,SDGZLWKFDVNVORFDWHGLQVLGHDSURWHFWHG

area common to the power plant, and arranged as 10 rows of 10 casks each, would cover about 

46 × 46 m × IW for a total area of DERXWKDDF+ROWHF 2000). For purposes of 

analysis in this GEIS, the NRC assumes that an ISFSI of sufficient size to hold all spent fuel 

generated by a reactor is constructed during the reactor’s licensed life for operation.

A common horizontal dry cask storage system currently in use in at-reactor ISFSIs is available 

from Transnuclear, Inc., a wholly-owned subsidiary of AREVA North America. The NUHOMS 

horizontal cask system uses dry shielded canisters that are placed in concrete horizontal 

storage modules (HSMs). Among the compatible NRC-approved canister designs is the 

NUHOMS-61BT dry shielded canister. This canister, for example, can hold 61 BWR fuel 

assemblies. Canisters are also available for PWR spent fuel. For a BWR, the HSM is about 

6.0 PIWORQJPIWKLJKDQGPIWZLGH$VDUHVXOWGU\VWRUDJHRI

1,600 MTU of spent fuel generated by a generic BWR, assuming all spent fuel is eventually 

transferred from the spent fuel pool to an at-UHDFWRU,6)6,ZRXOGUHTXLUHDERXW+60V,I

HSMs were installed in rows and placed back-to-back in 2 × DUUD\VDQ,6)6,ZLWK HSMs 

ZRXOGUHTXLUHDERXW double module rows and a single module row of 10 HSMs. Allowing for a 

6-m- (20-ft-ZLGHFRQFUHWHDSSURDFKVODERQWKHHQWUDQFHVLGHRIHDFK+60D+60,6)6,

VLWHZRXOGEHDERXWPIWZLGHDQGPIWORQJ7KHUHIRUHWKHWRWDODUHDRIWKH

horizontal ISFSI, including the protected area, would be about 1.3 ha (3.6 ac). 

2.1.3 Away-from-Reactor ISFSIs 

Existing away-from-reactor ISFSIs include the GEH Morris wet storage facility in Morris, Illinois, 

and the DOE’s Three Mile Island, Unit 2 Fuel Debris ISFSI at the Idaho National Engineering 

Laboratory. Further, the NRC has issued a license to PFS for an away-from-reactor ISFSI, 

which would have been located on the reservation of the Skull Valley Band of Goshute Indians 

(NRC 2004b). 

A future away-from-reactor ISFSI could accept spent fuel from one or more nuclear power 

plants. For purposes of this GEIS, the NRC assumes that the nuclear power industry could 

develop an away-from-reactor ISFSI that would store up to 40,000 MTU of spent fuel from 

various nuclear power plant sites using existing technologies. 
Generic Facility Descriptions and Activities 

September 2014 2-19 185(*௅

Construction of away-from-reactor ISFSIs is a 

continued storage activity for the short-term, longterm, and indefinite timeframes. For an awayfrom-reactor ISFSI, the initial construction cost 

is different than subsequent replacement 

construction costs because of transportation. 

For spent fuel transportation, continued storage 

only addresses the one-time transfer of spent fuel 

from the at-reactor ISFSI to an away-from reactor 

ISFSI. Therefore, transportation capital costs are 

only included in the initial construction of an awayfrom-reactor ISFSI. For continued storage, 

subsequent replacement of an away-from-reactor 

ISFSI excludes transportation capital costs 

because the spent fuel is already located at the 

site. EPRI estimated the costs of constructing a 

40,000 MTU ISFSI (EPRI 2009). The EPRI estimate is based in part on the number of casks at 

the facility. For cost estimates in this GEIS, the NRC uses the EPRI value of 10 MTU per cask 

(EPRI 2009) which translates to 4,000 casks for a 40,000 MTU away-from-reactor ISFSI. 

Based on 2009 data from EPRI (EPRI 2009), the NRC estimates initial construction costs for a 

40,000 MTU away-from-reactor interim storage facility at $6M, which iQFOXGHV0IRU

start-up costs, $141M for facility capital costs, and $46M for transportation capital costs. 

Excluding the transportation capital cost reduces the price for building a replacement awayfrom-reactor ISFSI at that location (i.e., subseqXHQWUHSODFHPHQWFRQVWUXFWLRQFRVWWR0

Activity costs associated with transportation are described in GEIS Section 2.2.1.4. 

Spent fuel would be moved from operating or decommissioning reactor sites, or ISFSI-only 

sites, to an away-from-reactor ISFSI or ISFSIs, and then from the away-from-reactor ISFSI to 

one or more permanent repositories. Aside from the existing GEH Morris wet storage facility, 

and for the purposes of the analysis in this GEIS, the NRC assumes that, in the future, a portion 

of the nuclear power industry’s spent fuel would be stored in one or more dry cask storage 

systems at an away-from-reactor ISFSI. 

In 2006, the NRC granted a license to PFS, to construct and operate an away-from-reactor 

ISFSI in Skull Valley, Utah. PFS, a consortium of eight nuclear power utilities, proposed to 

FRQVWUXFWWKHVLWHRQWKHUHVHUYDWLRQRIWKH6NXOO9DOOH\%DQGRI*RVKXWH,QGLDQVDERXWNP

PLVRXWKZHVWRI6DOW/DNH&LW\8WDK7KH3)6IDFLOLW\ZDVLQWHQGHGIRUWHPSRUDU\

aboveground storage, using the Holtec HI-STORM dual-purpose canister-based cask system, of 

up to 40,000 MTU of spent fuel from U.S. commercial nuclear power plants. PFS proposed to 

build the ISFSI on a 330-KD-ac) site leased from the Skull Valley Band of Goshute Indians. 

7KHVLWHZRXOGEHORFDWHGLQWKHQRUWKZHVWFRUQHURIWKHUHVHUYDWLRQDSSUR[LPDWHO\NPPL

Start-up costs include the design, 

engineering, and licensing costs 

associated with constructing a storage 

facility. 

Storage facility capital costs include the 

construction, material, and equipment 

costs for the storage pads and the various 

support buildings. 

Transportation capital costs include 

infrastructure (e.g., rail spurs), 

transportation equipment (e.g., rail 

locomotives and cars), and transportation 

casks and associated equipment.
Generic Facility Descriptions and Activities 

185(*௅ 2-20 September 2014 

from the Skull Valley Band's village. The proposed PFS ISFSI has not been constructed. 

Despite the PFS facility not having been constructed, issuance of the PFS license supports the 

assumption in this GEIS that an away-from-reactor ISFSI is feasible and that the NRC can 

license an away-from-reactor storage facility. Thus, the NRC’s analysis of construction, 

operation, and decommissioning activities and impacts for an away-from-reactor ISFSI in 

NUREG–DUHUHIOHFWHGLQWKLV*(,615& 2001). 

Consolidated Storage 

On January 29, 2010, the President of the United States directed the Secretary of Energy to 

establish a “Blue Ribbon Commission on America’s Nuclear Future.” The Blue Ribbon 

Commission was tasked with conducting a comprehensive review of policies for managing the 

back end of the nuclear fuel cycle and recommending a new strategy. The Blue Ribbon 

Commission issued its findings and conclusions in January 2012 (BRC 2012). Among the 

findings and conclusions related to continued storage of spent fuel was a strategy for prompt 

efforts to develop one or more consolidated storage facilities. 

In January 2013, DOE published its response to the Blue Ribbon Commission 

recommendations titled, Strategy for the Management and Disposal of Used Nuclear Fuel and 

High-Level Radioactive Waste (DOE 2013). This strategy implements a program over the next 

10 years that, with congressional authorization, will: 

x site, design, construct, license, and begin operation of a pilot interim storage facility by 2021 

with an initial focus on accepting spent fuel from shutdown reactor sites, 

x advance toward the siting and licensing of a larger interim storage facility to be available by 

ZLWKVXIILFLHQWFDSDFLW\WRSURYLGHflexibility in the waste-management system and 

allow for acceptance of enough spent fuel to reduce expected government liabilities, and 

x make demonstrable progress on the siting and characterization of repository sites to 

facilitate the availability of a geRORJLFUHSRVLWRU\E\. 

The Federal government’s support for interim storage supports the NRC’s decision to consider 

this type of facility as one of the reasonably foreseeable interim solutions for spent fuel storage 

pending ultimate disposal at a repository. 

2.1.4 Dry Transfer System 

Although there are no dry transfer systems (DTSs) at U.S. nuclear power plant sites today, the 

potential need for a DTS, or facility with equivalent capability, to enable retrieval of spent fuel 

from dry casks for inspection or repackaging will increase as the duration and quantity of fuel in 

dry storage increases. A DTS would enhance management of spent fuel inspection and 

repackaging at all ISFSI sites and provide additional flexibility at all dry storage sites by enabling 
Generic Facility Descriptions and Activities 

September 2014 2-21 185(*௅

repackaging without the need to return the spent fuel to a pool. A DTS would also help reduce 

risks associated with unplanned events or unforeseen conditions and facilitate storage 

reconfiguration to meet future storage, transport, or disposal requirements (Carlsen and Raap 

2012). 

Several DTS designs and related concepts have been put forward over the past few decades. 

Among these designs is a design developed by Transnuclear, Inc. in the early 1990s under a 

cooperative agreement between DOE and EPRI. Although the conceptual design was based on 

transferring spent fuel from a 30-ton 4-DVVHPEO\VRXUFHFDVNWRD-ton receiving cask, the 

DTS could be adapted to be suitable for any two casks (Carlsen and Raap 2012). 

On September 30, 1996, the DOE submitted to the NRC for review a topical safety analysis 

report on the Transnuclear-EPRI DTS design (DOE 1996). In November 2000, the NRC issued 

an assessment report in which it found the DTS concept has merit. The NRC’s assessment 

ZDVEDVHGRQWKH'76PHHWLQJWKHDSSOLFDEOHUHTXLUHPHQWVRI&)53DUWIRUVSHQWIXHO

storage and handling and 10 CFR Part 20 for radiation protection. However, the DOE has not 

yet requested a 3DUWlicense for the DTS (NRC 2000). 

Construction of a DTS is considered a continued storage activity in the long-term and indefinite 

WLPHIUDPHV%DVHGRQ(35,GDWD(35,WKH15&HVWLPDWHVDFRQVWUXFWLRQFRVWRI

0IRUWKHGHYHORSPHQWRID'76WRKDQGOHEDUHVSHQWIXHOWKDWFRXOGDFFRPPRGDWH

repackaging, as needed, to replace casks. The NRC assumed that estimated construction 

costs for the DTS are the same for both the at-reactor and away-from-reactor facilities. 

The reference DTS considered in this GEIS is a two-level concrete and steel structure with an 

attached single-level weather-resistant preengineered steel building. The concrete and steel 

structure provides both confinement and shielding during fuel transfer operations. The DTS was 

designed to enable loading of one receiving cask in 10 24-hour days and unloading one source 

cask in one 24-hour day. 

The key facility parameters and characteristics described in the September 30, 1996, topical 

safety analysis report are summarized below. 

The reference DTS is a reinforced-concrete rectangular box structure with internal floor 

GLPHQVLRQVRIDERXW× P× IWDQGDERXWPIWWDOO7KHV\VWHPDOVRLQFOXGHV

an attached, prefabricated, aluminum Butler-type building referred to as the preparation area 

with dimensions of about 11.6 [P× IWZLGHDQGP ft) tall. The basemat for 

the facility measures 14.9 × 21.9 m (49 × IWDQGWKHVHFXULW\]RQHZRXOGEHDERXW

 × 91 P× IWLHOHVVWKDQha [2 ac]). 

As shown in Figure 2-3, the preparation area is located at ground level of the DTS. The lower 

access area is next to the preparation area and directly below the transfer confinement area. 
Generic Facility Descriptions and Activities 

NUREG௅2157 2-22 September 2014 

Figure 2-3. Conceptual Sketches of a Dry Transfer System (DOE 1996) 
Generic Facility Descriptions and Activities 

September 2014 2-23 185(*௅

The lower access area provides shielding, confinement, and positioning for the open source and 

UHFHLYLQJFDVNVGXULQJVSHQWIXHOWUDQVIHUV$Q- to 23-FP- to 9-in.)-thick steel sliding door 

separates the lower access area from the preparation area. The transfer confinement area is 

the upper level of the DTS, directly above the lower access area. The transfer confinement 

area provides the physical confinement boundary and radiation shielding between spent fuel 

and the environment. 

Transnuclear-EPRI found that radioactive waste generation from dry transfer activities could not 

be readily quantified, as it depends strongly on reactor-specific conditions, primarily the crud 

levels on the fuel assemblies. Table 6.1-1 of the topical safety analysis report (DOE 1996) 

showed the expected waste sources, including decontamination wastes, spalled material in a 

crud catcher, and prefilters and high-efficiency particulate air filters used in the heating 

ventilation and air conditioning system. Other wastes considered included mechanical 

lubricants and precipitation runoff. The DTS does not rely on water-supply lines. Water is 

brought to the facility in bottles and used for general purpose cleaning only. 

The reference DTS, if licensed, would operate under the radiological protection requirements of 

10 CFR Part 20, “Standards for Protection against Radiation.” Occupational doses for various 

WDVNVSHUIRUPHGLQWKH'76DUHSURYLGHGLQ7DEOH-1 of the topical safety analysis report 

(DOE 1996). Total estimated occupational doses from loading a single cask are about 

 person-rem. 

Maximum offsite doses repRUWHGLQ7DEOH-1 of the topical safety analysis report were 

estimated to range from 44 PUHPSHU\HDUDWPWRPUHPSHU\HDUDWP

$VZLWKRWKHUIDFLOLWLHVOLFHQVHGXQGHU&)53DUWWKHGHVLJQHYHQWVLGHQWLILHGLQ

ANSI/ANS (ANSI/ANS 1992) form the basis for the accident analyses performed for the 

DTS. The bounding accident results for a distance of 100 m are a stuck fuel assembly 

 mrem) and a loss-of-FRQILQHPHQWEDUULHUPUHP

This GEIS considers the environmental impacts of constructing a reference DTS to provide a 

complete picture of the environmental impacts of continued storage. This GEIS does not 

license or approve construction or operation of a DTS. A separate licensing action would be 

necessary before a licensee may construct and operate a site-specific DTS. 

For the purposes of analysis in this GEIS, the NRC relies primarily on the facility description of 

the Transnuclear-EPRI DTS described above. However, for some impact assessments in this 

GEIS, the NRC has drawn from the Environmental Impact Statement for the Proposed Idaho 

Spent Fuel Facility at the Idaho National Engineering and Environmental Laboratory in Butte 

County, Idaho (NRC 2004b). The NRC licensed the Idaho Spent Fuel Facility in November 

2004, but DOE has not constructed the facility. However, the proposed facility has the 

capability to handle bare spent fuel for the purposes of repackaging and storing spent fuel from 
Generic Facility Descriptions and Activities 

185(*௅ 2-24 September 2014 

Peach Bottom Unit 1; the Shippingport Atomic Power Station; and various training, research, 

and isotope reactors built by General Atomics. Because the Idaho Spent Fuel Facility, like the 

DTS, includes design features that allow bare fuel-handling operations to repackage spent fuel 

from DOE transfer casks to new storage containers, the NRC has concluded that some 

environmental impacts of the facility would be comparable to those of a DTS. 

2.2 Generic Activity Descriptions 

As described in Chapter 1, this GEIS analyzes environmental impacts of the continued storage 

of spent fuel in terms of three storage timeframes: short-term, long-term, and indefinite storage. 

As described below, the activities at spent fuel storage facilities during the short-term timeframe 

coincide with nuclear power plant decommissioning activities. By the beginning of the long-term 

timeframe, reactor licensees will have removed all spent fuel from the spent fuel pool and 

decommissioned all remaining nuclear power plant structures. At that point, all spent fuel will be 

stored in either an at-reactor or away-from-reactor ISFSI. During the long-term storage 

timeframe, the NRC has conservatively assumed for the purpose of analysis in this GEIS that 

the need will arise for the transfer of spent fuel assemblies from aged dry cask storage systems 

to newer systems of the same or newer design. In addition, the NRC assumes that storage 

pads and modules would need to be replaced periodically. 6HFWLRQidentifies the 

continued storage activities for which the NRC evaluated the environmental impacts in this 

GEIS. This section provides the costs for those activities, as well as costs for transporting spent 

fuel to an away-from-reactor ISFSI during continued storage; the environmental impacts of 

transporting spent fuel to an away-from-reactor ISFSI are analyzed LQ&KDSWHU

2.2.1 Short-Term Storage Activities 

As depicted in the generic timeline in Figure 2-4DIWHUDERXW\HDUVRIRSHUDWLRQDWORZIXHO

burnups, or about 46 years of high-burnup operation, the spent fuel pool at a typical reactor 

reaches capacity and spent fuel must be removed from the pool to ensure full core offload 

capability. The inventory of spent fuel that exceeds spent fuel pool capacity may be transferred 

to dry cask storage at an at-reactor or away-from-reactor ISFSI. This GEIS focuses on the 

activities and impacts associated with continued storage in a spent fuel pool and dry cask. This 

section explains the activities that occur during short-term storage: 

x decommissioning of the plant systems, structures, and components not required for 

continued storage of spent fuel, 

x routine maintenance of the pool and ISFSI, and 

x transfer of spent fuel from the pool to the at-reactor or away-from-reactor ISFSI. 
Generic Facility Descriptions and Activities 

September 2014 2-25 NUREG௅2157 

Figure 2-4. Continued Storage Timeline 

2.2.1.1 Decommissioning Activities during Short-Term Storage 

A number of activities occur after a reactor licensee declares permanent cessation of operations. 

These activities are divided into three phases: (1) initial activities; (2) major decommissioning 

and storage activities; and (3) license-termination activities. The initial activities include the 

licensee’s certification to the NRC within 30 days of the decision or requirement to permanently 

cease operations. This is followed by certification of permanent fuel removal from the reactor. 

Within 2 years of permanent shutdown, the licensee is required to submit to the NRC a postshutdown decommissioning activities report that includes a description of planned 

decommissioning activities along with a schedule, an estimate of expected costs, and a 

discussion that provides the reasons for concluding that previously issued environmental impact 

statements bound the site-specific decommissioning activities (NRC 2013c). 
Generic Facility Descriptions and Activities 

185(*௅ 2-26 September 2014 

Licensees may choose from three decommissioning options: DECON, SAFSTOR, and 

ENTOMB: 

DECON: The equipment, structures, and portions of the facility and site that contain 

radioactive contaminants are removed or decontaminated to a level that permits 

termination of the license shortly after cessation of operations. 

SAFSTOR: The facility is placed in a safe, stable condition and maintained in that 

state until it is subsequently decontaminated and dismantled to levels that permit 

license termination. During SAFSTOR, a facility is left intact, but the fuel is removed 

from the reactor vessel and radioactive liquids are drained from systems and 

components and then processed. Radioactive decay occurs during the SAFSTOR 

period, which reduces the levels of radioactivity in and on the material and, 

potentially, the quantity of material that must be disposed of during decontamination 

and dismantlement. 

ENTOMB: ENTOMB involves encasing radioactive structures, systems, and 

components within a structurally long-lived substance, such as concrete. The 

entombed structure is appropriately maintained, and continued surveillance is carried 

out until the radioactivity decays to a level that permits termination of the license10

(NRC 2013c). The NRC has previously considered a range of likely ENTOMB 

scenarios. For all scenarios considered, spent fuel was removed from the spent fuel 

pool prior to entombment (NRC 2002a). While the nuclear power industry has 

expressed interest in maintaining the option for ENTOMB, no licensees have 

committed to using it (NRC 2002c). 

The choice of decommissioning option is left to the licensee, but decommissioning must 

conform to the NRC's regulations. This choice is communicated to the NRC and the public in 

the post-shutdown decommissioning activities report. In addition, the licensee may choose to 

combine the DECON and SAFSTOR options. For example, after power operations cease at a 

facility, a licensee could use a short storage period for planning purposes, followed by removal 

of large components (such as the steam generators, pressurizer, and reactor vessel internals), 

place the facility in storage for 30 years, and eventually finish the decontamination and 

dismantlement process (NRC 2013c). 

If a licensee needs to change the decommissioning schedules or activities identified in the postshutdown decommissioning activity report, or if the decommissioning costs increase 

significantly, 10 CFR D DQGJ require the licensee to notify the NRC in writing 

 

10 Because most power reactors will have radionuclides in concentrations exceeding the limits for 

unrestricted use even after 100 years, this option will generally not be feasible (NRC 2013c). 
Generic Facility Descriptions and Activities 

September 2014 2- 185(*௅

and send a copy to the affected States. The NRC uses the post-shutdown decommissioning 

activity report and any written notification of changes to manage decommissioning oversight 

activities. 

Decommissioning will be completed within 60 years of permanent cessation of operations in 

accordance with the license-termination requirements for power reactors in 10 CFR D

DQGF. Completion of decommissioning beyond 60 years will be approved by the 

Commission only when necessary to protect public health and safety. Factors that will be 

considered by the Commission include unavailability of waste disposal capacity and other 

site-specific factors, including the presence of other nuclear facilities at the site. Given this 

regulatory framework, it may be reasonably assumed that each nuclear power plant, including 

its onsite spent fuel pool, will be decommissioned within 60 years of permanent cessation of 

operations. 

Licensees may begin major decommissioning activities 90 days after the NRC has received the 

post-shutdown decommissioning activities report. The term “major decommissioning activity” is 

GHILQHGLQ&)5DQGPHDQVIRUDQXFOHDUSRwer reactor facility, any activity that results 

in permanent removal of major radioactive components, permanently modifies the structure of 

the containment, or results in dismantling components for shipment containing greater-thanclass-C low-level waste as defined in 10 CFR . Finally, once decommissioning is 

completed, and any spent fuel stored by the licensee is removed from the site, a licensee may 

DSSO\WRWKH15&WRWHUPLQDWHLWV3DUW RU3DUW license.11 A licensee is required by 

10 CFR D RUL to submit to the NRC a license-termination plan as a 

supplement to its final safety analysis report at least 2 years prior to the expected termination of 

the license as scheduled in the post-shutdown decommissioning activities report. 

Decommissioning activities are not a part of continued storage. Therefore, decommissioning 

costs are not included in this GEIS. 

2.2.1.2 Activities in Spent Fuel Pools 

Spent fuel pools are cooled by continuously circulating water that cools the spent fuel 

assemblies and provides shielding from radiation. During the short-term storage timeframe, the 

pools will be used to store fuel until a licensee decides to remove the spent fuel as part of 

implementing the selected decommissioning option. Beyond the short-term storage timeframe, 

the NRC assumes that all of the spent fuel has been transferred to a dry cask storage system in 

an at-reactor or away-from-reactor ISFSI, which is consistent with current practice. 

 

11 $OLFHQVHHPD\WHUPLQDWHLWV3DUW RU3DUW license earlier if the remaining spent fuel is stored 

XQGHUDVSHFLILFOLFHQVHLVVXHGXQGHU&)53DUW
Generic Facility Descriptions and Activities 

185(*௅ 2- September 2014 

Operation and maintenance of spent fuel pools as well as the handling and transfer of spent fuel 

from spent fuel pools to ISFSIs are continued storage activities for the short-term timeframe. 

The U.S. Government Accountability Office (GAO) estimated the annual costs for operating and 

maintaining a spent fuel pool at a decommissioning reactor site (GAO 2012). Based on GAO’s 

HVWLPDWHVWKH15&HVWLPDWHVWKDWFRVWVUDQJHIURP0WR$13.4M per year. For 

loading the fuel from the pools into dry cask storage, EPRI estimated costs for the initial cask 

procurement and loading (EPRI 2012). Based on EPRI’s estimates, the NRC estimates costs to 

be $1.34M per cask. Based on the estimate of $1.34M per dry cask, the costs for transferring 

all of the spent fuel from the pool to dry cask for a 1,600 MTU facility (assuming 160 dry casks) 

would be $214M. This cost estimate is conservative because some of the spent fuel may have 

been moved into dry casks before the end of the licensed life for operation of a reactor; 

therefore, those costs would not be incurred during continued storage. 

During the short-term storage timeframe, spent fuel in the pool continues to generate decay 

heat from radioactive decay. The rate at which the decay heat is generated decreases the 

longer the reactor has been shut down. Storing the spent fuel in a pool of water provides a heat 

sink adequate for the removal of heat from the irradiated fuel. In addition, the fuel is located 

under water so that the radiation emanating from the fuel is shielded by the water, thus 

significantly limiting worker exposure to radiation. After the spent fuel has cooled adequately, it 

can be removed from the pool and stored in an ISFSI in air-cooled dry casks. At the earliest, 

such as for low-burnup spent fuel, transfer of spent fuel to an ISFSI occurs after the fuel has 

FRROHGIRU years (NRC 2002a). Minimum cooling times for high-burnup fuel vary with burnup 

DQGLQLWLDOXUDQLXPHQULFKPHQWIRUGLIIHUHQWGU\FDVNVWRUDJHV\VWHPVUDQJLQJIURPyears to 

greater than 20 years. 

Spent fuel pools are cooled by spent fuel pool cooling systems, which typically consist of 

pumps to circulate cooling water through the system, a purification system of filters and a 

demineralizer, and a heat exchanger (which transfers the heat from the spent fuel pool cooling 

system to the service-water system or its equivalent). The operation of the purification system 

generates some liquid low-level radioactive waste and some solid low-level radioactive waste in 

the form of demineralizer resins. During decommissioning, some licensees opt to modify the 

existing spent fuel pool support systems by installing self-contained spent fuel pool cooling and 

cleanup systems and monitoring, controls and electrical power. These modifications effectively 

isolate the spent fuel pool from the remainder of plant structures, systems, and components, 

thereby creating a “spent fuel pool island.” This approach allows decommissioning to begin on 

WKHUHPDLQGHURIWKHSODQWZKLOHWKHVSHQWIXHOLVVDIHO\VWRUHG(35,$VGHVFULEHGLQ

Chapter 4 of this GEIS, the operation of a new self-contained system would be bounded by the 

impacts of operating the existing cooling system, which are also described in Chapter 4. The 

environmental impacts of constructing a new spent fuel pool cooling system, which facilitates 

decommissioning activities, are addressed in Chapter 6 of this GEIS. 
Generic Facility Descriptions and Activities 

September 2014 2-29 185(*௅

For plants that enter SAFSTOR, the spent fuel pool will continue to be subject to preventative 

and corrective maintenance, including maintenance of the structure, its security systems, 

radiation protection and environmental monitoring programs, and processing of radioactive 

waste that may be generated. 

For purposes of analysis in this GEIS, the NRC assumes timely decommissioning of the reactor 

in accordance with requirements in 10 CFR or F$VDUHVXOWDOOVSHQWIXHOLQ

storage in the spent fuel pool is assumed to be transported to a repository, if it is available, or to 

either an at-reactor or away-from-reactor ISFSI within 60 years beyond the licensed life for 

operation of the reactor. 

2.2.1.3 Activities at At-Reactor ISFSIs 

Operation and maintenance activities at an at-reactor ISFSI are focused on inspections, 

monitoring, and training. The staff that must be trained for ISFSI operations include staff for 

operations, maintenance, health physics, and security. A licensee will also maintain an 

emergency response plan for ISFSI-related events. 

At-reactor ISFSI operation and maintenance are continued storage activities in the short-term, 

long-term, and indefinite timeframes. EPRI developed estimates for routine annual operation 

and maintenance costs for an at-reactor ISFSI (EPRI 2012). Based on EPRI’s estimates, the 

NRC estimates annual costs of $6.4M. Construction of an at-reactor ISFSI is not a continued 

storage activity in the short-term timeframe. 

In accordance with 10 CFR  for specifically licensed ISFSIs, the initial license term for an 

ISFSI must not exceed 40 years and licenses may be renewed upon NRC approval for a period 

not to exceed 40 years. ,QDFFRUGDQFHZLWK&)5DJHQHUDOOLFHQVHIRUVSHQWIXHO

storage in a cask fabricated under a Certificate of Compliance commences on the date that the 

cask is first used by a general licensee and continues through any renewals of the Certificate of 

Compliance, unless otherwise specified in the Certificate of Compliance, and terminates when 

the Certificate of Compliance for the cask expires. Renewal applications for specifically 

licensed ISFSIs and spent fuel storage cask designs approved for use under the general license 

must include, among other things: (1) time-limited aging analyses that demonstrate structures, 

systems, and components important to safety will continue to perform their intended safety 

function for the requested period of extended operation and (2) a description of the aging 

management program for management of issues associated with aging that could adversely 

affect structures, systems, and components important to safety. The NRC reviews renewal 

applications using its Standard Review Plan for Renewal of Spent Fuel Dry Cask Storage 

System Licenses and Certificates of Compliance (NRC 2011b). 

The kinds of aging effects managed under an aging management program include, but are not 

limited to concrete cracking and spalling; cask and canister confinement boundary material 
Generic Facility Descriptions and Activities 

185(*௅ 2-30 September 2014 

degradation; and reduction in heat transfer (e.g., by blocked air duct screens). The application 

of aging management programs may include structure monitoring; monitoring of protective 

coating on carbon steel structures; ventilation surveillance; welded canister seal and leakage 

monitoring programs; and bolted canister seal and leakage monitoring programs (DOE 2012). 

2.2.1.4 Activities at Away-from-Reactor ISFSIs 

In assessing environmental impacts from construction and operation at an away-from-reactor 

ISFSI, the NRC has drawn from the PFS facility environmental impact statement prepared by 

the NRC (NRC 2001). The proposed PFS facility was designed to store up to 40,000 MTU and 

was licensed to operate for 20 years. The NRC now allows an initial license term of 40 years 

with 40-year renewal terms. While this GEIS uses the general attributes of such a facility to 

assess likely impacts for purposes of this analysis, it should be recognized that the 

environmental impacts of constructing and operating an away-from-reactor ISFSI would be 

evaluated in more detail in an environmental review associated with a site-specific license 

application. 

Based on the construction plans for the proposed PFS facility, construction of the away-fromreactor ISFSI would include construction of major buildings (e.g., administrative, security, and 

maintenance) including a canister transfer building and installation of concrete storage pads, 

batch plant, access and heavy haul roads, parking areas, and potentially new rail lines. A peak 

ZRUNIRUFHRIDSSUR[LPDWHO\ZRUNHUVZRXOGEHH[SHFWHG15&*URXQGZDWHUZHOOV

could be installed for potable water use or aboveground storage tanks could be erected for 

potable water and water for fires and the concrete plant. 

Should storage at an away-from-reactor ISFSI continue for a long enough time for bare fuel 

handling to be required for inspection or maintenance, then a DTS could be constructed at the 

facility. 

Operation of the away-from-reactor ISFSI would include receiving, transferring, storing, and 

repackaging of spent fuel. If a repository becomes available, operations could include 

transferring spent fuel canisters to shipping casks and transporting them to the repository. 

Approximately 100 to 200 loaded shipping casks would be received at the postulated facility 

each year (NRC 2001). The shipping casks would be brought into the canister transfer building 

where the spent fuel would be transferred from the shipping cask to a storage cask. The 

storage casks would then be placed on the concrete storage pads. 

Away-from-reactor ISFSI construction, operation, and maintenance are continued storage 

activities in the short-term, long-term, and indefinite timeframes. Section 2.1.3 discusses awayfrom-reactor ISFSI construction costs. The initial away-from-reactor ISFSI constructed during 

the short-term timeframe includes transportation capital costs and is estimated to be $6M 
Generic Facility Descriptions and Activities 

September 2014 2-31 185(*௅

(see Section 2.1.3). EPRI estimated the total annual routine costs for operation and 

maintenance during “caretaker” periods (i.e., when loading and unloading is not occurring) 

(EPRI 2009). This estimate included administrative costs, labor costs, and other operating 

costs (excluding railroad freight fees and State inspection fees). Based on EPRI’s estimates, 

the NRC estimates annual costs for “caretaker” periods of $11.6M. 

Continued storage costs will include transportation activities to move spent fuel to an awayfrom-reactor ISFSI. These transportation costs include initial costs for cask procurement and 

loading, additional labor costs associated with loading and unloading transportation casks 

(i.e., labor cost beyond the annual routine caretaker costs), and shipping costs (i.e., railroad 

freight fees). As described in Section 2.1.3, transportation casks and other transportation 

equipment capital costs are accounted for in the storage facility construction cost. The costs for 

initial cask procurement and loading are assumed to be the same as the costs for the at-reactor 

facility, which are estimated to be $1.34M (see Section 2.2.1.2). EPRI also estimated annual 

transportation of 200 casks (i.e., 2,000 MTU of spent fuel) to an away-from-reactor ISFSI (EPRI 

2009). Based on EPRI’s estimates, the NRC estimates additional annual labor costs of $.3M 

for lRDGLQJDQGXQORDGLQJWKHWUDQVSRUWDWLRQFDVNVDQG0LQUDLOURDGIHHVDQGState 

inspection fees. 

To completely fill a 40,000 MTU (assuming 4,000 casks) capacity away-from-reactor facility 

FRVWVB) for initial cask procurement and loading, $106M for the 

additional labor associated with ORDGLQJDQGXQORDGLQJWUDQVSRUWDWLRQFDVNVDQG0IRU

transportation fees. The total cost for initially constructing and filling a 40,000 MTU capacity 

away-from-reactor ISFSI is $B. 

2.2.2 Long-Term Storage Activities 

As described below, the new activities associated with long-term storage include continued 

facility maintenance, construction, and operation of a DTS, and storage facility replacement. 

The maintenance activities during the long-term storage activities are the same as for the 

short-term, including any additional monitoring and inspections that may arise as part of 

implementation of ongoing aging management programs. The annual costs for routine ISFSI 

operation and maintenance described in Section 2.2.1.3 in the short-term timeframe would 

continue throughout the long-term timeframe. 

2.2.2.1 Construction and Operation of a DTS 

As described in Section 2.1.4, the NRC assumes a DTS, or its equivalent, would be used to 

transfer fuel as needed for inspection or repackaging. For the purposes of this GEIS, the NRC 

assumes the reference DTS would be constructed, operated, and replaced once during the 

long-term storage timeframe, and every 100 years thereafter. The reference DTS would occupy 

aboXWKDDFDQGZRXOGKDYHDWRWDOUHVWULFWHGDFFHVVDUHDRIKD ac). The NRC 
Generic Facility Descriptions and Activities 

185(*௅ 2-32 September 2014 

assumes that construction of a reference DTS would take 1 to 2 years. Section 2.1.4 discusses 

construction costs for a DTS. Operation costs for the DTS, described in Section 2.2.2.2, are 

associated with the labor to transfer spent fuel from old casks to new casks. 

DOE has described the operation of a reference DTS in the Dry Transfer System Topical Safety 

Analysis Report (DOE 1996). A summary is provided here to illustrate the process of spent fuel 

repackaging. 

The reference DTS includes three major areas: 

x preparation area, 

x lower access area, and 

x transfer confinement area. 

As shown in Figure 2-3, receiving casks and source casks enter the preparation area and exit 

the DTS on rail-mounted trolleys. To begin spent fuel transfer operations, a receiving cask 

(i.e., the cask into which fuel will be transferred) is transported to the DTS. The receiving cask 

is positioned and loaded on a receiving cask transfer trolley at the DTS and rolled into the 

preparation area. Next, the receiving cask lid and outer and inner canister lids are removed. 

Finally, the receiving cask is moved into the lower access area and mated to the transfer 

confinement area. 

A source cask (i.e., the cask from which fuel will be transferred) follows a similar path as the 

receiving cask into the lower access area and is mated to the transfer confinement area. 

No personnel are present in the lower access area for the transfer operations; all transfer 

operations are controlled remotely. The lids on both the receiving cask and source cask are 

removed to prepare for spent fuel transfer. The fuel-assembly-handling subsystem in the 

transfer confinement area is used to grab and lift a spent fuel assembly from the source cask. 

The spent fuel assembly is lifted inside a transfer tube and then moved over an empty position 

in the receiving cask. The spent fuel assembly is lowered into the receiving cask and detached 

from the lifting device. When spent fuel transfers are complete, both casks are closed, 

detached from the transfer confinement area, and ultimately removed from the lower access 

area back to the preparation area. 

Maintenance and monitoring activities at the DTS would include routine inspections and testing 

of the spent fuel and cask transfer and handling equipment (e.g., lift platforms and associated 

mechanical equipment) and process and effluent radiation monitoring. 

Damaged Fuel 

As stated in Section 2.1.4, one reason DTSs may be needed in the future is to reduce risks 

associated with unplanned events (e.g., the need to repackage spent fuel that becomes 
Generic Facility Descriptions and Activities 

September 2014 2-33 185(*௅

damaged or that becomes susceptible to damage while in dry cask storage). The NRC defines 

damaged spent fuel as any fuel rod or fuel assembly that can no longer fulfill its fuel-specific or 

system-UHODWHGIXQFWLRQV15&7KHVHIXQFWLRQVLQFOXGHFULWLFDOLW\VDIHW\UDGLDWLon 

shielding, confinement, and retrievability of the fuel. Appendix B of this GEIS describes spent 

fuel degradation mechanisms that could occur during continued storage. These include a 

mechanism (i.e., hydride reorientation) in which high-burnup spent fuel cladding can become 

less ductile (more brittle) over time as cladding temperatures decrease. Taking actions (e.g., 

repackaging or providing supplemental structural support) can reduce risks posed by damaged 

fuel by maintaining fuel-specific or system-related safety functions. 

The Transnuclear-EPRI DTS described by DOE in its topical safety analysis report (DOE 1996) 

and summarized in Section 2.1.4 of this GEIS does not have the capability to handle damaged 

spent fuel, which the DOE defined as spent fuel that is not dimensionally or structurally sound 

and spent fuel that cannot be handled by normal means. However, as a result of its experience 

with damaged spent fuel, described in more detail in the following paragraphs, the nuclear 

power industry has developed specialized tools that could be deployed if damaged spent fuel 

needs to be retrieved from a dry cask storage system. Therefore, NRC considers it reasonable 

to assume that a DTS similar to the Transnuclear-EPRI DTS could be designed, constructed, 

and equipped to handle damaged fuel. 

International experience provides a broad understanding of the technical feasibility of various 

methods for handling damaged fuel. An International Atomic Energy Agency (IAEA 2009) 

technical report documented the types of methods that have been used separately or in 

combination to handle damaged spent fuel under a variety of circumstances while maintaining 

specific safety functions. The methods include removinging rods, canning, replacing or 

repairing damaged structural components, and providing supplemental structural support. 

When a single rod in a fuel assembly is damaged, the damaged rod can be removed to restore 

the integrity of the fuel assembly, but that process leaves a gap in the fuel assembly. Rod 

replacement involves replacing the damaged rod with a steel rod to maintain the structural 

integrity of the assembly to facilitate transfer. Structural repair or replacement involves repairing 

or replacing damaged components in the assembly (e.g., grid spacers, vanes, and tie plates) to 

restore stability of the assembly. Supplemental structural support involves adding mechanical 

strengthening to the assembly to address loss of capabilities from a damaged part. 

The NRC requires that spent fuel classified as damaged for storage be protected during storage 

(e.g., placed in a can designed for damaged fuel, referred to as a damaged fuel can or 

GDPDJHGIXHOFRQWDLQHU15&12 A damaged fuel can is designed to ensure that the fuelspecific or system-related functions continue to be met. When a spent fuel assembly is placed 

 

12 An acceptable alternative approved by the NRC is to confine damaged spent fuel using top and bottom 

“end caps” in dry cask storage system basket cells (Transnuclear, Inc. 2011). 
Generic Facility Descriptions and Activities 

185(*௅ 2-34 September 2014 

in a damaged fuel can, one or more of the necessary safety functions, depending on the type of 

can, are performed by the can instead of the spent fuel assembly (IAEA 2009). A damaged fuel 

can will confine fuel particles, debris, and the damaged spent fuel to a known volume in a cask; 

ensure compliance with criticality safety, shielding, thermal, and structural requirements; and 

permit normal handling and retrieval of spent fuel from a cask. An additional example of a 

method approved by the NRC for providing supplemental structural support to damaged fuel 

involves using instrument tube tie rods to reinforce PWR spent fuel assembly top nozzles that 

have suffered inter-JUDQXODUVWUHVVFRUURVLRQFUDFNLQJ)5

In current dry cask storage system designs, damaged fuel cans are placed in a limited number 

of positions inside the canister or cask (Transnuclear, Inc. 2011). Because a damaged fuel can 

performs the safety functions of undamaged fuel components (i.e., criticality safety, shielding, 

confinement, retrievability, etc.), the presence of damaged fuel cans in dry cask storage 

systems would not cause environmental impacts during continued storage different from casks 

containing undamaged spent fuel. For this reason, this GEIS does not further consider generic 

environmental impacts associated with use of damaged fuel cans or their alternatives. 

2.2.2.2 Replacement of Storage and Handling Facilities 

For purposes of analysis in this GEIS, the NRC assumes that storage facilities will require 

complete replacement over the long-term storage timeframe (100 years). Replacement 

activities are assumed to occur as needed throughout the long-term storage timeframe, but not 

all at once over a relatively short interval (e.g., 2 years). Replacement activities include the 

following: 

x construction of new ISFSI pads near the initial pads, 

x construction of replacement storage casks or HSMs, 

x movement of canisters in good condition to new casks or HSMs, 

x use of the initial and replacement DTS to transfer fuel to new canisters and casks, as 

necessary, and 

x replacement of the DTS. 

Continued storage activities include replacing the storage facility (for either an at-reactor or an 

away-from reactor ISFSI), the DTS, and the spent fuel canisters and casks. Replacing the 

ISFSI and DTS requires dismantling the existing facilities and constructing new ones. The costs 

for dismantling the existing ISFSIs are based on decommissioning activities. Using 

decommissioning costs conservatively bounds the dismantling costs because there would be 

fewer activities associated with dismantling than for decommissioning as the site is not being 

released for other uses. Dismantling costs for at-reactor ISFSIs are based on licensee 
Generic Facility Descriptions and Activities 

September 2014 2- 185(*௅

LQIRUPDWLRQ1XFOHDU0DQDJHPHQW&RPSDQ\//&DQGGLVPDQWOLQJFRVWVIRUDZD\-fromreactor ISFSIs are based on EPRI information (EPRI 2009). 

The 15&HVWLPDWHVFRVWVIRUGLVPDQWOLQJWKHH[LVWLQJIDFLOLW\DW6M for an at-reactor ISFSI 

DQG0IRUDQDZD\-from-reactor ISFSI. The cost for dismantling the DTS is the same for 

both the at-reactor and away-from-reactor facilities. Although the decommissioning cost for a 

DTS is not known, the decommissioning cost of an away-from reactor ISFSI is about 40 percent 

of the initial construction costs (see Section 2.1.3). Applying this same 40 percent difference 

between the DTS construction and demolition costs results in an estimated DTS dismantling 

cost of $3.43M. Construction of a replacement at-reactor facility costs $10M (see 

Section 2.1.2.2) and construction of a replacement away-from-UHDFWRUIDFLOLW\FRVWV0

(see Section 2.1.3). &RQVWUXFWLRQRIDUHSODFHPHQW'76FRVWV0VHH6HFWLRQ

Using the costs for initial construction as estimates for constructing replacement facilities can be 

considered conservative because start-up costs (e.g., design, engineering, and licensing cost) 

may be lower for subsequent construction at the same location. 

Replacing a cask requires procurement of a new cask and the labor to unload the fuel from the 

old cask and then load the fuel into the new cask. EPRI estimated costs for cask procurement 

and loading (EPRI 2012). Based on EPRI’s estimates, the NRC estimates that replacing a 

single cask costs $1.66M, which includes procuring a new cask at $1.02M, unloading fuel from 

the old cask at $321,000, and subsequent loading of spent fuel into the new cask at $321,000. 

The initial transfer of spent fuel into a dry cask costs $1.34M per cask (see Section 2.2.1.2) 

because the unloading of spent fuel from the old cask is not required. The labor costs for 

replacing a single cask can be considered conservative because the unloading of the old cask 

and loading of the new cask occur essentially as one operation. Replacing all 160 casks for a 

1,600 MTU at-reactor ISFSI (assuming 10 MTU per cask) can then be estimated to cost $26M, 

and replacing all 4,000 casks for a 40,000 MTU away-from-reactor ISFSI (assuming 10 MTU 

per cask) costs $6.64B. The total cost for complete replacement of an at-reactor storage facility 

(i.e., dismantling the old ISFSI and DTS, building a new ISFSI and DTS, procuring new casks, 

and transferring the spent fuel from the old facilities to the new facilities) is about $392M. The 

total cost for complete replacement of an away-from-UHDFWRUIDFLOLW\LVDERXW1B. 

2.2.3 Indefinite Storage Activities 

Should a repository not become available within the long-term storage timeframe, then activities 

described for the long-term storage timeframe in Section 2.2.2 are assumed to continue 

indefinitely. For purposes of analysis in this GEIS, the NRC assumes that storage facilities 

(i.e., an ISFSI and its associated DTS) would be replaced once every 100 years. The costs for 

replacement of storage and handling facilities discussed in Section 2.2.2.2 would therefore be 

realized every 100 years as well. The annual costs for routine ISFSI operation and 

maintenance described in Section 2.2.1.3 for the short-term timeframe would continue. 
Generic Facility Descriptions and Activities 

185(*௅ 2-36 September 2014 

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&)53DUWCode of Federal Regulations, Title 10, Energy3DUW3/LFHQVHV

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$FFHVVLRQ1R0/$

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0/$

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La &URVVH:LVFRQVLQ$FFHVVLRQ1R0/$

6&RKHQ	$VVRFLDWHV,QFEffectiveness of Fuel Rod Cladding as an Engineered 

Barrier in the Yucca Mountain Repository0F/HDQ9$$FFHVVLRQ1R0/

Sailor, V.L, K.R. Perkins, J.R. Weeks, and H.R. Connell. Severe Accidents in Spent Fuel 

Pools in Support of Generic Safety Issue 82. NUREG/CR–Brookhaven National 

Laboratory, Upton, New York. Available at KWWSZZZRVWLJRYEULGJHVHUYOHWVSXUO-

YRRI/SGI. 

Transnuclear, Inc. 2011. NUHOMS® 37PTH Dry Shielded Canister. ANP:U-291-V2-11-ENG, 

Columbia, Maryland. Available at 

http://us.areva.com/home/liblocal/docs/Solutions/literature/ANP_U_291_V2_11_ENG_NUHOM

S_37+SGI. 

UxC (Ux Consulting). 2013. 32YHU'U\6WRUDJH6\VWHPV'HSOR\HGLQWKH86 ́

StoreFUEL :14– Roswell, Georgia. 
September 2014 3-1 185(*௅

3.0 Affected Environment 

For purposes of the evaluation in this Generic Environmental Impact Statement for Continued 

Storage of Spent Nuclear Fuel (GEIS), the affected environment is the environment that exists 

at and around the facilities that store spent nuclear fuel (spent fuel) after the end of a reactor’s 

licensed life for operation. Spent fuel is stored in at-reactor spent fuel pools and independent 

spent fuel storage installations (ISFSIs). Where appropriate, this chapter will discuss the 

environmental impacts during reactor operations to establish the baseline affected environment 

at the beginning of continued storage. 

The affected environment and potential impacts of continued storage at an away-from-reactor 

ISFSI are discussed in Chapter DQGDUHQRWDGGUHVVHGIXUWKHULQWKLVFKDSWHU%HFDXVH

conditions at at-reactor ISFSIs are at least partially the result of past construction and 

operations at power plants, the impacts of these past and ongoing operations and how 

they have shaped the environment help to establish the baseline affected environment. 

A comprehensive description of the affected environment during operations is provided in the 

Generic Environmental Impact Statement for License Renewal of Nuclear Plants (License 

Renewal GEIS) (NRC 2013a) and the analysis in this GEIS relies on that description to help 

establish the affected environment for continued storage. Sections 3.1 through 3.16 provide a 

general description of the affected at-reactor environment for each resource area. Descriptions 

of the typical facilities and activities that occur during continued storage are described in 

Chapter 2. The potential environmental impacts of continued storage at reactor sites are 

evaluated in Chapter 4. 

3.1 Land Use 

This section describes the affected environment in terms of land use associated with continued 

storage of spent fuel. 

The general characteristics of nuclear power plants are described in Section 2.1.1 of this GEIS. 

2SHUDWLQJFRPPHUFLDOQXFOHDUSRZHUSODQWVLWHVUDQJHLQDUHDIURPKDDFWRKD

(14,000 ac) (NRC 2013a). Nuclear power plant sites are zoned for industrial use with land 

UHTXLUHPHQWVJHQHUDOO\DPRXQWLQJWRWRKDWRDFIRUthe reactor-containment 

building, auxiliary buildings, cooling system structures, administration and training offices, and 

other facilities (e.g., switchyards, security facilities, and parking lots). Areas disturbed during 

construction of the power plant generally were returned to prior uses when construction was 

completed. Other land commitments include transmission line right-of-ways and cooling lakes 

(if used) (NRC 2013a). 
Affected Environment 

185(*௅ 3-2 September 2014 

As described in the License Renewal GEIS (NRC 2013a), areas surrounding nuclear power 

plant sites typically consist of flat to rolling countryside in wooded or agricultural areas. 

,QIRUPDWLRQRQODQGFRYHUZLWKLQNPPLRIFRPPHUFLDOQXFOHDUSRZHUSODQWVLVVXPPDUL]HG

in Table 3.2–1 of the License Renewal GEIS (NRC 2013a). Most of the land cover near plants 

is undeveloped land (forest, wetlands, herbaceous cover, and shrub/scrub land), agricultural 

land, or open water. U.S. Nuclear Regulatory Commission (NRC) regions and the location of 

operating reactors within the United States are shown in Figure 3-1. In Region I (Northeast) and 

Region II (Southeast), more than 80 percent of land cover surrounding most plants is open 

water, forest, wetlands, and agricultural. Power plants in Region III (northern Midwest) are 

mostly surrounded (approximately 80 percent) by agricultural land, open water, and forests. In 

Region IV (West and southern Midwest), more than 90 percent of land cover surrounding most 

plants is agricultural land, shrub/scrub land, open water, forest, herbaceous cover, and wetlands 

(NRC 2013a). 

 

Figure 3-1. Map of NRC Regions Showing Locations of Operating Reactors (NRC 2013b)
Affected Environment 

September 2014 3-3 185(*௅

Nuclear power plants and their ISFSIs are located in a range of political jurisdictions including 

towns, townships, service districts, counties, parishes, and states. The distances of plants from 

metropolitan and residential areas vary among sites. Most sites are not very remote (i.e., they 

DUHQRWPRUHWKDQDERXWNP>PL@IURPDFRPPXQLW\RISHRSOHRUNP>PL@

from a community of 100,000 people). State, Federal, and Native American lands are present 

to various extents within the 80-NP-mi) radius of power plants (NRC 2013a). 

During the period from 1960 to 1980, with utilities and local government actively encouraging 

growth (Metz 1983), commercial and industrial land uses tended to expand within the 16-km 

(10-mi) radius around nuclear power plants at the expense of agriculture (NRC 2013a). In some 

instances, the roads and water lines built for plant purposes encouraged residential and 

industrial growth. As described in Section 2.1, the distance of the nearest resident to a nuclear 

SRZHUSODQWDQG,6)6,LVW\SLFDOO\DERXWNPPL5HFHQWO\ORFDOMXULVGLFWLRQVKDYH

adopted comprehensive land use or master plans to control residential and commercial growth 

and preserve agricultural land around nuclear power plants (NRC 2013a). 

Commercial nuclear power plant sites are owned and maintained by investor-owned utilities or 

merchant generators (i.e., independent power producers) that operate the associated power 

plants. While many plant owners use the land solely for generating electricity, some owners 

allow other uses for the land. Some plant owners lease land for agricultural (farming) and 

forestry production, permit cemetery and historical site access, and designate portions of their 

sites for recreation, management of natural areas, and wildlife conservation. As a result of 

security concerns after September 11, 2001, licensees have implemented improved site security 

measures, such as upgraded fencing, reduced site access, and increased signage detailing site 

access and restrictions (NRC 2013a). 

Spent fuel pools are housed in shield buildings at nuclear power plants with boiling water 

reactors or in fuel buildings at plants with pressurized water reactors (NRC 2013a). Continued 

storage in spent fuel pools would require only the building housing the spent fuel pool and any 

cooling system infrastructure that keeps the spent fuel cool. Land requirements for spent fuel 

pools are small in comparison to the total nuclear power plant site area. 

At most operating nuclear power plants, ISFSIs have been constructed to provide increased 

spent fuel storage because the spent fuel pools have reached capacity. The majority of ISFSIs 

are located at licensed nuclear power plant sites. Land requirements for ISFSIs (either at 

operating or decommissioned power plants) are small in comparison to the total power plant site 

area. Spent fuel storage under either a general license or a site-specific license at an operating 

reactor consists of the casks, a cask transfer system (i.e., cranes and mobile equipment 

necessary to move the casks), and reinforced concrete pads on which the casks are placed 

(NRC 1989). Table 3-1 provides comparisons of land area needed for ISFSIs at various nuclear 

power plants in contrast to the total land area of power plant sites. 
Affected Environment 

185(*௅ 3-4 September 2014 

Table 3-1. Land Area Characteristics of Operating Nuclear Power Plants with Site-Specific 

ISFSI Licenses 

Plant 

Total Site Area 

ha (ac) 

Land Area Developed 

for ISFSI 

ha (ac) 

Land Area of Concrete 

Pad(s) 

ha (ac) 

Calvert Cliffs 843 (2,108) 2.4 (6) 

Diablo Canyon  1.6–2 (4– 0.48 (1.2)

Surry 336 (840)  

+%5RELQVRQ 2,408 (6,020)  0.016 (0.04)

North Anna  4 (10) 

Oconee  1.2 (3) 0.16 (0.4)

Prairie Island  4 (10) 0.16 (0.4)

Sources: NRC 2012a; 2009a; 2008; DE

3.2 Socioeconomics 

This section describes the general socioeconomic factors that could be directly or indirectly 

affected by continued storage. For the GEIS, the NRC assumes that all nuclear power plant 

sites have constructed ISFSIs by the end of a reactor’s licensed life for operation. Further, by 

this time, the socioeconomic effects of reactor operations have become well established 

because regional socioeconomic conditions will have adjusted to the presence of the nuclear 

power plant. In addition, local communities will have adjusted to fluctuations in workforce 

caused by regularly scheduled refueling and maintenance outages. Changes in employment 

and tax payments caused by the transition from reactor operations to decommissioning, and the 

continued storage of spent fuel, can have a direct and indirect effect on public services and 

housing demand, as well as traffic volumes in the region around each nuclear power plant site.

In general, nuclear power plant sites in the United States are located in one of two broad 

regional economic settings: rural or semi-urban. Rural areas have relatively simple economies 

that are based primarily on agricultural activity (NRC 2013a). Rural economies have smaller, 

less diversified labor markets that are often composed of lower-paying occupations requiring 

less skill (NRC 2013a). Examples of nuclear power plant sites located in rural environments 

LQFOXGH'LDEOR&DQ\RQ*UDQG*XOI2FRQHH3HDFK%RWWRP, Susquehanna, Three Mile Island, 

and Wolf Creek. Semi-urban areas have more complex economic structures, containing a wider 

range of industries, with larger and more diverse labor markets (NRC 2013a). Examples of 

power plant sites in semi-urban areas include Indian Point, Limerick, Millstone, and Palo Verde.

For the purposes of this GEIS, the socioeconomic region of influence is defined by where spent 

fuel storage workers and their families reside, spend their income, and use their benefits, 

thereby directly and indirectly affecting the economic conditions of the region. Local and 

regional communities provide the people, goods, and services needed to support spent fuel 
Affected Environment 

September 2014 3- 185(*௅

storage operations. Spent fuel storage operations, in turn, provide wages and benefits for 

people and dollar expenditures for goods and services.

The NRC has prepared several environmental assessments (EAs) for constructing and 

operating at-reactor ISFSIs. A review of these EAs found that the construction workforce for an 

ISFSI ranged from approximately 20 to 60 workers for approximately 1 year (NRC 1991a, 2003, 

). In most cases, the construction workforce was comprised of locally available 

construction workers and existing power plant operations and security personnel. Since most 

ISFSIs were constructed during the licensed life of the reactor (including renewed license 

periods), most reactor licensees added a small number of additional workers (i.e., fewer than 

WKUHHZRUNHUVWRVXSSRUW,6)6,RSHUDWLRQV15&E1RDGGLWLRQDOZRUNHUV

were required to maintain or monitor continued ISFSI operations for license renewal (NRC 

DE, 2009a, 1991a, 2012a).

The number of operations workers at a nuclear plant decreases as the power plant transitions 

from reactor operations to decommissioning. Compared to the number of workers needed to 

support nuclear power plant operations (i.e., 600 to 2,400 workers [NRC 2013a]), the storage of 

spent fuel requires far fewer workers, from 20 to ZRUNHUV. In contrast, decommissioning 

activities require approximately 100 to 200 workers (NRC 2002). The number of operations 

workers required for continued storage would depend on current storage operations activities at 

any given site (e.g., ISFSI and spent fuel pool transfer operations). As noted in Chapter 1 of 

this GEIS, the environmental impacts of decommissioning are not considered to be part of 

continued storage. 

3.2.1 Employment and Income 

Regional socioeconomic conditions associated with continued storage can vary depending on 

the location of the at-reactor storage site and the size of the storage workforce. Impacts 

associated with reactor shutdown and decommissioning are discussed with respect to 

cumulative impacts in Chapter 6 of this GEIS. Some systems that were used during reactor 

operations would remain in operation to ensure spent fuel pool cooling prior to the transfer of 

spent fuel from the pool to an ISFSI. After reactor operations cease, a reduced workforce would 

maintain and monitor the spent fuel pool and ISFSI. The workforce would be further reduced 

once all spent fuel is transferred to the ISFSI. Workforce numbers would vary from site to site. 

Fewer than 20 full-time employees monitor and maintain the spent fuel at GEH Morris, an awayfrom-reactor spent fuel pool storage facility (NRC 2004). ,QWKH(OHFtric Power Research 

Institute and Maine Yankee Atomic Power Company prepared a report that provides detailed 

information on the decommissioning of Maine Yankee Atomic Power Station (EPRI and Maine 

<DQNHH$W0DLQH<DQNHHDSSUR[LPDWHO\ZRUNHUVFRmpleted fuel transfer from the 

VSHQWIXHOSRROWRWKH,6)6,(35,DQG0DLQH<DQNHH$IWHUfuel transfer was completed, 

RYHUDOOVWDIILQJDW0DLQH<DQNHHZDVUHGXFHGIXUWKHU(35,DQG0DLQH<DQNHH

Currently, Maine Yankee maintains a staff of 3WRZRUNHUVZKLFKFRQVLVWVRIRSHUDWLRQVDQG
Affected Environment 

185(*௅ 3-6 September 2014 

security personnel (MYAPC 2013). In contrast, at Fort St. Vrain, the licensee estimated that ten 

workers were needed for ISFSI operations (NRC 1991a).

3.2.2 Taxes 

Tax payments to local communities vary widely and the magnitude of tax payments depends on 

a number of factors including the State tax laws and established tax payment agreements with 

local tax authorities. These tax payments, whether occurring in rural or semi-urban areas, 

provide support for public services at the local level (NRC 2013a). After termination of reactor 

operations, property tax payments would continue to provide revenue, albeit at a reduced rate, 

for State and local governments to spend on education, public safety, local government 

services, and transportation. For example during plant operations, Maine Yankee paid 

approximately $12 million a year to the Town of Wiscasset. Following plant shutdown, the town 

initially agreed to a reduction in taxes to approximately $6.1 million. Then, subsequent 2-year 

agreements were reached, and the annual tax liability was reduced to approximately $1 million 

(35,DQG0DLQH<DQNHH)RUWKH–2013 tax year, Maine Yankee paid 

approximately $1,003,000 in property taxes and fees (MYAPC 2013). Portland General Electric, 

the licensee for the decommissioned Trojan site, which stopped electrical generation in 

November 1992, has maintained an at-UHDFWRU,6)6,DQGSDLGLQSURSHUW\WD[HV

for the 2012 tax year (Columbia County 2013). Pacific Gas and Electric, the licensee for 

+XPEROGW%D\ZKLFKVKXWGRZQLQ-XO\KDVPDLQWDLQHGDQDW-reactor spent fuel pool 

and SDLGLQSURSHUW\WD[HVWR+XPEROGW&RXQW\IRUWKH–2013 tax year 

(PG&E 2012). Connecticut Yankee Atomic Power Company, the licensee for Haddam Neck, 

which shut down in December 1996, paid approximately $1,200,000 in property taxes for the 

2012 tax year to the town of Haddam (CYAPC 2012). 

3.2.3 Demography 

Nuclear power plants sites and their associated spent fuel pools and ISFSIs are located in a 

range of political jurisdictions (e.g., towns, townships, service districts, counties, parishes, 

1DWLYH$PHULFDQODQGVDQGVWDWHV0RUHWKDQ percent of the sites have a population 

density within an 80-NP-miUDGLXVRIIHZHUWKDQ persons/km2 (200 persons/mi2). In 

JHQHUDOWKHQHDUHVWUHVLGHQWWRDQXFOHDUSRZHUSODQWLVDSSUR[LPDWHO\NPPL15&

2013a). Demographic characteristics vary in the region around each nuclear power plant site 

and may be affected by the remoteness of the nuclear plant to regional population centers 

(NRC 2013a).

Many communities have transient populations associated with regional tourist and recreational 

activities, weekend and summer homes, or populations of students who attend regional colleges 

and other educational institutions. For example, nuclear power plant sites located in coastal 

UHJLRQVVXFKDV'&&RRNDQG3DOLVDGHVRQ/DNH0LFKLJDQ2\VWHU&UHHNRQWKH1HZ-HUVH\

shore north of Atlantic City, and Diablo Can\RQQRUWKRI$YLOD%HDFKKDYHVXPPHUZHHNHQG
Affected Environment 

September 2014 3- 185(*௅

and retirement populations and a range of recreational and environmental amenities that attract 

visitors from nearby metropolitan population centers (NRC 2013a). The regions around 

Vermont Yankee and Diablo Canyon power stations attract visitors seeking outdoor recreational 

activities for camping, skiing, and hiking in nearby state parks (NRC 2013a, 2003).

In addition to transient populations, farms and factories in rural communities often employ 

migrant workers on a seasonal basis. For example, berry production near the D.C. Cook and 

Palisades Nuclear Plants is a local agricultural activity that employs a sizable migrant labor 

force in the summer (NRC 2013a).

3.2.4 Housing 

Housing markets near nuclear power plant sites, including the spent fuel pools and associated 

ISFSIs, vary considerably, with wide ranges in the number of housing units, vacancy rates, and 

the type and quality of housing (NRC 2013a). Although housing demand may be temporarily 

affected by the number of workers employed at a nuclear power plant site (NRC 2013a), actual 

housing choices are not likely to be affected by the presence of a nuclear power plant or 

construction or operation of an ISFSI (NRC 2002). Rather, housing demand and choices 

are more likely to be in response to housing prices and commutes to a nearby urban area 

(NRC 2002). Nuclear power plants located in rural communities have relatively small housing 

markets (i.e., low housing availability), stable housing prices, lower median house values, and 

moderate and stable vacancy rates. In semi-urban regions, housing markets are likely to 

change more rapidly with population growth near metropolitan areas (NRC 2013a).

3.2.5 Public Services 

Licensees of nuclear power plant sites pay taxes to local and State governments. Revenues 

from these tax payments support public services at local levels (NRC 2013a). Changes in 

employment and tax payments caused by the transition from reactor operations to 

decommissioning and continued storage can have a direct and indirect effect on public services 

in the region around each nuclear power plant site. Although the most important source of 

revenue for local communities are property taxes, other sources of revenue include levies of 

electricity output and direct funding for local educational facilities and programs. As discussed 

in Section 3.2.2, after termination of reactor operations, property tax payments would continue 

to provide revenue, albeit at a reduced rate, for State and local governments to spend on public 

services (e.g., education, public safety, local government services, and transportation).

3.2.6 Transportation 

Local and regional transportation networks and traffic volumes in the vicinity of nuclear power 

plants and associated spent fuel pools and ISFSIs vary considerably depending on the regional 

population density, location, size of local communities, and the nature of economic development 
Affected Environment 

185(*௅ 3-8 September 2014 

patterns (NRC 2013a). For continued storage, it is anticipated that roadways used during plant 

operations would continue to be used for access to the ISFSI after reactor ceases operation. In 

both rural and semi-rural locations most sites have only one access road, which may experience 

congestion at peak travel times (NRC 2013a). For further information on transportation 

networks see Section 3.12. 

3.3 Environmental Justice 

This section describes the affected environment in the vicinity of at-reactor spent fuel storage 

sites with respect to environmental justice factors that could occur during continued storage. 

The environmental justice analysis assesses the potential for disproportionately high and 

adverse human health or environmental effects on minority and low-income populations that 

could result from continued storage. 

8QGHU([HFXWLYH2UGHU)5)HGHUDODJHQFLHVDUHUHVSRQVLEOHIRULGHQWLI\Lng 

and addressing potential disproportionately 

high and adverse human health and 

environmental impacts on minority and lowincome populations. Environmental justice 

refers to a Federal policy implemented to 

ensure that minority, low-income, and tribal 

communities historically excluded from 

environmental decision-making are given 

equal opportunities to participate in decisionmaking processes. In 2004, the Commission 

issued a Policy Statement on the Treatment of 

(QYLURQPHQWDO-XVWLFH0DWWHUVLQ15&

Regulatory and Licensing Actions (69 FR 

ZKLFKVWDWHV37KH&RPPLVVLRQLV

committed to the general goals set forth in 

Executive Order 12898, and strives to meet 

those goals as part of its National 

Environmental Policy Act (NEPA) review process” (NRC 2013a). 

The Council on Environmental Quality (CEQ) provides the following definitions to consider when 

conducting environmental justice reviews within the framework of NEPA, in Environmental 

Justice: Guidance under the National Environmental Policy Act &(4): 

x Disproportionately High and Adverse Human Health Effects—Adverse health effects are 

measured in risks and rates that could result in latent cancer fatalities, as well as other fatal 

or nonfatal adverse impacts on human health. Adverse health effects may include bodily 

impairment, infirmity, illness, or death. Disproportionately high and adverse human health 

Executive Order 12898, Federal Actions to 

Address Environmental Justice in Minority 

Populations and Low-Income Populations 

3(DFKFederal agency, whenever practicable and 

appropriate, shall collect, maintain, and analyze 

information assessing and comparing 

environmental and human health risks borne by 

populations identified by race, national origin, or 

income. To the extent practical and appropriate, 

Federal agencies shall use this information to 

determine whether their programs, policies, and 

activities have disproportionately high and 

adverse human health or environmental effects on 

minority populations and low-income populations” 

()5
Affected Environment 

September 2014 3-9 185(*௅

effects occur when the risk or rate of exposure to an environmental hazard for a minority or 

low-income population is significant (as employed by NEPA) and appreciably exceeds the 

risk or exposure rate for the general population or for another appropriate comparison 

group. 

x Disproportionately High and Adverse Environmental Effects—A disproportionately high 

environmental impact that is significant (as employed by NEPA) refers to an impact or risk of 

an impact on the natural or physical environment in a low-income or minority community that 

appreciably exceeds the environmental impact on the larger community. Such effects may 

include ecological, cultural, human health, economic, or social impacts. An adverse 

environmental impact is an impact that is determined to be both harmful and significant (as 

employed by NEPA). In assessing cultural and aesthetic environmental impacts, impacts 

that uniquely affect geographically dislocated or dispersed minority or low-income 

populations or American Indian tribes are considered. 

x Minority individuals—Individuals who identify themselves as members of the following 

population groups: Hispanic or Latino, American IndiDQRU$ODVND1DWLYH$VLDQ%ODFNRU

African American, Native Hawaiian or Other Pacific Islander, or two or more races meaning 

individuals who identified themselves on a Census form as being a member of two or more 

races, for example, Hispanic and Asian. 

x Minority populations—Minority populations are identified when (1) the minority population 

RIDQDIIHFWHGDUHDH[FHHGVSHUFHQWRUWKHPLQRULW\SRSXODWLRQSHUFHQWDJHRIWKH

affected area is meaningfully greater than the minority population percentage in the general 

population or other appropriate unit of geographic analysis. Minority populations may be 

communities of individuals living in close geographic proximity to one another, or they may 

be a geographically dispersed or transient set of individuals, such as migrant workers or 

American Indians, who, as a group, experience common conditions with regard to 

environmental exposure or environmental effects. The appropriate geographic unit of 

analysis may be a political jurisdiction, county, region, or State, or some other similar unit 

that is chosen so as not to artificially dilute or inflate the affected minority population. 

x Low-income population—Low-income population is defined as individuals or families 

living below the poverty level as defined by the 86&HQVXV%XUHDX¶V&XUUHQW3RSXODWLRQ

Reports, Series P–RQ,QFRPHDQG3RYHUW\86&%/RZ-income populations may 

be communities of individuals living in close geographic proximity to one another, or they 

may be a set of individuals, such as migrant workers, who, as a group, experience common 

conditions. 

&RQVLVWHQWZLWKWKH15&¶V3ROLF\6WDWHPHQW)5DIIHFWHGSRSXODWLRQVDUHGHILQHGDV

minority and low-income populations who reside within an 80-NP-mi) radius of a nuclear 

power plant site. Data on low-income and minority individuals are usually collected and 

analyzed at the census tract or census block group level (NRC 2013a). 
Affected Environment 

185(*௅ 3-10 September 2014 

For the continued storage of spent fuel, the NRC will comply with Executive Order 12898 

 FR  through implementation of its NEPA requirements in Title 10 of the Code of 

Federal Regulations &)53DUWE\FRQVLGHULQJLPSDFWVWRPLQRULW\DQGORZ-income 

populations in this GEIS. It should be noted, however, that the rulemaking is not a licensing 

action; it does not authorize the initial or continued operation of any nuclear power plant, and it 

does not authorize storage of spent fuel. Neither this rulemaking nor this GEIS identify specific 

sites for NRC licensing actions that would trigger a site-specific assessment. 

This GEIS describes the potential human health and environmental effects to minority and lowincome populations associated with continued storage of spent fuel at both at- and away-fromreactor ISFSIs. The NRC has determined that, for the purposes of this analysis, a generic 

analysis of the human health and environmental effects of continued storage on minority and 

low-income populations is possible.

For site-specific licensing actions, the NRC addresses environmental justice matters by 

(1) identifying the location of minority and low-income populations that may be affected by longterm storage of spent fuel at nuclear power plant sites, (2) determining whether there would be 

any potential human health or environmental effects to these populations and special-pathway 

receptors, and (3) determining if any of the effects may be disproportionately high and adverse. 

The NRC has and will continue to prepare a site-specific environmental analysis, including an 

assessment of potential impacts to minority and low-income populations prior to any future NRC 

licensing action.

As discussed in Section 3.2 of this GEIS, nuclear power plant sites in the United States are 

located in one of two broad regional economic settings: rural or semi-urban. Demographic 

characteristics vary in the region around each nuclear power plant site and may be affected by 

the remoteness of the nuclear plant to regional population centers (NRC 2013a). Nuclear power 

plants located in both rural and semi-urban areas can have varying concentrations of minority 

and low-income communities. Prairie Island Nuclear Generating Plant near Red Wing, 

Minnesota, is an example of a facility in a rural environment. The Prairie Island Indian 

Community is located immediately next to the Prairie Island Nuclear Generating Plant and is the 

closest minority population and American Indian community to spent fuel storage pools and an 

ISFSI. 

Subsistence Consumption of Fish and Wildlife 

Section 4-RI([HFXWLYH2UGHU)5GLUHFWV)HGHUDODJHQFLHVZKHQHYHU

practical and appropriate, to collect and analyze information on the consumption patterns of 

populations that rely principally on fish or wildlife for subsistence and to communicate the risks 

of these consumption patterns to the public. In this GEIS, the NRC considered whether there 

were any means for minority or low-income populations to be disproportionately affected by 

examining impacts to American Indians, Hispanics, migrant workers, and other traditional 
Affected Environment 

September 2014 3-11 185(*௅

lifestyle special-pathway receptors. Special pathways take into account the levels of 

radiological and nonradiological contaminants in native vegetation, crops, soils and sediments, 

groundwater, surface water, fish, and game animals on or near power plant sites that have 

spent fuel storage pools and ISFSIs.

The special-pathway-receptors analysis is an important part of the environmental justice 

analysis because consumption patterns may reflect the traditional or cultural practices of 

minority and low-income populations in an area, such as migrant workers or Native Americans. 

Traditional use of an area can be indicative of properties or resources that are historically 

significant for a living community to maintain its cultural heritage. These places—called 

traditional cultural properties—are discussed in Section 3.11 of this GEIS. For example, in the 

Prairie Island Nuclear Generating Plant license renewal review, the Prairie Island Indian 

Community provided the NRC information about the traditional use of Prairie Island as a 

summer encampment for fishing, hunting, gathering medicines and foods, and raising crops. 

During the review, the Prairie Island Indian Community also expressed concern about native 

plants on Prairie Island being displaced by invasive species and human health impacts 

associated with the use of plants that are culturally significant to the Prairie Island Indian 

Community.

Operating nuclear power plants must have a comprehensive radiological environmental 

monitoring program to assess the impact of site operations on the environment. During plant 

operations, nuclear power plant operators collect samples from aquatic pathways (e.g., fish, 

surface water, and sediment) and terrestrial pathways (e.g., airborne particulates, radioiodine, 

milk, food products, crops, and direct radiation). Contaminant concentrations found in native 

vegetation, crops, soils, sediment, surface water, fish, and game animals in areas surrounding 

nuclear power plants are usually quite low (i.e., at or near the threshold of detection) and are 

seldom above background levels (NRC 2013a).

3.4 Climate and Air Quality 

This section describes the local and regional climate, air quality, and sources of greenhouse gas 

emissions during continued storage. 

3.4.1 Climate 

This section describes the climate near spent fuel pools and at-reactor ISFSIs. For this 

resource area, the License Renewal GEIS (NRC 2013a) provides the baseline description of the 

affected environment at the start of continued storage. As described in the License Renewal 

GEIS, weather conditions at nuclear power plant sites vary depending on the year, season, time 

of day, and site-specific conditions, such as whether the site is located near coastal zones or in 

or near terrain with complex features (e.g., steep slopes, ravines, and valleys). These 
Affected Environment 

185(*௅ 3-12 September 2014 

conditions can be generally described by climate zones according to average temperatures. 

On the basis of temperature alone, there are three major climate zones: polar, temperate, and 

tropical. Within each of the three major climate zones, there are marine and continental 

climates. Areas near an ocean or other large body of water have a marine climate. Areas 

located within a large landmass have a continental climate. Typically, areas with a marine 

climate receive more precipitation and have a more moderate climate. A continental climate 

has less precipitation and a greater range in climate. Regional or localized refinements in 

climate descriptions and assessments can be made by considering other important climate 

variables and climate-influencing geographic variables, such as precipitation, humidity, surface 

roughness, proximity to oceans or large lakes, soil moisture, albedo (i.e., the fraction of solar 

energy [shortwave radiation] reflected from the Earth back into space), snow cover, and 

associated linkages and feedback mechanisms. Localized microclimates can be defined by 

considering factors such as urban latent and sensible heat flux and building-generated 

WXUEXOHQFH%RWKQDWLRQDODQGUHJLRQDOPD[LPXPDQGPLQLPXPDYHUDJHDQQXDOWHPSHUDWXUH

and precipitation climates ovHUWKH\HDUVIURPWKURXJKDUHVXPPDUL]HGLQ

Section D.2 in Appendix D of the License Renewal GEIS (NRC 2013a). 

The frequency and intensity of tornadoes, straight winds, and wind-borne missiles are a 

consideration in the design of both spent fuel storage pools and dry cask storage systems. 

Natural phenomena hazards, including design bases for high winds and wind-borne missiles are 

considered in the design bases of spent fuel storage facilities, as discussed in Section 4.18. 

3.4.2 Greenhouse Gases 

%DVed on assessments by the Global Climate Research Program (GCRP) and the National 

Academy of Sciences’ National Research Council, the U.S. Environmental Protection Agency 

(EPA) determined that potential changes in climate caused by greenhouse gas (GHG) 

emisVLRQVFRXOGHQGDQJHUSXEOLFKHDOWKDQGZHOIDUH)57KH(3$LQGLFDWHGWKDW

while ambient concentrations of GHGs do not cause direct adverse health effects (such as 

respiratory or toxic effects), public health risks and impacts can result indirectly from changes in 

FOLPDWH%DVHGRQWKH(3$¶VGHWHUPLQDWLRQWKH15&UHFRJQL]HVWKDW*+*VFRQWULEXWHWR

climate change, climate change can affect health and the environment, and mitigation actions 

are necessary to reduce impacts. The NRC considers carbon dioxide and other GHG 

emissions in its environmental reviews, and includes consideration of emissions from 

construction and operation of a facility (NRC 2009b). NRC guidance (NRC 2013c) also 

addresses consideration of GHGs and carbon dioxide in environmental reviews for new power 

reactors. Historically, long-term carbon dioxide levels extending back 800,000 years have 

UDQJHGEHWZHHQDQGSDUWVSHUPLOOLRQWKH*&53HVWLPDWHVWKDWSUHVHQW-day carbon 

dioxide concentrations are about 400 parts per million, higher than at any time in at least the last 

1 million years (GCRP 2014). 
Affected Environment 

September 2014 3-13 185(*௅

According to GCRP estimates, carbon dioxide 

levels at the end of the century will range 

between 420 and  parts per million 

(GCRP 2014). This corresponds to a projected 

increase in average temperature through the end 

of the century of between 2.8° to °C (° to 

10°F) for a higher GHG emissions scenario, 

which assumes no efforts to reduce GHG 

emissions (GCRP 2014). The GCRP also 

presented the projected change in precipitation 

IURPWKH3UHFHQWSDVW ́to 1999) through the 

end of the century (around 2100). Generally, the 

GCRP forecasts that future precipitation will 

increase in northern areas (especially the 

Northeast and Alaska), while southern areas, 

particularly the Southwest, will become drier 

(GCRP 2014). 

3.4.3 Criteria Pollutants 

7KH(3$KDVVHW1DWLRQDO$PELHQW$LU4XDOLW\6WDQGDUGV1$$46&)53DUWIRUVL[

criteria pollutants, including sulfur dioxide, nitrogen dioxide, carbon monoxide, ozone, particulate 

matter (PM; PM10, and PM), and lead. Primary NAAQS specify maximum ambient (outdoor 

air) concentration levels of the criteria pollutants with the aim of protecting public health with an 

adequate margin of safety.1 Secondary NAAQS specify maximum concentration levels with the 

aim of protecting public welfare.2 States can have their own State Ambient Air Quality 

Standards. State Ambient Air Quality Standards must be at least as stringent as the NAAQS, 

and they can include standards for additional pollutants. If a State has no standard 

corresponding to one of the NAAQS, then the NAAQS apply. The EPA’s Tribal Authority Rule 

(63 )5DOVRLGHQWLILHVSURYLVLRQVRI the Clean Air Act that treat eligible Federally 

recognized Tribes as States. 

The EPA generally designates a nonattainment area based upon air quality monitoring data or 

modeling studies that show the area violates or contributes to violations of the national 

 

1%DVHGRQ(PA regulations, primary (health-based) standards are requisite to protect public health with 

DQ3DGHTXDWHPDUJLQRIVDIHW\.” The margin of safety is intended to address uncertainties associated with 

inconclusive evidence, and to provide a reasonable degree of protection against hazards that research 

has not yet identified. 

2%DVHGRQ(3$UHJXODWLRQVVHFRQGDU\ZHOIDUH-EDVHGVWDQGDUGVDUHUHTXLVLWHWRSURWHFWWKH3SXEOLF

ZHOIDUH ́IURPDQ\NQRZQRUDQWLFLSDWHGDGYHUVHHIIHFWV:HOIDUHHIIHFWVLQFOXGH3HIIHFWVRQVRLOVZDWHU

crops, vegetation, man-made materials, animals, wildlife, weather, visibility and climate...” (Hassett-Sipple 

2011). 

Three EPA Air Quality Designations 

Nonattainment: Any area that does not meet 

(or that contributes to ambient air quality in a 

nearby area that does not meet) the national 

primary or secondary ambient air quality 

standard for the pollutant. 

Attainment: Any area that meets the national 

primary or secondary ambient air quality 

standard for the pollutant. 

Unclassifiable: Any area that cannot be 

classified on the basis of available information 

as meeting or not meeting the national primary 

or secondary ambient air quality standard for 

the pollutant. 
Affected Environment 

185(*௅ 3-14 September 2014 

standard. The area also is referred to as an air quality control region, which the EPA designates 

for air quality management purposes and which typically consists of one or more counties. The 

EPA designates the area as attainment/unclassifiable if the area meets the standard or expects 

to meet the standard despite a lack of monitoring data or modeling studies. After the air quality 

in a nonattainment area improves so that it no longer violates or contributes to violations of the 

standard and the State or Tribe adopts an EPA-approved plan to maintain the standard, the 

EPA can re-designate the area as attainment. These areas are known as maintenance areas. 

In the License Renewal GEIS (NRC 2013a), the NRC identified operating plants located within 

or adjacent to counties with designated nonattainment areas. The EPA periodically reviews 

ambient pollution concentrations throughout the country and reclassifies the attainment status of 

areas. Attainment designation status for areas is presented in 40 CFR Part 81. 

Each State develops an implementation plan that includes a strategy for attaining or maintaining 

the NAAQS, modeling that demonstrates attainment or maintenance, and various rules, 

regulations, and programs that provide the necessary air pollutant emissions reductions. 

On tribal lands, Federally recognized Indian tribes can develop their own tribal implementation 

plans, similar to State implementation plans. If a State or Tribe fails to submit a required plan, 

the EPA can promulgate a plan known as a Federal implementation plan. In accordance with 

Section FRIWKH&OHDQ$LU$FWDQGWKH*HQHUDO&RQIRUPLW\5HJXODWLRQV&)53DUW

and Part 93), the NRC must analyze its licensing actions to ensure that its Federal action 

conforms to any applicable implementation plan. Conformity determinations are required when 

a department, agency, or instrumentality of the Federal government engages in, supports in any 

way or provides financial assistance for, licenses or permits, or approves any activity to ensure 

that the activity conforms to an applicable implementation plan. Currently, the General 

&RQIRUPLW\5HJXODWLRQV&)53DUWDQG3DUWDSSO\WRDOO)HGHUDODFWLRQVWKDWDUHWDNHQ

in nonattainment or maintenance areas. 

The NRC will evaluate and document the need for a conformity determination for the activities 

within its authority that require an NRC license. These evaluations are completed as part of 

licensing actions involving new reactors, reactor license renewal, and any specifically licensed 

ISFSI. Most NRC licensing actions involve emissions well below de minimis levels established 

by the EPA in the General Conformity Regulations (e.g., 100 tons per year for nitrogen oxide 

emissions [a precursor to ozone] in maintenance areas). As described further in Chapter 4, 

emissions of criteria pollutants during continued storage are likely to remain below de minimis

levels at all sites, and a general conformity determination would not be required. 

3.5 Geology and Soils 

This section describes the geology and soils that have the potential to be affected by continued 

storage of spent fuel. 
Affected Environment 

September 2014 3- 185(*௅

The geologic environment of a nuclear power plant consists of the regional physiography, 

tectonic setting, and composition and physical properties of the bedrock and sedimentary strata 

underlying the site. Geologic hazards are also a condition of the geologic environment, 

including faulting and seismicity (NRC 2013a). Seismic hazards are the most ubiquitous of the 

geologic hazards, and almost all parts in the United States are subject to some potential for 

earthquake-induced vibrations. The likelihood and intensity of earthquake-induced vibratory 

ground motion at reactors depend on two factors. First, the number, frequency, and location of 

earthquakes depend on the site’s tectonic setting, tectonic activity, and nature of the seismic 

sources. Second, the physical characteristics of bedrock and soils beneath the site determine 

how earthquake energy is attenuated or amplified as it travels from the earthquake sources to 

WKHVLWH%RWKIDFWRUVDUHLQWHJUDOWRWKHGHYHORSPHQWRIWKHHDUWKTXDNHKD]DUGDVVHVVPHQWV

that form the bases for the seismic design of spent fuel pools and dry cask storage systems. 

Natural phenomena hazards in the design basis of spent fuel storage facilities, including seismic 

GHVLJQDUHDGGUHVVHGLQ6HFWLRQ3(QYLURQPHQWDO,PSDFWVRI3RVWXODWHG$FFLGHQWV ́

The general characteristics of nuclear power plants are discussed in Section 2.1.1 of this GEIS, 

in the License Renewal GEIS, and in environmental statements and environmental impact 

statements prepared for initial construction and operation of nuclear power plants. All safetyrelated structures (e.g., seismic category 1 structures) at nuclear power plants are founded 

either on competent natural or engineered strata to ensure that no safety-related facilities are 

constructed in potentially unstable materials (NRC 2013a). 

During construction of nuclear power plants, soil is disturbed for buildings, roads, parking 

lots, underground utilities (including cooling-water system intake and discharge systems), 

aboveground utility structures (including transmission lines), cooling towers, and other 

structures (NRC 2013a), including at-reactor ISFSIs, which are usually constructed during 

nuclear power plant operations. Nuclear power plant sites range in size from 34 ha (84 ac) 

DWWKH6DQ2QRIUHSODQWLQ&DOLIRUQLDWR0 ha (14,000 ac) at the Clinton plant in Illinois. 

At-UHDFWRU,6)6,VUDQJHLQVL]HIURPWRKDWRDF7KHSroportion of land that 

remains undisturbed or undeveloped by construction activities varies from site to site. 

Soils form over time in response to weathering and erosion of parent materials (underlying 

bedrock or sediments), and as soils mature, they develop distinct horizons or layers that have 

varying properties and potential uses. Across the United States, soils have a variety of 

compositions and related physical properties, depending on the local geologic conditions and 

climate. The degree of infiltration and the relative movement of groundwater or contaminants 

through the soils depend on these physical properties. 

The geologic resources in the vicinity of each nuclear plant and at-reactor ISFSI vary with the 

location and land-use activities. For example, where mining operations occur (e.g., sand and 

gravel pit operations or quarrying for crushed stone), there is little if any interaction between 

plant operations and local mining industries. However, some nuclear plants may purchase 
Affected Environment 

185(*௅ 3-16 September 2014 

materials for landscaping and site construction from local sources. Commercial mining or 

quarrying operations are not allowed within nuclear power plant boundaries (NRC 2013a). 

3.6 Surface-Water Quality and Use 

This section describes the surface-water use and quality that could be affected by the continued 

storage of spent fuel in spent fuel pools and at-reactor ISFSIs. 

%HFDXVHQXFOHDUUHDFWRURSHUDWLRQVUHO\SUHGRPLQDQWO\RQZDWHUIRUFRROLQJPRVWQXFOHDUSRZHU

plant sites are located near reliable sources of water. These sources are often surface 

waterbodies such as rivers, lakes, oceans, bays, and reservoirs and other man-made 

impoundments (NRC 2013a). The single exception is the Palo Verde Nuclear Generating 

Station in Arizona, which uses treated municipal wastewater for cooling water. Of the sites in 

the United States that contain NRC-licensed nuclear power plants, 32 are located near rivers, 

QHDUODNHVDQGUHVHUYRLUVQHDURFHDQVDQGQHDUHVWXDULHVDQGED\V7KHVH

waterbodies form part of the affected environment for storage of spent fuel in spent fuel pools 

and at-reactor ISFSIs. Local drainage features at and near nuclear power plant sites, such as 

creeks and small streams, provide avenues for surface-water movement and interaction with 

surface waterbodies. Depending on regional precipitation regimes, local topography, and 

drainage patterns, operation of spent fuel pools and at-reactor ISFSIs may affect the availability 

and quality of these nearby surface-water resources. 

Provisions of the Clean Water Act regulate the discharge of pollutants into waters of the 

United States. Discharges of cooling water and other plant wastewaters are monitored through 

the National Pollutant Discharge Elimination System (NPDES) program administered by the 

EPA, or, where delegated, individual States. An NPDES permit is developed with two levels of 

controls: (1) technology-based limits and (2) water quality-based limits. The technology-based 

limits applicable to nuclear power-generating plants are in 40 CFR Part 423. NPDES permit 

WHUPVPD\QRWH[FHHG years (unless administratively continued), and the applicant must 

reapply at least 180 days prior to the permit expiration date. The NPDES permit contains 

requirements that limit the flow rates and pollutant concentrations that may be discharged at 

SHUPLWWHGRXWIDOOV%LRFLGHVDQGRWKHUFRQWDPLQDQWVLQGLVFKDUJHGFRROLQJZDWHUVDUHJRYHUQHG

by NPDES permit restrictions to reduce the potential for toxic effects on nontargeted organisms 

(e.g., native mussels and fish). NPDES permits impose temperature limits for effluents (which 

may vary by season) and/or a maximum temperature increase above the ambient water 

WHPSHUDWXUHUHIHUUHGWRDV3GHOWD-T,” which also may vary by season). Other aspects of the 

permit may include the compliance measuring location and restrictions against plant shutdowns 

during winter to avoid drastic temperature changes in surface waterbodies. The permit also 

may include biological monitoring parameters that are primarily associated with the discharge of 

cooling water. The intake of cooling water from waters of the United States is regulated under 

Clean Water Act Section 316(b), and the thermal component of any effluent discharges from 
Affected Environment 

September 2014 3- 185(*௅

power-generating plants may be regulated by either the applicable State water quality standard 

or by Clean Water Act Section 316(a). 

Wastewater discharge is also covered through NPDES permitting, and it includes biochemical 

monitoring parameters. Conditions of discharge for each plant are specified in its NPDES permit 

issued by the State or EPA. Most plants have a stormwater management plan, with the 

parameter limits of the stormwater outfalls included in the NPDES permit. Plants also may have 

a spill prevention, control, and countermeasures plan that provides information on potential 

liquid spill hazards and the appropriate absorbent materials to use if a spill occurs. 

In an effort to minimize or eliminate impacts to the water quality of receiving waterbodies, best 

management practices are typicaOO\LQFOXGHGDVFRQGLWLRQVZLWKLQ13'(6SHUPLWV%HVW

management practices are measures used to control the adverse stormwater-related effects of 

land disturbance and development. They include structural devices designed to remove 

pollutants, reduce runoIIUDWHVDQGYROXPHVDQGSURWHFWDTXDWLFKDELWDWV%HVWPDQDJHPHQW

practices also include nonstructural or administrative approaches, such as training to educate 

staff on the proper handling and disposal of potential pollutants. 

After cessation of reactor operations at the nuclear power plant sites, water use would be 

reduced to spent fuel pool cooling, radiation protection for workers, maintenance, human 

consumption, and personal hygiene. 

3.7 Groundwater Quality and Use 

This section describes the groundwater use and quality that could be affected by the continued 

storage of spent fuel in spent fuel pools and at-reactor ISFSIs. 

Groundwater, which has been used as a water supply source throughout recorded history, is 

found in the voids of unconsolidated geologic materials (e.g., sand and gravel), in fractures of 

consolidated rocks (e.g., sedimentary, metamorphic, igneous, and volcanic rocks), and in 

conduits/channels of carbonates (e.g., limestone and dolomites). Where groundwater can be 

found in the subsurface depends on the geologic history of an area. The quantity and quality of 

groundwater for domestic uses depends on site-specific conditions. Anthropogenic impacts 

may affect groundwater quality, but those impacts also are site-VSHFLILF%RWKXQFRQILQHGDnd 

confined aquifers that can provide a potential water supply source for domestic use may exist 

beneath a nuclear power plant site. The type of aquifers and their properties at nuclear power 

plant sites are site-specific and can vary considerably. 

In the eastern United States, most nuclear power plant sites are located in two large regional 

groundwater provinces: (1) the first is composed of the Atlantic and Eastern Gulf coastal plain, 

the Southeastern coastal plain, and the Gulf of Mexico coastal plain; and (2) the second is 

FRPSRVHGRIWKH&HQWUDO*ODFLDWHGDQGWKH&HQWUDO1RQJODFLDWHGSODLQV%DFNHWDO7KH
Affected Environment 

185(*௅ 3-18 September 2014 

ILUVWJURXQGZDWHUSURYLQFHZKLFKH[WHQGVIURP1HZ-HUVH\VRXWKWR)ORULGDDQGZHVWDORQJWKH

Gulf of Mexico, includes aquifers that have moderate to very high transmissivity values, 

moderate to high recharge rates, and moderate- to high-yield wells. In contrast, the second 

groundwater province, which includes the Great Lakes and upper Midwest, includes aquifers 

that have moderate to high transmissivity values, lower recharge rates, and low- to moderateyield wells. 

,QDGGLWLRQVHYHUDOQXFOHDUSRZHUSODQWVLWHVDUHORFDWHGLQWKH3LHGPRQWDQG%OXH5LGJHDQG

WKH$SSDODFKLDQ3ODWHDXDQG9DOOH\DQG5LGJHJURXQGZDWHUUHJLRQV%DFNHWDO

$TXLIHUVLQWKH3LHGPRQWDQG%OXH5LGJHUHJLRQKDYHORZWUDQVPLVVLYLW\YDOXHVDQGZKLOH

UHFKDUJHUDWHVDUHPRGHUDWHWRKLJKW\SLFDOZHOOVKDYHYHU\ORZ\LHOGV%\FRQWUDVWDTXLIHUVLQ

the Appalachian Plateau and Valley and Ridge have moderate to high transmissivity values, 

moderate to high recharge rates, and low to moderate-yield wells. 

Two of the four nuclear power plant sites located in the western United States use cooling water 

from the Pacific Ocean. These two nuclear power plants are located in the Pacific Coast Range 

region of California. The geologic complexity of this region creates diverse hydrogeologic 

conditions. Another power plant in the west uses cooling water from the Columbia River, which 

dissects the prolific bedded basalt aquifer system of the Columbia Lava Plateau, while the 

IRXUWKORFDWHGLQWKH&HQWUDO$OOXYLDO%DVLQVRIWKHDULGGHVHUWVRXWKZHVWXVHVWUHDWHGPXQLFLSDO

ZDVWHZDWHUIRUFRROLQJ%DFNHWDO

Many of the nuclear power reactor sites in the United States that are adjacent to lakes, rivers, 

reservoirs, and engineered cooling ponds are constructed on unconsolidated stream, glacial, 

and lake deposits that host shallow, unconfined to semi-FRQILQHGDTXLIHUV%DFNHWDO

Where unconsolidated permeable deposits are thin or not inter-bedded with lower permeability 

sediments, local groundwater flow systems may be hydraulically connected to deeper, regional 

to sub-regional groundwater flow systems in underlying permeable unconsolidated deposits, 

coarse-grained sandstone, carbonate units with solution features, and folded or fractured 

crystalline rocks. Where shallow aquifers are immediately underlain by thick, impermeable 

shale or massive, unjointed carbonate strata, there is likely little or no hydraulic connection with 

deeper, regional groundwater flow systems. 

Contaminants may enter an aquifer system and be transported with the hydraulic gradient. The 

direction and rate of contaminant transport will depend on the site-specific properties of the 

aquifer. For relatively permeable aquifers with a substantial hydraulic gradient, contaminants 

would be transported down-gradient quickly. For relatively permeable aquifers with a low 

hydraulic gradient, contaminants would move very slowly down-gradient. Typically, a 

contaminant plume would be elongated in the direction of the hydraulic gradient because 

transverse mixing (transverse dispersion) is much less than in the groundwater flow direction 

(longitudinal dispersion) (Todd 1960). For relatively low permeable aquifers, contaminants 

would move very slowly. 
Affected Environment 

September 2014 3-19 185(*௅

As noted in the License Renewal GEIS (NRC 2013a), leaks and spills during the licensed life for 

operation at reactors have resulted in groundwater and soil contamination. Industrial practices 

involving the use of solvents, heavy metals, or other chemicals and unlined wastewater lagoons 

have the potential to contaminate site groundwater, soil, and subsoil. Contamination is subject 

to State- and EPA-regulated cleanup and monitoring programs (NRC 2013a). In addition, 

radionuclides, particularly tritium, have been released to groundwater at many plants. 

Underground system leaks of process water also have been discovered in recent years at 

several plants. A description of spent fuel pool leaks at NRC-licensed facilities is included in 

Appendix E. 

%HFDXVHWULWLXPWUDYHOVWKURXJKJURXQGZDWHUIDVWHUWKDQPRVWRWKHUUDGLRQXFOLGHVWULWLXPLV

generally the first radionuclide to be identified in groundwater after a radioactive spill or leak. 

Records as of December 2013 indicate that, at some time during their operating history, 

4 nuclear power plant sites have had leaks or spills involving tritium concentrations in excess 

of the 20,000 pCi/L drinking water standard established in the Safe Drinking Water Act. Also as 

of December 2013,  sites are reporting tritium concentrations from a leak or spill in excess of 

20,000 pCi/L onsite. However, no site is currently reporting tritium in excess of 20,000 pCi/L 

offsite, or in drinking water (NRC 2013d). 

2Q-XQHWKH15&LVVXHGWKH'HFRPPLVVLRQLQJ3ODQQLQJ5XOH)57KLV

UXOHWKURXJKFKDQJHVWRWKHUHJXODWLRQVDW&)5DQGUHTXLUHVOLFHQVHHVWR

3«PLQLPL]HWKHLQWURGXFWLRQRIVLJQLILFDQWUHVLGXDOUDGLRDFWLYLW\LQWRWKHVLWHLQFOXGLQJWKH

subsurface, and to perform radiological surveys to identify the extent of significant residual 

radioactivity at their sites, including the subsurface” (NRC 2012b). As a result, all currently 

operating NRC-licensed nuclear power plants and any nuclear power plant that may be built in 

the future are required to perform groundwater monitoring to determine the extent of any 

existing contamination and to aid in the timely detection of any future contamination. Timely 

detection of leakage will allow licensees to identify and repair leaks and employ mitigation 

measures, as necessary, to minimize or eliminate any environmental impacts that would result 

from leaks. 

Licensees that have implemented a groundwater monitoring program consistent with the 

Nuclear Energy Institute Groundwater Protection Initiative are considered to have an adequate 

program for the purposes of the Decommissioning Planning Rule (NRC 2011). Additional 

discussion pertaining to groundwater monitoring can be found in Appendix E of this GEIS. 

3.8 Terrestrial Resources 

This section describes the general terrestrial resources that could be affected by continued 

storage of spent fuel in spent fuel pools and at-reactor ISFSIs. Terrestrial plant and animal 
Affected Environment 

185(*௅ 3-20 September 2014 

communities found on land may be subject to potential effects associated with spent fuel 

storage facilities (wet storage in spent fuel pools or dry storage in casks). 

Nuclear power plants (which include spent fuel pools) and associated ISFSIs (which are located 

on nuclear power plant sites) are sited in a wide variety of terrestrial habitat types from coastal 

to intermountain landscapes. Terrestrial habitats vary widely depending on their ecoregion or 

geographic location, especially in relation to the climate, landforms, and soil characteristics. 

Surrounding land uses and land forms (e.g., deserts and mountains) significantly influence the 

local and regional biodiversity and ecosystem. For example, an arid desert location is likely to 

have less biodiversity than a temperate rainforest. In addition, impacts at the local level in the 

immediate vicinity of nuclear power plants and associated at-reactor ISFSIs that have relatively 

intact, functioning ecosystems because of the lack of extensive development and disturbance 

would provide higher quality habitat and biodiversity as opposed to heavily industrialized areas 

where larger areas of habitat loss and disturbances decreases habitat quality and biodiversity. 

For the purposes of this analysis, terrestrial ecological resources are described in terms of 

upland vegetation and habitats, lowland and wetland vegetation and habitats, and wildlife. 

3.8.1 Upland Vegetation and Habitats 

In general, upland terrestrial vegetation and habitats include habitats such as forests, 

grasslands, and shrublands as opposed to lowland areas. These habitats experience changes, 

called succession, within the vegetation communities in response to land-disturbing activities. 

The level of anthropogenic disturbance varies by land-use management activities (see 

Section 3.1). Typically, areas within the security fence at a nuclear power plant and associated 

ISFSI have been modified by construction and maintenance activities and are maintained as 

modified landscapes for operational and security purposes. Some of these areas could contain 

relatively undisturbed habitat. Disturbed habitats are characterized mainly by grasses, forbs, 

and shrubs that represent the early successional stage. A maintenance activity, such as 

mowing and herbicide or pesticide applications, limits the diversity and maturity of plant species 

that are present. After construction of nuclear power plants and during maintenance activities, 

non-native plant species and weeds often replace the naturally occurring vegetation, while 

natural forest or shrubland in various degrees of disturbance may be present outside the 

security fence (NRC 2013a). The affected habitats for at-reactor continued storage would be 

similar to habitats described in the License Renewal GEIS because spent fuel pools and atreactor ISFSIs are located at the nuclear power reactor sites described in the License Renewal 

GEIS. 

Several operational activities at nuclear power plants may have effects on upland vegetative 

communities and habitats. As described in License Renewal GEIS (NRC 2013a), terrestrial 

habitats near nuclear power plants can be subject to small amounts of radionuclides. 

Radionuclides, such as tritium, and other constituents in cooling-water systems, such as 
Affected Environment 

September 2014 3-21 185(*௅

biocides, that enter shallow groundwater can also be taken up by terrestrial plant species. 

Maintenance activities along nuclear power plant transmission line corridors (cutting vegetation 

and using herbicides) within the property boundary of a nuclear power plant can contribute to 

habitat fragmentation and affect the distribution of plant and animal species in areas near the 

corridors. Nuclear power plants’ cooling towers may deposit water (and salt) droplets on 

vegetation and increase humidity in the area relatively close to the cooling towers during the 

period that the spent fuel pool is operated. In addition, heat dissipated during power plant 

operations by a combination of radiation, conduction, and convection can expose terrestrial 

habitats to elevated temperatures (NRC 2013a). 

3.8.2 Lowland and Wetland Vegetation and Habitats 

Lowlands along rivers, streams, and coastlines may include floodplains, riparian zones, and 

several types of wetlands (riverine, palustrine, lacustrine, estuarine, and marine) that support 

ILVKDQGZLOGOLIH$VRIZHWODQGVFRYHUHGDQDYHUDJHRISHUcent of the land area near 

nuclear power plants and at-reactor ISFSIs, as mapped by the National Wetland Inventory 

):6:HWODQGVH[FOXGHSHUPDQHQWO\IORRGHGDUHDVWKDWRFFXS\RQDYHUDJHDERXW

10 SHUFHQWRIWKHDUHDZLWKLQNPPLRIQXFOHDUSower plants (NRC 2013a). Wetland 

vegetation is hydrophytic (i.e., able to withstand waterlogged conditions) whether anchored on 

relatively dry land or in standing water. Depending on the wetland type, vegetation can vary 

widely from flowering plants, grasses, shrubs (reeds, sedges, and rushes), ferns, and trees. 

During the initial nuclear power plant license periods, wetlands and riparian communities near 

nuclear power plants were affected by construction and operation activities (e.g., maintaining 

power line corridors, dredging wetland sediments, and sediment disposal) that caused 

stormwater runoff, changes in vegetative plant community characteristics, altered hydrology, 

decreased water quality and quantity, and sedimentation. Some wetlands and riparian 

communities have been affected by nuclear power plant cooling systems that can increase the 

salinity of stream segments, increase water temperatures, and introduce contaminants to 

wetlands that receive groundwater discharge. However, wetlands have also been created at 

some power plants that use cooling ponds (NRC 2013a). 

3.8.3 Wildlife 

Terrestrial animals (i.e., land mammals, insects, birds, amphibians, and reptiles) in the vicinity of 

a nuclear power plant and associated ISFSI are typical of species found in a particular ecoregion 

and vary widely across the United States. The removal of vegetation during plant construction 

and operations have affected the habitat quality and, at some sites, reduced the available habitat 

by hundreds of acres. Wildlife biodiversity and ecological function in disturbed areas of nuclear 

power plant sites, including at-reactor ISFSIs, are different from those in undisturbed areas, in 

part because the wildlife communities supported by disturbed areas are different from those that 

undisturbed areas support (NRC 2013a). Disruptive human activities (e.g., noise, ground 
Affected Environment 

185(*௅ 3-22 September 2014 

vibrations, mechanical equipment, vehicles, and physical obstructions) also repel animals that 

are less tolerant to such disturbances. At the beginning of continued storage, these disturbed 

and undisturbed areas will be identical to the areas that existed during operations. 

Maintenance activities along nuclear power plant transmission line corridors within the property 

boundary of the plant, which will continue during continued storage, affect the distribution of 

plant and animal species in areas near the corridors and expose wildlife to nonionizing radiation 

exposure from transmission line electromagnetic fields (NRC 2013a). 

Wildlife species that rely on and use the water resources at the reactor site will continue to be 

affected by continued storage. For example, the ongoing use of the spent fuel pool cooling 

system could introduce hazards to some wildlife and could create water-use conflicts with 

wildlife in the area. Wildlife species that occupy onsite habitats are exposed to a variety of 

contaminants and factors associated with nuclear power plant and at-reactor ISFSI operations 

and maintenance. The maintenance required for landscaped areas generally keeps the 

diversity of wildlife at a reduced level compared to unmaintained surrounding habitats. Wildlife 

species within the security areas are typically limited by the low quality of the habitat present 

and generally include common species adapted to industrial developments (NRC 2013a). 

3.9 Aquatic Ecology 

This section describes the general aquatic resources that could be affected by the continued 

storage of spent fuel in spent fuel pools and at-reactor ISFSIs. Aquatic biota may be subject to 

potential effects associated with spent fuel storage facilities (wet storage in spent fuel pools or 

dry storage in casks). 

The information contained in the following sections is a brief summary of aquatic resources 

known to exist near nuclear power plant sites, which include spent fuel pools and ISFSIs. 

The majority of this information comes from the License Renewal GEIS (NRC 2013a), which 

describes a range of potentially affected aquatic resources that may be found in the vicinity of 

nuclear power plants. The affected environment for at-reactor continued storage would be 

similar to the affected environment described in the License Renewal GEIS because spent fuel 

pools and at-reactor ISFSIs are located within power reactor sites, and the end of reactor 

operations would not significantly alter the affected environment for aquatic resources at most 

sites. However, when operation of a reactor cooling system ceases, the aquatic environment 

would be altered to some degree because less water would be withdrawn and discharged. 

Therefore, less impingement and entrainment would occur and the thermal plume associated 

with the discharge would be smaller. Once operation of the spent fuel pool ceases, no water 

would be withdrawn or discharged as a part of continued storage activities. A more detailed 

account of the range of aquatic environments existing at these facilities can be found in the 

License Renewal GEIS. 
Affected Environment 

September 2014 3-23 185(*௅

Nuclear power plant sites must be located near waterbodies that are large enough to 

adequately meet the demands of a plant’s cooling systems. At-reactor ISFSIs are generally 

located near nuclear power plants, and nuclear power plant sites are usually located near 

marine and estuarine coastal areas, on the Great Lakes, or along major rivers or reservoirs. 

Several power plants are sited near small streams (e.g., the V.C. Summer plant in South 

Carolina and the Clinton plant in Illinois), and initial construction activities included impounding 

the streams to create cooling ponds or reservoirs. 

To establish the affected environment for this analysis, aquatic resources are described in terms 

of aquatic habitats (freshwater rivers, reservoirs, lakes, and coastal estuarine and marine 

systems) and aquatic biota (fish, macroinvertebrates, zooplankton, phytoplankton and 

macrophytes, other aquatic vertebrates and invertebrates, and aquatic vegetation). 

3.9.1 Aquatic Habitats 

A wide range of aquatic habitats occur in the vicinity of U.S. nuclear power plant sites due to 

differences in geographies, physical conditions (e.g., substrate type, temperature, turbidity, and 

light penetration), chemical conditions (e.g., dissolved oxygen levels and nutrient 

concentrations), biological interactions (e.g., consumption of various algal and invertebrate 

species that provide habitats, such as seagrass or shellfish beds), seasonal influences 

(including climate change), and man-made modifications. The interactions of these factors 

often define the specific type of aquatic habitats and communities within a particular area. 

Three main aquatic ecosystem types occur near nuclear power plant sites: freshwater, 

estuarine, and marine ecosystems. 

3.9.1.1 Freshwater Systems 

Freshwater systems are generally classified into two groups based on the degree of water 

movement. Lentic systems are waterbodies with standing or slow-flowing water, such as ponds, 

lakes, reservoirs, and some canals. During warmer months, the upper and lower depths will 

stratify or become two layers that have different temperatures, oxygen content, and nutrient 

content. Lotic habitats, on the other hand, feature moving water and include natural rivers and 

streams and some artificial waterways. Most lotic habitats do not stratify (Morrow and 

Fischenich 2000). Some freshwater aquatic species may occur in both lentic and lotic habitats. 

However, many species are adapted to the physical, chemical, and ecological characteristics of 

one system or the other and the overall ecological communities present within these aquatic 

ecosystem types differ for different regions of the country (NRC 2013a). 

A number of major rivers provide cooling water for nuclear power plant sites. The geographic 

area, gradient of the river bed, substrate, temperature, dissolved oxygen concentration, depth, 

light penetration, velocity of the current, and source of nutrients and organic matter at the base 

of the food chain will largely determine species composition and ecological conditions within 
Affected Environment 

185(*௅ 3-24 September 2014 

riverine environments. In some instances, nuclear 

power plants that use rivers for cooling are located 

on sections of rivers that have been impounded, 

creating reservoirs. Impoundment of a river can alter 

ecological communities occurring in a given 

waterbody by blocking movement of aquatic 

organisms, changing flow and temperature 

characteristics, adding chemical pollutants, and 

introducing non-native species. Fish species in 

numerous reservoirs are often stocked and managed 

to support local recreational fisheries (NRC 2013a). 

Littoral, pelagic, and profundal habitat zones are all 

found within lentic systems and are classified on the 

basis of water depth and light penetration in the 

water. Littoral habitats refer to nearshore shallower 

waters where sufficient light reaches the bottom to 

enable rooted plants to grow. Pelagic habitats 

include open offshore waters where light intensity is 

great enough for photosynthesis to occur. Profundal 

habitats are found in deep-water areas where light 

penetration is insufficient to support photosynthesis 

(Armantrout 1998). Unique ecological communities 

inhabit each zone, reflecting the preferences and 

tolerances of various aquatic species (NRC 2013a). 

In the Great Lakes, species diversity and biomass of 

fish are greater nearshore than in the offshore areas since these areas feature habitats and 

conditions that are favorable for most species of Great Lakes fish for at least some portion of 

WKHLUOLIHF\FOH(GVDOODQG&KDUOWRQ7KUHDWVWRWKHHFRORJLFDOLQWHJULW\RIWKH*UHDW/DNHV

include eutrophication (nutrient enrichment), land-use changes, overfishing, invasive species, 

DQGSROOXWLRQ%HHWRQ5HJXODWLRQVand best management practices have been 

implemented to reduce nutrient inputs and control land-use changes, such as shoreline 

alteration and destruction of wetlands. Invasive species, however, have become a major 

problem as nonindigenous species gain access to the Great Lakes. The introduction of invasive 

species can result in changes to native ecological communities (NRC 2013a). 

3.9.1.2 Estuarine Ecosystems 

%UDFNLVKWRVDOWZDWHUHVWXDULQHHFRV\VWHPVRFFXUDORQJWKHFRDVWOLQHVRIWKH8QLWHG6WDWHV

General habitat types found within estuarine ecosystems include the mouths of rivers, tidal 

streams, shorelines, salt marshes, mangroves, seagrass communities, soft-sediment habitats 

Aquatic Ecosystem Types 

x Freshwater: Waters that contain a salt 

concentration or salinity of less than 

 parts per thousand (ppt) or 

 percent. 

– Lentic: Stagnant or slow-flowing 

fresh water (e.g., lakes and ponds). 

– Lotic: Flowing fresh water with a 

measurable velocity (e.g., rivers 

and streams). 

x Estuarine: Coastal bodies of water, 

where freshwater merges with marine 

waters. The waterbodies are often 

semi-enclosed and have a free 

connection with marine ecosystems 

(e.g., bays, inlets, lagoons, and oceanflooded river valleys). Salinity 

concentrations fluctuate between 0 and 

30 ppt, varying spatially and temporally 

due to location and tidal activity. 

x Marine: Waters that contain a salt 

concentration of about 30 ppt (e.g., 

ocean overlying the continental shelf 

and associated shores). 
Affected Environment 

September 2014 3- 185(*௅

(e.g., mudflats and shellfish beds), and open water. Estuaries can serve as important staging 

points during the migration of certain fish species, providing a refuge from predation while 

physiologically adjusting to the changes in salinity. Numerous marine fish and invertebrate 

species spawn in or use estuaries as places for larvae and juveniles to develop before moving 

to marine habitats. Estuarine habitats also support important commercial or recreational finfish 

and shellfish species (NRC 2013a). 

3.9.1.3 Marine Ecosystems 

Marine ecosystems occur along the coastline and offshore of the United States. General habitat 

types within marine ecosystems include the rocky intertidal, rocky subtidal, deep-sea 

communities, algal communities (e.g., kelp beds), soft-sediment communities (e.g., sandy 

bottom or mudflats), and the open water or pelagic habitats. Species often compete for space 

within rocky subtidal and intertidal habitats. The area where species eventually settle is often a 

tradeoff between accommodating physiological stress and avoiding predation and/or 

competition with other species. For example, lower depths may provide a more ideal habitat in 

terms of physical requirements (e.g., temperature, pressure, salinity, and avoiding desiccation), 

but shallower areas may provide a refuge from predation. As a result, many organisms 

(including algae, invertebrates, and some fish) that use rocky subtidal and intertidal habitats are 

restricted to a depth zone that balancHVSK\VLRORJLFDODQGELRORJLFDOSUHVVXUHV:LWPDQ

Marine habitats support important commercial or recreational finfish and shellfish species 

(NRC 2013a). 

3.9.2 Aquatic Organisms 

Aquatic organisms are known to occur near nuclear power plant sites. The following 

discussions provide high-level overviews of aquatic organisms that are known to exist in 

habitats near nuclear power plant sites. Additional details regarding aquatic organisms and 

species that occur near nuclear power plant sites are provided in the License Renewal GEIS 

(NRC 2013a). 

3.9.2.1 Fish 

Fish can be characterized as freshwater, estuarine, marine, and migratory (e.g., anadromous 

and catadromous) species. The first three categories are based on salinity regimes. For 

example, freshwater fish usuall\LQKDELWZDWHUVZLWKDVDOLQLW\RIOHVVWKDQSDUWVSHU

thousand (ppt), although some species can tolerate a salinity as high as 10 ppt; estuarine fish 

inhabit tidal waters with salinities that range between 0 and 30 ppt; and marine fish typically live 

and reproduce in coastal and oceanic waters with salinities that are at or more than 30 ppt. 
Affected Environment 

185(*௅ 3-26 September 2014 

Migratory fish are generally categorized by their migratory patterns, or periodic movements that 

result in regularly alternating between two or more habitats (NorWKFRWH)RUH[DPSOH

anadromous species migrate from the ocean waters to freshwater to spawn, while the opposite 

situation occurs for catadromous species. Amphidromous species also migrate between fresh 

and saltwater, but these migrations are not related to the reproductive cycle. Potamodromous 

species migrate entirely within a freshwater system (e.g., some species tend to move to 

upstream areas for spawning) whereas oceanodromous species migrate entirely within the 

ocean (e.g., some species tend to move northward as waters warm and southward as they 

cool). A number of fish species that occur in the vicinity of the power plants are considered 

commercially or recreationally important, while others serve as forage for those species 

(NRC 2013a). 

Fish are also categorized by where in the waterbody they inhabit. For example, pelagic fish live 

within the waters that extend from right below the surface to right about the sea floor (or bottom 

of the waterbody). Demersal fish live on or near the bottom of the sea floor (or bottom of the 

waterbody) and benthic fish live on the sea floor (or bottom of the waterbody). The distribution 

of demersal and benthic fish is usually highly dependent on the type of substrate that lines the 

floor of the waterbody. For example, certain fish prefer soft, sandy bottom habitat, whereas 

other fish prefer rocky substrates with crevices in which to hide. Other typical bottom water 

substrates that provide fish habitat include mud flats, kelp beds, submerged aquatic vegetation, 

salt marshes, mangroves, shellfish beds, and coral reefs. 

3.9.2.2 Aquatic Macroinvertebrates 

A broad range of aquatic macroinvertebrates may be found near nuclear power plant sites. 

Macroinvertebrates are responsible for controlling key ecosystem processes, including primary 

production, decomposition, nutrient regeneration, water chemistry, and water clarity. Mussels 

consume plankton (i.e., planktivores) and are prey for other organisms. Some 

macroinvertebrates require good water quality and physical habitat conditions that will support 

populations of their host fish species. Williams et al. (1993) reported that, of the nearly 

300 native freshwater mussels in the United 6WDWHVDQG&DQDGDQHDUO\SHUFHQWDUH

FRQVLGHUHGHQGDQJHUHGWKUHDWHQHGRURIVSHFLDOFRQFHUQDOPRVWSHUFHQWDUHRI

undetermined status, and less than 24 percent are considered stable. Freshwater mussels 

occur in the vicinity of most plants that use freshwater as a cooling-water source. Several 

species of non-native freshwater and saltwater mussels and clams have been introduced to the 

United States and have reached nuisance levels. These species can alter trophic and nutrient 

dynamics of aquatic ecosystems and displace native mussels. Many of the nuclear plants have 

programs in place to monitor for these nuisance species and, as appropriate, to control them, 

usually using biocides (NRC 2013a). 
Affected Environment 

September 2014 3- 185(*௅

3.9.2.3 Zooplankton 

Zooplankton are small animals that float, drift, or weakly swim in the water column of any 

waterbody, and include, among other forms, fish eggs and larvae with limited swimming ability, 

larvae of benthic invertebrates, medusoid forms of hydrozoans, copepods, shrimp, and krill 

(Euphausiids). Plankton are often categorized by how and where they inhabit the water column, 

including holoplankton (plankton that spend their entire lifecycle within the water column), 

meroplankton (plankton that spend a portion of their lifecycle in the water column), and 

demersal (benthic species that primarily reside on the seafloor but migrate into the water 

column on a regular basis). Zooplankton play an important role as a trophic link between 

phytoplankton and fish or other secondary consumers (NRC 2013a).

3.9.2.4 Single-Celled Algae 

Phytoplankton, also referred to as microalgae, contain chlorophyll and require sunlight to live 

and grow. Most phytoplankton are buoyant and float in the upper part of the waterbodies, 

where sunlight penetrates the water. Phytoplankton are an important food source for some 

invertebrate and fish species and are important for carbon fixation (converting carbon dioxide to 

organic materials via photosynthesis). Periphyton (algae attached to solid submerged objects) 

includes species of diatoms and other algae that grow on natural or artificial substrates. 

3.9.2.5 Other Aquatic Invertebrates and Vertebrates 

Other important aquatic species include cephalopods (e.g., squid and octopus), freshwater 

mammals, marine mammals (e.g., seals and whales), sea turtles and other reptiles. Many of 

these species are protected under various Federal statutes and regulations, such as the 

Endangered Species Act and the Marine Mammal Protection Act, as further described in 

Section 3.10. 

3.9.2.6 Aquatic Macrophytes 

Submerged aquatic vegetation, such as seagrass, provides important habitat for aquatic 

organisms and is often referred to as underwater meadows or forests. Submerged aquatic 

vegetation provides food, structurally complex habitat, areas to hide from predators, and 

breeding and nursery grounds for many aquatic species. 

Macroalgae, such as kelp and Sargassum, form communities and provide habitat, refugia, and 

food for other species such as fish and sea turtle hatchlings. Phytoplankton and macroalgae 

are also important for carbon fixation (converting carbon dioxide to organic materials via 

photosynthesis). 
Affected Environment 

185(*௅ 3-28 September 2014 

3.10 Special Status Species and Habitats 

Several Federal and State statutes and regulations protect aquatic and terrestrial species and 

habitats. Federally listed species, critical habitat, essential fish habitat (EFH), and other special 

status species and habitats are known to occur near nuclear power plant sites (NRC 2013a). 

The License Renewal GEIS provides additional details on the types of special status species 

that have occurred near nuclear power plants, such as sea turtles, fish, birds, and other 

protected species. 

Federally listed threatened and endangered species 

and critical habitat are protected under the 

(QGDQJHUHG6SHFLHV$FWRI (ESA), while Statelisted species and habitats are protected under 

provisions of various State statutes and regulations. 

Under 6HFWLRQRIthe ESA, the NRC must consult 

with the U.S. Fish and Wildlife Service (FWS) or the 

National Marine Fisheries Service (NMFS) for actions 

that could affect Federally listed species or critical 

habitat. Prior to initial licensing, the NRC would be 

required to consult with the FWS or the NMFS under 

6HFWLRQRIWKH(6$WRGHWHUPLQHWKHSUHVHQFHRI

and potential impacts to any Federally listed species 

or critical habitat at or near the site. 6HFWLRQ(6$

consultation could also be required after a license is 

granted if operations could affect a Federally listed 

species or designated critical habitat and if the criteria 

LQ&)5Part 402 are met for initiation or reinitiation 

RI6HFWLRQFRQVXOWDWLRQ, as described in more detail 

in Section 4.11. The objective of the consultation is 

to identify and assess potential impacts to listed 

species and critical habitat. Any ongoing or proposed 

activity associated with the operation or maintenance 

of spent fuel pools or ISFSIs that has the potential to 

affect a Federally listed species, and meets the 

FULWHULDLQ CFR Part 402 for initiation or reinitiation 

RI6HFWLRQFRQVXOWDWLRQ requires that the NRC 

initiate or reinitiate (6$6HFWLRQconsultation with 

the FWS or the NMFS depending on the species. 

Additional information on how the consultation 

process is used to identify, evaluate, and mitigate 

potential impacts to Federally listed species and 

designated critical habitat is discussed in Chapter 4. 

Terms Related to Threatened, 

Endangered, and Protected Species 

and Habitats 

x Endangered Species: Animal or plant 

species in danger of extinction 

throughout all or a significant portion of 

its range. 

x Threatened Species: Animal or plant 

species likely to become endangered 

within the foreseeable future throughout 

all or a significant portion of its range. 

x Candidate Species: Animal or plant 

species for which the FWS or NMFS 

has on file sufficient information on 

vulnerability and threats to support a 

proposal to list it as endangered or 

threatened. 

x Proposed Species: Animal or plant 

species that is proposed in the Federal

Register to be listed under Section 4 of 

the Endangered Species Act. 

x Designated Critical Habitat: Specific 

geographic areas, whether occupied by 

a listed species or not, that are 

essential for its conservation and that 

have been formally designated by rule 

published in the Federal Register. 

x Essential Fish Habitat: Those waters 

and substrates needed by Federally 

managed marine and anadromous fish 

for spawning, breeding, feeding, or 

growth to maturity.
Affected Environment 

September 2014 3-29 185(*௅

The Magnuson-Stevens Fishery Conservation and Management Act, as amended, calls for the 

description, identification, and management of EFH to help conserve and manage Federally 

managed fish and shellfish resources. EFH is defined as 3those waters and substrate 

necessary to fish for spawning, breeding, feeding, or growth to maturity.” The NRC must 

consult with NMFS for any Federal action that may adversely affect EFH. Spent fuel pools that 

withdraw and discharge water to marine, estuarine, and coastal waters near designated EFH 

have the potential to affect EFH because they have a potential to alter, damage, or destroy EFH 

components, thereby affecting the fishery resources that use them (NRC 2013a). 

0DULQHPDPPDOVDUHSURWHFWHGXQGHUWKH0DULQH0DPPDO3URWHFWLRQ$FWRIDVDPHQGHG

(MMPA), which also assigns responsibility for managing cetaceans (i.e., porpoises and whales) 

and most pinnipeds (i.e., seals, fur seals, and sea lions) to the NMFS. The FWS is responsible 

for managing walruses, polar bears, fissipeds (i.e., otters), and sirenians (i.e., dugongs and 

manatees)7KH$FWSURKLELWVZLWKFHUWDLQH[FHSWLRQVWKH3WDNH ́L.e., harming) of marine 

mammals in U.S. waters. The MMPA has no Federal consultation requirement; therefore, 

applicants and licensees are directly responsible for compliance with the MMPA. %RWKWKH

Magnuson–Stevens Act and MMPA are administered by the NMFS. 

7KH%DOGDQG*ROGHQ(DJOH3URWHFWLRQ$FWRIDVDPHQGHGSURYLGHVIRUWKHSURWHFWLRQRI

the bald eagle (Haliaeetus leucocephalus) and the golden eagle (Aquila chrysaetos) by 

prohibiting the taking, possession, and commerce of these birds, their nests, or their eggs. 

The Act prescribes criminal and civil penalties for persons violating the conventions identified in 

16 86&,QDGGLWLRQWKH0LJUDWRU\%LUG7UHDW\$FWRIDVDPHQGHGSURWHFWVPLJUDWRU\

birds included in the terms of the convHQWLRQVLGHQWLILHGLQ86&%RWKDFWVDUH

administered by the FWS. Similar to the MMPA, these two acts lack Federal consultation 

requirements; therefore, applicants and licensees are directly responsible for compliance. 

The Fish and Wildlife Coordination Act requires the NRC to consult with the FWS and the fish 

and wildlife agencies of States if a Federal permit or license could impound, divert, or otherwise 

modify waterbodies. The purpose of the consultation is to prevent loss of and damage to 

wildlife resources. 

7KH&RDVWDO=RQH0DQDJHPHQW$FWRI requires applicants for any NRC license or permit 

to conduct an activity, in or outside of the coastal zone, that would affect any land or water use 

or natural resource of the coastal zone to provide to the NRC a certification that the proposed 

activity complies with any applicable State Coastal Zone Management Plan. An applicant must 

also provide this certification to the State, and the State must notify the NRC whether the State 

concurs with the applicant’s certification. The NRC cannot issue a license or permit to an 

applicant until the State has concurred with the applicant’s certification. 
Affected Environment 

185(*௅ 3-30 September 2014 

3.11 Historic and Cultural Resources 

This section describes the historic and cultural resources that could be affected by continued 

storage. For the purposes of this GEIS, the area of potential effect is the area that may be 

impacted by land-disturbing activities or other operational activities associated with continued 

storage of spent fuel (whether in spent fuel pools or at an at-reactor ISFSI), including the 

viewshed. This determination is made irrespective of land ownership or control. A description 

of these sites, including spent fuel pools and at-reactor ISFSIs, is provided in Section 2.1 of this 

GEIS. 

Historic and cultural resources are the remains of 

past human activity and include prehistoric era 

and historic era archaeological sites, historic 

districts, buildings, or objects with an associated 

historical, cultural, archaeological, architectural, 

community, or aesthetic value. Historic and 

cultural resources also include traditional cultural 

properties that are important to a living community 

RISHRSOHIRUPDLQWDLQLQJWKHLUFXOWXUH3+LVWRULF

property” is the legal term for a historic or cultural 

resource that is eligible for listing on the National 

Register of Historic Places (NRHP) (NRC 2013a). 

The National Historic Preservation Act of 1966 (NHPA) requires Federal agencies to take into 

account the effects of their undertakings on historic properties. Historic properties are defined 

as resources that are eligible for listing on the NRHP. The criteria for NRHP eligibility are listed 

in 36 CFR 60.4 and include, among other things, (1) association with significant events that 

have made a significant contribution to the broad patterns of history, (2) association with the 

lives of persons significant in the past, (3) embodiment of distinctive characteristics of type, 

period, or method of construction, and (4) sites or places that have yielded or may be likely to 

yield important information in history or prehistory (ACHP 2008). The historic preservation 

review process (Section 106 of the NHPA) is outlined in regulations issued by the Advisory 

Council on Historic Preservation in 36 CFR Part 800. 

The prehistoric era refers to the period before Europeans arrived in North America in the 1490s. 

Some of the most heavily used areas during this period were along rivers, lakes, and the 

seashore. These locations provided freshwater and the most abundant food sources, as well as 

the most efficient ways to travel. As a result, prehistoric era archaeological sites tend to be 

found along these waterways. Prehistoric archaeological resources include small temporary 

camps, larger seasonal camps that were revisited year after year, large village sites that were 

Historic Property (36 CFR 800.16(l)(1))

Any prehistoric or historic district, site, 

building, structure, or object included in, or 

eligible for inclusion in, the National Register 

of Historic Places maintained by the Secretary 

of the Interior. Historic properties also include 

artifacts, records, and remains that are related 

to and located within such properties. The 

term includes properties of traditional religious 

and cultural importance to an Indian Tribe or 

Native Hawaiian organization and that meet 

the National Register criteria. 
Affected Environment 

September 2014 3-31 185(*௅

occupied continuously over several years or potentially for centuries, or specialized-use areas 

associated with fishing or hunting or with tool and pottery manufacture (NRC 2013a). 

The historic era refers to the period after Europeans arrived in North America. Similar to 

prehistoric populations, historic era sites tend to be clustered near waterways because water 

provided a means for transportation and trade, and supported agriculture. Historic era 

resources include farmsteads, mills, forts, residences, industrial sites (such as mines or canals), 

and shipwrecks (NRC 2013a). 

Traditional cultural properties are historic and cultural resources that are associated with cultural 

practices or beliefs of a living community, and are often associated with Native American 

cultures. Traditional cultural properties can be considered historic properties and be included 

on the NRHP. Examples include traditional gathering areas where particular plants or materials 

were harvested, locations where a community has traditionally carried out economic, artistic, or 

other cultural practices important to maintaining its identity, or burial locations that connect 

individuals or groups with their ancestors. The locations of traditional cultural properties are 

often kept private; State Historic Preservation Offices can often be unaware of these locations 

(NRC 2013a). 

Historic and cultural resources, especially archaeological sites, are sensitive to disturbance and 

are nonrenewable. Even a small amount of ground disturbance (e.g., ground clearing and 

grading) could affect a small but significant resource. Much of the information contained in an 

archaeological site is derived from the spatial relationships between soil layers and associated 

artifacts. Once these spatial relationships are altered, they can never be reclaimed. 

(NRC 2013a) 

Nuclear power plant sites are located in areas of focused past human activities (along 

waterways) and, as such, there is a potential for historic and cultural resources to be present 

near most nuclear power plants. For example, as part of the recent License Renewal GEIS 

update, the NRC reviewed historic and cultural resource reviews that were performed for 

40 license renewals. For sites that had conducted field investigations, on average, the number 

of historic and FXOWXUDOUHVRXUFHVSUHVHQWZHUHSHUVLWH15&D6LWHVLGHQWLILHG

included a variety of resources, including village and town sites, and cemeteries (NRC 2013a). 

Most existing nuclear power plants in the United States were constructed in the 1960sV

and early 1980s. Although the NHPA was passed in 1966, the process for complying with the 

ODZZDVGHYHORSLQJGXULQJWKHVDQGHDUO\V15&D0DQ\H[LVWLQJQXFOHDU

power plant sites were not investigated for the presence of historic and cultural resources prior 

to initial facility construction. %DVHGRQexperience from reactor license renewal, early site 

permit, and combined license environmental reviews, extensive ground-disturbing activities 

occurred during initial nuclear power plant construction. These construction activities 

extensively disturbed much of the land in and immediately surrounding the power block. 
Affected Environment 

185(*௅ 3-32 September 2014 

The WHUP3SRZHUEORFN ́UHIHUVWRWKHEXLOGLQJVDQGFRPSRQHQWVGLUHFWO\LQYROYHGLQJHQHUDWLQJ

electricity at a power plant. At a nuclear power plant, the components of the power block vary 

with the reactor design, but always include the reactor and turbine building, and usually include 

several other buildings that house access, reactor auxiliary, safeguards, waste processing, or 

other nuclear generation support functions. %XLOGLQJVZLWKLQWKHSRZHUEORFNrequire significant 

excavation of existing material, followed by placement of structural fill for a safe and stable 

EDVH%XLOGLQJH[FDYDWLRQVDUHH[WHQVLYHDQGWKHDUHDRIH[FDYDWLRQLVODUJHUWKDQWKHDV-built 

power block, and reactor containment. 

It is unlikely that historic and cultural resources are present within heavily disturbed areas of a 

power plant site. However, less-developed or disturbed portions of a power plant site, including 

areas that were not extensively disturbed (e.g., construction laydown areas), could still contain 

unknown historic and cultural resources. Laydown areas are lands that were cleared, graded, 

and used to support fabrication and installation activities during initial power plant construction. 

Many ISFSIs have been constructed in less-developed and disturbed areas outside the power 

block. %DVHGRQH[SHULHQFHIURPUHDFWRUOLFHQVHUHQHZDOHDUO\VLWHSHUPLWDQGFRPELQHG

license environmental reviews, historic and cultural resource sites tend to occur in lessdeveloped and undeveloped areas of the power plant site. Accordingly, many licensees have 

developed and implemented historic and cultural resource management plans and procedures 

that consider and protect known resources and address inadvertent discoveries. 

For continued storage, the NRC will consider impacts to historic and cultural resources in this 

*(,6WKURXJKLWV1(3$UHTXLUHPHQWVLQ&)53DUW1HLWKHUWKHUXOHPDNLQJQRUWKLV*(,6

identifies specific sites for NRC licensing actions that would trigger Section 106 consultation 

requirements that are normally conducted during site-specific licensing reviews. This 

rulemaking is not a licensing action; it does not authorize the initial or continued operation of any 

nuclear power plant, and it does not authorize storage of spent fuel. This GEIS describes the 

potential impacts to historic and cultural resources associated with continued storage of spent 

fuel at both at-reactor and away-from-reactor ISFSIs. 

For site-specific licensing actions (i.e., new reactor licensing, reactor license renewal, and sitespecific at-reactor and away-from-reactor ISFSIs), applicants are required to provide historic 

and cultural resource information in environmental reports submitted with license applications. 

To prepare these assessments, applicants conduct cultural resource surveys and may develop 

management plans or procedures, if such procedures are not already in place. This information 

assists the NRC in its review of the potential impacts to historic and cultural resources. As part 

of these site-specific licensing actions, the NRC has and will continue to comply with the 

consultation requirements in the NHPA regulations in 36 CFR Part 800 and consult with State 

Historic Preservation Offices or appropriate Tribal Historic Preservation Officer, Tribal 

representatives, and other interested parties to determine the area of potential effect and if the 

proposed licensing action would affect historic properties. As identified in 36 CFR 800.2, 
Affected Environment 

September 2014 3-33 185(*௅

interested parties can include representatives of the local government, the license applicant, the 

Advisory Council on Historic Preservation, the public, and organizations with a demonstrated 

interest in the undertaking (proposed licensing action). The NRC will consider information 

provided by these consulting parties when making determinations under the NHPA. If historic 

and cultural resources are present within the area of potential effect, identification of historic 

properties, adverse effects, and potential resolution of adverse effects will be done through 

consultation and application of the NRHP criteria in 36 CFR 60.4. 

3.12 Noise 

This section describes noise associated with continued storage. The affected environment is 

the environment that exists at and around spent fuel pools and at-reactor ISFSIs where 

continued storage activities would occur. Noise describes unwanted sound that is undesirable 

because it interferes with speech, communication, or hearing; is intense enough to damage 

hearing; or is otherwise annoying (NRC 2002). A common sound measurement used to 

indicate sound intensity is the A-weighted sound level (designated as decibel-$RUG%$)). The 

decibel expresses sound levels on a logarithmic scale and accounts for the response of the 

human ear. The noise levels experienced at spent fuel storage locations at a particular point in 

time depends on what noise generating activities are occurring in the vicinity. 

Ambient noise levels depend in part on the amount of development that has occurred in the 

area around nuclear power plant sites. In rural or low-population areas, background noise 

OHYHOVDUHW\SLFDOO\LQDUDQJHRIWRG%$15&D,QDUHDVZKHUHPRUH

development has occurred, the surrounding community and highway noise results in baseline 

QRLVHOHYHOVDURXQGWRG%$15&D2YHUWLPH, the ambient noise levels at a 

particular location can change as the area experiences changes in development. For example, 

if new development activities that generate additional noise are initiated, then the ambient noise 

levels in the area would increase. 

Noise can be examined from the perspective of two different receptor groups: workers and the 

general public. There are no Federal regulations for public exposure to noise. Impacts are 

primarily evaluated in terms of adverse reactions of the public to noise. The EPA has 

developed guideline sound levels below which the general public should be protected from 

activity interference and annoyance. For residential areas, the EPA identified thresholds over a 

24-KRXUSHULRGRIG%$IRULQGRRUH[SRVXUHVDQGG%$IRURXWGRRUH[SRVXUHV

(EPA $WWKH)HGHUDOOHYHOWKH2FFXSDWLRQDO6DIHW\DQG+HDOWK$GPLQLVWUDWLRQUHJXODWHV

noise exposure for workers. The permissible noise exposure limit varies by duration. The limit 

ranges from 90 G%$IRUDGXUDWLRQRIKRXUVSHUGD\WRG%$IRUPLQXWHVRUOHVV

(29 CFR 

%DVHOLQHQRLVHFKDUDFWHULVWLFVZRXOGDOVRLQFOXGHQRLVHJHQHUDWHGE\VSHQWIXHOVWRUDJH

activities. Noise has been assessed in various site-specific, at-reactor ISFSI environmental 
Affected Environment 

185(*௅ 3-34 September 2014 

reviews, such as the Calvert Cliffs ISFSI license renewal (NRC 2012a) for dry cask storage and 

the GEH Morris ISFSI license renewal (NRC 2004) for pool storage. Activities that involve 

construction equipment, such as decommissioning, generate the most ongoing noise, with 

HDUWKZRUNDQGH[FDYDWLRQHTXLSPHQWQRLVHOHYHOVH[FHHGLQJG%$15&1RLVH

associated with continued storage is primarily limited to mobile sources associated with the 

movement of spent fuel between the spent fuel pool and the dry cask storage pad (see 

NRC 2012a). 

Proximity is a factor when assessing impacts because noise levels decrease as distance from 

the source increases. Spent fuel storage facilities typically have large buffer areas between the 

facility and the nearest receptor. In addition, other barriers such as buildings, vegetation, and 

topography can also reduce noise levels. 

3.13 Aesthetics 

Aesthetic resources refer to the visual appeal of a tract of land. The scenic quality of an area 

may include natural and man-made landscapes and the ways in which the two are integrated. 

Aesthetic resources can include scenic viewsheds with waterbodies, topographic features, or 

other visual landscape characteristics. The baseline for evaluation of impacts to aesthetic 

resources is the existing visual condition of a site. Assessment of potential impacts to aesthetic 

resources requires evaluation of the degree to which a project would contrast adversely with the 

existing landscape. Section 2.1 provides a generic description of nuclear power plant sites and 

storage facilities. 

3.14 Waste Management 

This subsection describes the various types of wastes generated and managed as a result of 

the continued storage of spent fuel. 

3.14.1 Low-Level Radioactive Waste 

Low-level waste (LLW) is radioactive waste that (1) is not classified as high-level radioactive 

waste, transuranic waste, spent fuel, or byproduct material defined in paragraphs (2), (3), and 

(4) of the definition of byproduct material set forth in 10 CFR 20.1003. 

Almost all LLW generated from reactor operation activities, including management of spent fuel 

stored in pools and ISFSIs, is shipped offsite, either directly to a disposal facility or to a 

processing center before being sent to a disposal site. The number of shipments leaving each 

reactor site varies but generally ranges from a few to about 100 per year. Subpart K of 10 CFR 

Part 20 discusses the various means by which the licensees may dispose of their radioactive 

waste. The transportation and land disposal of solid radioactive wastes are performed in 

DFFRUGDQFHZLWKWKHDSSOLFDEOHUHTXLUHPHQWVRI&)53DUWDQG CFR Part 61, 

respectively. 
Affected Environment 

September 2014 3- 185(*௅

There are currently four operating disposal facilities 

in the United States that are licensed to accept 

commercial-origin LLW. They are located in 

%DUQZHOO6RXWK&DUROLQD5LFKODQG:DVKLQJWRQ

Clive, Utah; and Andrews County, Texas. The 

facility in Utah, operated by EnergySolutions, is 

licensed to accept only Class A LLW, whereas the 

RWKHUWKUHHIDFLOLWLHVFDQDFFHSW&ODVV$%DQG&

wastes (GAO 2004). In 2001, the South Carolina 

OHJLVODWXUHLPSRVHGUHVWULFWLRQVRQWKH%DUQZHOO

IDFLOLW\VXFKWKDWDIWHU-XQHWKHIDFLOLW\FDQ

accept waste from generators in only three States: 

6RXWK&DUROLQD1HZ-HUVH\DQGConnecticut. The 

%DUQZHOOIDFLOLW\LVSURMHFWHGWRFORVHLQ

(EnergySolutions 2012). The Richland facility 

accepts LLW from 11 States: Washington, Alaska, 

Hawaii, Idaho, Montana, Oregon, Utah, Wyoming, 

Colorado, Nevada, and New Mexico. It is expected 

WRFORVHLQ7KH(QHUJ\6ROXWLRQVIDFLOLW\LQ

Utah accepts only Class A waste, but the waste can 

come from any state. This facility currently does not 

have a projected closing date. The Waste Control 

Specialists, LLC, site LQ7H[DVDFFHSWV&ODVV$%

and C wastes from Texas and Vermont per the 

Texas Low-Level Radioactive Waste Disposal 

Compact. In addition, individual waste generators 

from any other state may apply for an agreement to 

dispose of their non-Compact generated waste at the 

Waste Control Specialists, LLC site. For example, 

waste generators from more than 13 non-Compact 

States have agreements in place to dispose of waste 

at this site (TCC 2014). Currently, there is no 

projected closing date for the Waste Control 

Specialists, LLC LLW site. 

Operating nuclear power plants, including activities associated with spent fuel storage, generate 

LLW generally consisting of air filters, cleaning rags, protective tape, paper and plastic 

coverings, discarded contaminated clothing, tools, equipment parts, and solid laboratory wastes 

(all these are collectively known as dry active waste) and wet wastes that result during the 

processing and recycling of contaminated liquids at the plants. Wet wastes generally consist of 

spent demineralizer or ion exchange resins, and spent filter material from the equipment drain, 

Waste Types Associated with Spent Fuel 

Storage 

Low-level Radioactive Waste (LLW) –

radioactive waste not classified as high-level 

waste, transuranic waste, spent nuclear fuel, 

or byproduct material. LLW for near surface 

GLVSRVDOLVFODVVLILHGLQWR&ODVV$&ODVV%

or Class C waste, and must be disposed of 

in facilities licensed by the NRC or an NRC 

Agreement State. Greater-than-class-C 

(GTCC) waste is not created as a result of 

continued storage activities and is not within 

the scope of this GEIS. 

Mixed Waste: Waste that is both hazardous 

and radioactive. 

Hazardous Waste: A solid waste or 

combination of solid wastes that, because of 

its quantity, concentration, or physical, 

chemical, or infectious characteristics, may 

(1) cause or significantly contribute to an 

increase in mortality or an increase in 

serious irreversible or incapacitating 

reversible illness or (2) pose a substantial 

present or potential hazard to human health 

or the environment when improperly treated, 

stored, transported, disposed of, or 

otherwise managed (as defined in the 

Resource Conservation and Recovery Act, 

DVDPHQGHG

Nonradioactive Nonhazardous Waste: 

Waste that is neither radioactive nor 

hazardous. 
Affected Environment 

185(*௅ 3-36 September 2014 

floor drain, and water cleanup systems. The wet wastes are generally solidified, dried, or 

dewatered to make them acceptable at a disposal site (NRC 2013a). 

The quantity of LLW generated by reactor operation, including spent fuel storage in spent fuel 

pools, varies annually depending on the number of maintenance activities (NRC 2013a). A 

pressurized water reactor, on average, generates approximately 300 m3 (10,600 ft3) and 

1,000 &L× 1013 %T of LLW per year (Table 6.6 in NRC 2013a). The annual volume and 

activity of LLW generated at a boiling water reactor are approximately twice the values indicated 

IRUDSUHVVXUL]HGZDWHUUHDFWRU$SSUR[LPDWHO\SHUFHQWRIWKLVZDVWHLV&ODVV$1(,3). 

After reactor operations have ceased, the number and types of activities generating LLW will 

decrease. Therefore, the annual quantity of LLW generated from storage of spent fuel during 

continued storage is expected to be a small fraction of that generated while the nuclear power 

plant is operating because there are less waste generating activities occurring. 

3.14.2 Mixed Waste 

Wastes that are both radioactive and hazardous are called mixed waste. These wastes are 

regulated by the EPA or an authorized State for the hazardous component, and by the NRC or 

an agreement State for the radioactive component. The types of mixed wastes generated in the 

storage of spent fuel include organics (e.g., waste oils and halogenated organics), metals 

(e.g., lead, mercury, chromium, and cadmium), solvents, paints, and cutting fluids. 

The quantity of mixed waste generated by an operating nuclear power plant is generally 

relatively small (NRC 2013a). For example, the environmental impact statement (EIS) for the 

Fermi Unit 3 FRPELQHGOLFHQVHDSSOLFDWLRQVWDWHGWKDWOHVVWKDQP3\U\G3/yr) of mixed 

waste would be generated during operation (NRC 2013e). 

%HFDXVHRIWKHDGGHGFRPSOH[LW\RIGXDOUHJXODWLRQWKHPDQDJHPHQWDQGGLVSRVDORIPL[HG

waste is more problematic than for the other types of wastes. Similar to hazardous waste, 

mixed waste is generally accumulated onsite in designated areas as authorized under the 

Resource Conservation and Recovery Act (RCRA), and then shipped offsite for treatment as 

appropriate and for disposal. The disposal facilities that are authorized to receive mixed waste 

for disposal are the EnergySolutions facility in Utah and the Waste Control Specialists, LLC, site 

in Texas. 

3.14.3 Hazardous Waste 

+D]DUGRXVZDVWHLVGHILQHGE\WKH(3$LQ&)53DUW3,GHQWLILFDWLRQDQG/LVWLQJRI

Hazardous Waste,” as solid waste that (1) is listed by the EPA as being hazardous; (2) exhibits 

one of the characteristics of ignitability, corrosivity, reactivity, or toxicity; or (3) is not excluded by 

the EPA from regulation as being hazardous. All aspects of hazardous waste generation, 

treatment, transportation, and disposal are strictly regulated by the EPA or by the States under 
Affected Environment 

September 2014 3- 185(*௅

agreement with the EPA per the regulations promulgated under RCRA. Hazardous waste does 

not contain radioactive waste (and if mixed with radioactive waste would be categorized as 

3PL[HGZDVWH ́ as explained above in Section 3.14.2). 

The types of hazardous waste typically generated by nuclear power plants during storage 

operations include waste paints, laboratory packs, and solvents. The quantities of these wastes 

generated by an operating nuclear power plant can vary between facilities, but the quantities 

generally are relatively small when compared with the quantities at most other industrial facilities 

that generate hazardous waste (NRC 2013a). Nuclear power plants would likely accumulate 

their hazardous waste onsite as authorized under RCRA and transport it to a treatment facility. 

Residues remaining after treatment are sent to a permanent disposal facility. There are many 

RCRA-permitted treatment and disposal facilities available throughout the United States. 

3.14.4 Nonradioactive, Nonhazardous Waste 

Similar to other industrial activity, the continued storage of spent fuel will generate wastes that 

are not contaminated with either radionuclides or hazardous chemicals. These wastes include 

trash, paper, wood, construction and demolition materials, and sanitary wastes (sewage). 

Nonhazardous solid wastes as defined in 40 CFR Part 261 are collected and disposed of in a 

local landfill. Sanitary wastes may be treated onsite and the residues sent to local landfills or 

discharged directly to a municipal sewage treatment facility. Sanitary waste may also be 

collected in onsite septic tanks, which are emptied periodically, and then the waste is shipped to 

a local sanitary waste treatment plant. The wastes and sewage are tested for radionuclides 

before being sent offsite to ensure that no inadvertent contamination occurs. Offsite releases 

from onsite sewage treatment plants are conducted under NPDES permits. As with operating 

nuclear power plants, stormwater runoff may be collected and tested before it is discharged 

offsite (NRC 2013a). 

3.14.5 Pollution Prevention and Waste Minimization 

Waste minimization and pollution prevention are important elements of operations at all nuclear 

power plants and at-reactor ISFSIs. Licensees are required to consider pollution prevention 

measures as dictated by the Pollution Prevention Act of 1990 and RCRA. 

In addition, as noted in the License Renewal GEIS and in recent EISs for new reactors and 

license renewal applications, licensees are likely to have waste-minimization programs in place 

that are aimed at minimizing the quantities of waste sent offsite for treatment or disposal. 

Waste-minimization techniques employed by the licensees may include source reduction and 

recycling of materials either onsite or offsite. The establishment of a waste-minimization 

program is also a requirement for managing hazardous wastes under RCRA. 
Affected Environment 

185(*௅ 3-38 September 2014 

3.15 Transportation 

The affected environment for transportation associated with continued storage includes the 

characteristics of the reactor site that support transportation activities, workers involved in 

transportation activities, and the local, regional, and national transportation networks and 

populations that use or live along these networks. 

All nuclear power plants sites are serviced by controlled access roads. In addition to the access 

roads, many of the plants also have railroad connections for moving heavy equipment and other 

materials. Some of the plants that are located on navigable waters, such as rivers, the Great 

Lakes, or oceans, have facilities to receive and ship loads on barges (NRC 2013a). Power plant 

sites provide a network of roads and sidewalks for vehicles and pedestrians as well as parking 

areas for workers and visitors (NRC 2013a). 

Local and regional transportation networks in the vicinity of nuclear power plant sites may vary 

considerably depending on the regional population density, location and size of local 

communities, nature of economic development patterns, location of the region relative to 

interregional transportation corridors, and land surface features, such as mountains, rivers, and 

lakes. The impacts of employee commuting patterns on the transportation network in the 

vicinity of nuclear power plants depend on the extent to which these factors limit or facilitate 

traffic movements and on the size of the plant workforce that uses the network at any given 

time. Impacts at the local level in the immediate vicinity of power plant sites vary depending on 

the capacity of the local road network, local traffic patterns, and particularly the availability of 

alternate routes for power plant workers. Given the rural locations of most power plant sites, 

site traffic has a small impact on the local road system, since often there is not much other 

traffic on local URDGVLQWKHLPPHGLDWHYLFLQLW\RIWKHSODQW%HFDXVHPRVWVLWHVKDYHRQO\RQH

access road, there may be congestion on this road at certain times, such as during shift 

changes (NRC 2013a). 

For transportation of radioactive material from a nuclear power plant site, the affected 

environment includes all rural, suburban, and urban populations living along the transportation 

routes within range of exposure to radiation emitted from the packaged material during normal 

transportation activities or that could be exposed in the unlikely event of a severe accident 

involving a release of radioactive material. The affected environment also includes people in 

vehicles on the same transportation route, as well as people at truck stops and workers who are 

involved with the transportation activities. 

3.16 Public and Occupational Health 

This section describes the affected environment during continued storage with respect to the 

radiological protection of the public and workers. Public radiation doses from natural and 
Affected Environment 

September 2014 3-39 185(*௅

artificial sources other than spent fuel are also described. This section also describes the 

regulatory framework for protection from occupational hazards. 

3.16.1 Radiological Exposure 

Nuclear power plants, spent fuel pools, and at-reactor ISFSIs cause doses to members of the 

public and onsite workers. The Atomic Energy Act of UHTXLUHVWKH15&WRSURPXOJDWH

inspect, and enforce standards that provide an adequate level of protection for public health and 

safety. The NRC continuously evaluates the latest radiation protection recommendations from 

international and national scientific bodies to establish the requirements for nuclear power plant 

licensees. The NRC has established multiple layers of radiation protection limits to protect the 

public against potential health risks from exposure to effluent discharges from nuclear power 

plant operations. If licensees exceed a certain 

fraction of these dose levels in a calendar quarter, 

they are required to notify the NRC, investigate the 

cause, and initiate corrective actions within the 

specified timeframe (10 CFR 20.2201 and 20.2203). 

Nuclear power reactors and their associated spent 

fuel pools and ISFSIs in the United States are 

licensed by the NRC and must comply with NRC 

regulations and conditions specified in the license in 

order to operate. Licensees are required to comply 

with 10 CFR Part 20, Subpart &32FFXSDWLRQDO'RVH

Limits for Adults,” and 10 CFR Part 20, Subpart D, 

35DGLDWLRQ'RVH/LPLWVIRU,QGLYLGXDO0HPEHUVRIWKH

Public.” Additionally, the EPA provides environmental 

radiation protection standards for the uranium fuel 

cycle in 40 CFR Part 190. 

3.16.1.1 Regulatory Requirements for Occupational Exposure 

A plant licensee must maintain individual doses to workers within the 10 CFR 20.1201 

occupational dose limits that are summarized in Table 3-2 and incorporate provisions to 

maintain doses as low as is reasonably achievable. Under 10 CFR 20.2206, the NRC requires 

licensees to submit an annual report of the results of individual monitoring carried out by the 

licensee for each individual for whom monitoring was required by 10 &)5GXULQJWKDW

year. Annually, the NRC publishes a volume of the results of annual reporting of all licensees in 

the publicly available NUREG–9ROXPHOccupational Radiation Exposure at 

Commercial Nuclear Power Reactors and Other Facilities 2010 (NRC 2012c). 

Total effective dose equivalent 

(TEDE): Sum of the effective dose 

equivalent (for external exposure) 

and the committed effective dose 

equivalent (for internal exposure). 

Committed effective dose equivalent 

(CEDE): Sum of the products of the 

weighting factors for body organs or 

tissues that are irradiated and the 

committed dose equivalent to these 

organs or tissues. 

Deep dose equivalent: Applies to 

external whole body exposure and is the 

dose equivalent at a tissue depth of 1 

cm (0.39 in.). 
Affected Environment 

185(*௅ 3-40 September 2014 

Table 3-2. Occupational Dose Limits for Adults Established by 10 CFR Part 20 

Tissue Dose Limit(a)

Whole body or any individual 

organ or tissue other than 

the lens of the eye 

0RUHOLPLWLQJRIUHP\U7('(WRZKROHERG\RUUHP\UVXPRIWKH

deep dose equivalent and the committed dose equivalent to any 

individual organ or tissue other than the lens of the eye 

Lens of the eye UHP\UGRVHHTXLYDOHQW

Skin of the whole body, or 

skin of any extremity 

UHP\UVKDOORZGRVHHTXLYDOHQW

(a) See text box for definitions. 

Note: To convert rem to Sievert, multiply by 0.01. 

Under 10 CFR 20.2202 and 20.2203, the NRC requires all licensees to submit reports of all 

occurrences involving personnel radiation exposures that exceed certain control levels. The 

control levels are used to investigate occurrences and to take corrective actions as necessary. 

Depending on the magnitude of the exposure, reporting is required immediately, within 

24 hours, or within 30 days. 

3.16.1.2 Regulatory Requirements for Public Exposure 

During continued storage in spent fuel pools, liquid, gaseous, and solid radioactive wastemanagement systems would be used to collect and treat the radioactive materials produced as 

byproducts. These systems would process radioactive liquid, gaseous, and solid effluents to 

maintain releases within regulatory limits and to levels as low as is reasonably achievable 

before releasing them to the environment. Waste processing systems are designed to meet the 

GHVLJQREMHFWLYHVRI&)53DUW$SSHQGL[,31XPHULFDO*XLGHVIRU'HVLJQ2EMHFWLYHVDQG

Limiting Conditions for Operation to Meet the Criterion ‘As Low as is Reasonably Achievable’ for 

Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents.” 

NRC regulations in 10 &)5LGHQWLI\FULWHULDIRUUDGLRDFWLYHPDWHULDOVLQHIIOXHQWVDQG

direct radiation from an ISFSI. These criteria include that, for normal operations and anticipated 

occurrences, the annual dose equivalent to any real individual located beyond the controlled 

DUHDPXVWQRWH[FHHGPUHPP6YWRWKHZKROHERG\PUHPPSv) to the 

WK\URLGDQGPUHPP6YWRDQ\RWKHUFULWLFDORUJDQDVDUHVXOWRIH[SRVXUHWRSODQQHG

discharges of radioactive materials, direct radiation, and any other radiation from uranium fuel 

cycle operations within the region. This regulation also requires that operational restrictions be 

established to meet as low as is reasonably achievable objectives. 

3.16.2 Radiological Exposure from Naturally Occurring and Artificial Sources

Table 3-3 identifies background doses to a typical member of the U.S. population. In the table, 

the annual values are rounded to the nearest 1 percent. A total average annual effective dose 

equivalent to members of the U.S. population (i.e., 620 mrem/yr) comes from two primary 

sources: (1) naturally occurring background radiation and (2) medical exposure to patients. 
Affected Environment 

September 2014 3-41 185(*௅

Table 3-3. Average Annual Effective Dose Equivalent of Ionizing Radiation to a Member of the 

U.S. Population for 2006

Source

Effective Dose 

Equivalent 

mrem 

Percent of 

Total 

Ubiquitous background 

Radon and thoron 228 

Natural 

Cosmic 33 

Terrestrial 21 3 

Internal 29 

Total ubiquitous background 311 

Medical 

Computed tomography  24 

Nuclear medicine  12 

Interventional fluoroscopy 43 

Conventional radiography and fluoroscopy 33 

Total medical 300 48 

Consumer products 13 2 

Industrial, security, medical, educational and research 0.3 

Occupational  0.08 

Total 624.8 100 

Source: Adapted from NCRP 2009 

Natural radiation sources other than radon result in 13 percent of the typical radiation dose 

received. The larger source of radiation dose in XELTXLWRXVEDFNJURXQG percent) is from 

radon, particularly because of homes and other buildings that trap radon and significantly 

enhance its dose contribution over open-DLUOLYLQJ7KHUHPDLQLQJ percent of the average 

annual effective dose equivalent consists of radiation mostly from medical procedures 

(computed tomography, 24 percent; nuclear medicine, 12 percent; interventional fluoroscopy, 

 SHUFHQWDQGFRQYHQWLRQDOUDGLRJUDSK\DQGIOXRURVFRS\ percent) and a small fraction from 

consumer products (2 percent). The consumer product exposure category includes exposure to 

members of the public from building materials, commercial air travel, cigarette smoking, mining 

and agricultural products, combustion of fossil fuels, highway and road construction materials, 

and glass and ceramic products. The industrial, security, medical, education, and research 

exposure category includes exposure to the members of the public from nuclear power 

generation; U.S. Department of Energy (DOE) installations; decommissioning and radioactive 

waste; industrial, medical, education, and research activities; contact with nuclear medicine 

patients; and security inspection systems. The occupational exposure category includes 
Affected Environment 

185(*௅ 3-42 September 2014 

exposure to workers from medical, aviation, commercial nuclear power, industry and commerce, 

education and research, government, the DOE, and military installations. Radiation exposures 

from occupational activities, industrial, security, medical, educational and research contribute 

insignificantly to the total average effective dose equivalent. 

3.16.3 Occupational Hazards 

The Occupational Safety and Health Administration (OSHA) is responsible for developing and 

enforcing workplace safety regulations. OSHA was created by the Occupational Safety and 

Health Act RIZKLFKZDVHQDFWHGWRVDIHJXDUGWKHKHDOWKRIZRUNHUV)DFLOLW\ conditions 

that result in an occupational risk, but do not affect the safety of licensed radioactive materials, 

are under the statutory authority of OSHA rather than the NRC as set forth in a Memorandum of 

8QGHUVWDQGLQJ FR EHWZHHQWKH15&DQG26+$5HJDUGOHVVRFFXSDWLRQDOKD]DUGV

can be minimized when workers adhere to safety standards and use appropriate protective 

equipment; however, fatalities and injuries from accidents can still occur. 

3.17 References 

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy3DUW36WDQGDUGVIRU

Protection Against Radiation.” Washington, D.C. 

&)53DUWCode of Federal Regulations, Title 10, Energy3DUW3'RPHVWLF/LFHQVLQJRI

Production and Utilization Facilities.” Washington, D.C. 

&)53DUWCode of Federal Regulations, Title 10, Energy3DUW3(QYLURQPHQWDO

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

Washington, D.C. 

10 CFR Part 61. Code of Federal Regulations, Title 10, Energy3DUW3/LFHQVLQJ

Requirements for Land Disposal of Radioactive Waste.” Washington, D.C. 

&)53DUWCode of Federal Regulations, Title 10, Energy3DUW33DFNDJLQJDQG

Transportation of Radioactive Material.” Washington, D.C. 

&)53DUWCode of Federal Regulations, Title 10, Energy3/LFHQVLQJ5HTXLUHPHQWVIRU

the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and ReactorRelated Greater-Than-Class-C Waste.” Washington, D.C. 

29 CFR Part 1910. Code of Federal Regulations, Title 29, Labor3DUW32FFXSDWLRQDO

Safety and Health Standards.” Washington, D.C. 
Affected Environment 

September 2014 3-43 185(*௅

36 CFR Part 60. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

Part 60, 3National Register of Historic Places.” Washington, D.C. 

36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

3DUW33URWHFWLRQRI+LVWRULF3URSHUWLHV ́:DVKLQJWRQ'&

&)53DUW Code of Federal Regulations, Title 40, Protection of the Environment3DUW

31DWLRQDO3ULPDU\DQG6HFRQGDU\$PELHQW$LU4XDOLW\6WDQGDUGV ́ Washington, D.C. 

&)53DUWCode of Federal Regulations, Title 40, Protection of the Environment3DUW, 

35HTXLUHPHQWVIRU3UHSDUDWLRQ$GRSWLRQDQG6XEPLWWDORI,PSOHPHQWDWLRQ3ODQV ́

Washington, D.C. 

40 CFR Part 81. Code of Federal Regulations, Title 40, Protection of the Environment, Part 81, 

3'HVLJQDWLRQRI$UHDVIRU$LU4XDOLW\3ODQQLQJ3XUSRVHV ́ Washington, D.C. 

40 CFR Part 93. Code of Federal Regulations, Title 40, Protection of the Environment, Part 93, 

3'HWHUPLQLQJ&RQIRUPLW\RI)HGHUDO$FWLRQVWR6WDWHRU)HGHUDO,PSOHPHQWDWLRQ3ODQV ́

Washington, D.C. 

40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of the Environment, 

Part 3Environmental Radiation Protection Standards for Nuclear Power Operations.” 

Washington, D.C. 

40 CFR Part 261. Code of Federal Regulations, Title 40, Protection of the Environment, 

Part 261, 3,GHQWLILFDWLRQDQG/LVWLQJRI+D]DUGRXV:DVWH ́ Washington, D.C. 

40 CFR Part 423. Code of Federal Regulations, Title 40, Protection of the Environment, Part 

36WHDP(OHFWULF3RZHU*HQHUDWLQJ3RLQW6RXUFH&DWHJRU\ ́:DVKLQJWRQ'&

&)53DUW. Code of Federal Regulations7LWOHWildlife and Fisheries, Part 402, 

3,QWHUDJHQF\&RRSHUDWLRQ—(QGDQJHUHG6SHFLHV$FWRIDV$PHQGHG ́:DVKLQJWRQ'&

 FR 2FWREHU30HPRUDQGXPRI8QGHUVWDQGLQJbetween the Nuclear 

Regulatory Commission and Occupational Safety and Health Administration; Worker Protection 

at NRC-licensed Facilities.” Federal Register, U.S. Nuclear Regulatory Commission, 

Washington, D.C. 

)5)HEUXDU\3([HFutive Order 12898: Federal Actions to Address 

(QYLURQPHQWDO-XVWLFHLQ0LQRULW\3RSXODWLRQVDQG/RZ-Income Populations.” Federal Register, 

Executive Office of the President, Washington, D.C.
Affected Environment 

185(*௅ 3-44 September 2014 

)5)HEUXDU\3,QGLDQ7ULEHV$LU4XDOLW\3ODQQLQJDQG0DQDJHPHQW ́

Federal Register, U.S. Nuclear Regulatory Commission, Washington, D.C. 

)5. August 24, 2004. 33ROLF\6WDWHPHQWRQWKH7UHDWPHQWRI(QYLURQPHQWDO-XVWLFH

Matters in NRC Regulatory and Licensing Actions.” Federal Register, U.S. Nuclear Regulatory 

Commission, Washington, D.C. 

)5'HFHPEHU3(QGDQJHUPHQWDQG&DXVHRU&RQWULEXWH)LQGLQJVIRU

Greenhouse Gases under Section 202(a) of the Clean Air Act.” Federal Register, 

U.S. Environmental Protection Agency, Washington, D.C.

)5-XQH3'HFRPPLVVLRQLQJ3ODQQLQJ ́Federal Register, U.S. Nuclear 

Regulatory Commission, Washington, D.C. 

ACHP (Advisory Council on Historic Preservation). 2008. National Register Evaluation Criteria. 

Washington, D.C. Accession No. 0/

$UPDQWURXW1%Glossary of Aquatic Habitat Inventory Terminology. Western Division 

of $PHULFDQ)LVKHULHV6RFLHW\%HWKHVGD0DU\ODQG

$WRPLF(QHUJ\$FWRIDVDPHQGHG86&et seq. 

%DFN:-65RVHQVKHLQDQG35. Seaber, eds. 1988. The Geology of North America: 

Volume O–2: Hydrogeology7KH*HRORJLFDO6RFLHW\RI$PHULFD%RXOGHU&RORUDGR

%DOGDQG*ROGHQ(DJOH3URWHFWLRQ$FWRIDVDPHQGHG86&–668d et seq.

%HHWRQ$03/DUJH)UHVKZDWHr Lakes: Present State, Trends, and Future.” 

Environmental Conservation 29(1):21–38, New York, New York. 

&(4&RXQFLORQ(QYLURQPHQWDO4XDOLW\Environmental Justice: Guidance Under the 

National Environmental Policy Act. Executive Office of the President, Washington, D.C. 

Available at 

KWWSZZZHSDJRYFRPSOLDQFHHMUHVRXUFHVSROLF\HMBJXLGDQFHBQHSDBFHTSGI. 

Clean Air Act, as amended. 42 USC et seq. 

Clean Water Act 6HH)HGHUDO:DWHU3ROOXWLRQ&RQWURO$FWRI

Coastal Zone Management Act RI, as amended86&et seq. 

&ROXPELD&RXQW\36XPPDU\RI$VVHVVPHQWDQG7D[5ROO–13.” Columbia County, 

Mt. St. Helens, Oregon. Accession No. ML13099A042. 
Affected Environment 

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CYAPC (Connecticut Yankee Atomic Power Company). 2012. Haddam Neck Plant 

Independent Spent Fuel Storage Installation Decommissioning Funding Plan. East Hampton, 

Connecticut. Accession No. ML123630241. 

(GVDOO7DQG0&KDUOWRQNearshore Waters of the Great Lakes. U.S. Environmental 

Protection Agency and Environment Canada, Washington, D.C. and Downsview, Ontario. 

Available at 

http://www.epa.gov/solec/archive/1996/Nearshore_Waters_of_the_Great_Lakes.pdf. 

(QGDQJHUHG6SHFLHV$FWRI (ESA), as amended. 16 USC  et seq. 

EnergySolutions. 2012. FY 2012/2013 Least Cost Operating Plan Barnwell Disposal Facility. 

%('/–12–024, %DUQZHOO6RXWK&DUROLQD$YDLODEOHDW

KWWSGPVSVFVFJRYSGIPDWWHUV)&$%-'--%%$%'&SGI. 

(3$86(QYLURQPHQWDO3URWHFWLRQ$JHQF\Information on Levels of Environmental 

Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety. 

––004, Washington, D.C. 

(35,DQG0DLQH<DQNHHMaine Yankee Decommissioning Experience Report: Detailed 

Experiences 1997–2004. Palo Alto, California and Wiscasset, Maine. Accession 

No. 0/$

)HGHUDO:DWHU3ROOXWLRQ&RQWURO$FWRIDVDPHQGHGDOVRUHIHUUHGWRDVWKH&OHDQ:DWHU

$FW86&et seq.

Fish and Wildlife Coordination Act of 1934, as amended. 16 USC 661-H et seq. 

FWS (U.S)LVKDQG:LOGOLIH6HUYLFH National Wetlands Inventory. U.S. Department of 

the Interior, Washington, D.C. Available at http://www.fws.gov/wetlands/index.html. 

GAO (U.S. Government Accountability Office). 2004. Low-Level Radioactive Waste—Disposal 

Availability Adequate in Short Term, but Oversight Needed To Identify Any Future Shortfalls. 

GAO–04–604, U.S. Nuclear Regulatory Commission, Washington, D.C. Available at 

KWWSZZZJDRJRYDVVHWVSGI. 

GCRP (U.S. Global Change Research Program). 2014. Climate Change Impacts in the United 

States: The Third National Climate Assessment. -00HOLOOR7&5LFKPRQGDQG*:<RKH

eds. U.S. Government Printing Office, Washington, D.C. Accession No. ML14129A233. 
Affected Environment 

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Hassett-6LSSOH%0National Ambient Air Quality Standards (NAAQS) for Particulate 

Matter (PM): Current Review—Focus on Primary PM2.5 Standards. EPA/WESTAR Residential 

Wood Smoke Workshop, Salt Lake City, Utah. 

Magnuson-Stevens Fishery Conservation and Management Act, as amended. 16 USC 1801 et 

seq.

Marine Mammal Protection Act RI, as amended. 16 USC 1361 et seq.

Metz, W. 1983. Population and Land Use Change in the Vicinity of Operating Nuclear Power 

Station—An Anthology. %URRNKDYHQ National Laboratory, Upton, New York. 

0LJUDWRU\%LUG7UHDW\$FWRIDVDPHQGHG86&– et seq.

0RUURZ-9DQG-&)LVFKHQLFKHabitat Requirements for Freshwater Fishes. ERDC 

TN–EMRRPSR–06, U.S. Army Engineer Research and Development Center, Vicksburg, 

Mississippi. Available at http://el.erdc.usace.army.mil/elpubs/pdf/sr06.pdf. 

MYAPC (Maine Yankee Atomic Power Company). 2013. Maine Yankee Independent Spent 

Fuel Storage Installation Revised Decommissioning Funding Plan. Wiscasset, Maine. 

Accession No. 0/. 

National Environmental Policy Act of 1969 (NEPA), as amended. USC 4321 et seq.

National Historic Preservation Act of 1966 (NHPA), as amended86&et seq. 

NCRP (National Council on Radiation Protection and Measurements). 2009. Ionizing Radiation 

Exposure of the Population of the United States5HSRUW%HWKHVGD0DU\ODQG

NEI (Nuclear Energy Institute). 2013. Low-Level Radioactive Waste. Washington, D.C. 

$FFHVVLRQ1R0/$

1RUWKFRWH7*30LJUDWRU\VWUDWHJLHVDQGSURGXFWLRn in freshwater fishes.” In S.D. 

Gerking, ed., Ecology of Freshwater Fish Production%ODFNZHOO6FLHQFH2[IRUG(QJODQG. 

15&861XFOHDU5HJXODWRU\&RPPLVVLRQEnvironmental Assessment Related to the 

Construction and Operation of the Surry Dry Cask Independent Spent Fuel Storage Installation. 

Washington, D.C. Accession No. ML062400262. 

NRC (U.S. Nuclear Regulatory Commission). 1988. Environmental Assessment Related to the 

Construction and Operation of the Oconee Nuclear Station Independent Spent Fuel Storage 

Installation. Washington, D.C. Accession No. ML123480209. 
Affected Environment 

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NRC (U.S. Nuclear Regulatory Commission). 1989. Environmental Assessment and Finding of 

No Significant Impact for Proposed Rule Entitled, “Storage of Spent Nuclear Fuel in NRCApproved Storage Casks at Nuclear Power Reactor Sites.” Washington, D.C. Accession 

No. 0/

NRC (U.S. Nuclear Regulatory Commission). 1991a. Environmental Assessment Related to 

Construction and Operation of the Fort St. Vrain Independent Spent Fuel Storage Installation. 

'RFNHW1R–009, Public Service Company of Colorado, Washington, D.C. Accession 

No. 0/

NRC (U.S. Nuclear Regulatory Commission). 1991b. Environmental Assessment Related to 

the Construction and Operation of the Calvert Cliffs Independent Spent Fuel Storage 

Installation. Washington, D.C. Accession No. 0/

NRC (U.S. Nuclear Regulatory Commission). 1992. Environmental Assessment Related to 

Construction and Operation of the Prairie Island Independent Spent Fuel Storage Installation. 

Washington, D.C. $FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 2002. Final Generic Environmental Impact 

Statement on Decommissioning of Nuclear Facilities, Supplement 1 Regarding the 

Decommissioning of Nuclear Power Reactors. NUREG–9ROXPHs 1 and 2, Washington, 

D.C. Accession Nos. 0/0/

NRC (U.S. Nuclear Regulatory Commission). 2003. Environmental Assessment Related to the 

Construction and Operation of the Diablo Canyon Independent Spent Fuel Storage Installation. 

:DVKLQJWRQ'&$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 2004. Environmental Assessment for the License 

Renewal of the General Electric Morris Operation Independent Spent Fuel Storage Installation 

in Morris, Illinois. :DVKLQJWRQ'&$FFHVVLRQ1R0/

15&861XFOHDU5HJXODWRU\&RPPLVVLRQDEnvironmental Assessment Related to 

the Renewal of the H.B. Robinson Steam Electric Plant, Unit No. 2 Independent Spent Fuel 

Storage Installation License Special Nuclear Materials License No. SNM–2502. 

Washington, '&$FFHVVLRQ1R0/

15&861XFOHDU5HJXODWRU\&RPPLVVLRQEEnvironmental Assessment Related to 

the Renewal of the License for the Surry Independent Spent Fuel Storage Installation. 

:DVKLQJWRQ'&$FFHVVLRQ1R0/
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185(*௅ 3-48 September 2014 

15&861XFOHDU5HJXODWRU\&RPPLVVLRQFEnvironmental Assessment Related to 

the Construction and Operation of the Humboldt Bay Independent Spent Fuel Storage 

Installation. :DVKLQJWRQ'&$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 2008. North Anna Independent Spent Fuel 

Storage Installation, Final Safety Analysis Report. Revision 6, Washington, D.C. Accession 

No. 0/

NRC (U.S. Nuclear Regulatory Commission). 2009a. Environmental Assessment for the 

Renewal of U.S. Nuclear Regulatory Commission License No. SNM–2503 for Oconee Nuclear 

Power Station Independent Spent Fuel Storage Installation. Washington, D.C. Accession 

No. 0/

NRC. (U.S. Nuclear Regulatory Commission). 2009b. 3Memorandum and Order in the Matter 

of Duke Energy Carolinas, LLC and Tennessee Valley Authority [Greenhouse Gas Emissions].” 

CLI–09–:DVKLQJWRQ'&$FFHVVLRQ1R0/. 

NRC (U.S. Nuclear Regulatory Commission). 2011. Policy Issue (Information) from 

R.W. %RUFKDUGWWR7KH&RPPLVVLRQHUVGDWHG)HEUXDU\UHJDUGLQJ36HQLRU0DQDJHPHQW

Review of Overall Regulatory Approach to Groundwater Protection.” SECY–11–0019, 

WaVKLQJWRQ'&$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 2012a. Environmental Assessment for the 

Proposed Renewal of U.S. Nuclear Regulatory Commission License No. SNM–2505 for Calvert 

Cliffs Nuclear Power Plant, LLC’s Independent Spent Fuel Storage Installation. 

Washington, D.C. Accession No. ML121220084. 

NRC (U.S. Nuclear Regulatory Commission). 2012b. Predecisional Draft—Proposed Draft 

Guidance Decommissioning Planning During Operations. Washington, D.C. Accession 

No. 0/$

NRC (U.S. Nuclear Regulatory Commission). 2012c. Occupational Radiation Exposure at 

Commercial Nuclear Power Reactors and Other Facilities 2010: Forty-Third Annual Report. 

NUREG–9ROXPH :DVKLQJWRQ'&$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 2013a. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants. NUREG–5HYLVLRQ:DVKLQJWRQ'&

$FFHVVLRQ1R0/$

NRC (U.S. Nuclear Regulatory Commission). 2013b. 2013–2014 Information Digest. NUREG–

9ROXPH:DVKLQJWRQ'&$FFHVVLRQ1R0/$. 
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NRC (U.S. Nuclear Regulatory Commission). 2013c. Attachment 1—Staff Guidance for 

Greenhouse Gas and Climate Change Impacts for New Reactor Environmental Impact 

Statements. COL/ESP-ISG-026, Washington, D.C. Accession No. ML12326A811. 

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0/0439. 

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Combined Licenses (COL) for Enrico Fermi Unit 3 Final Report. NUREG–9ROXPHV 1 and 

2, :DVKLQJWRQ'&$FFHVVLRQ1RV0/$, 0/$

Occupational Safety and Health Act RI86&et seq. 

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Payments to 49 California Counties.” News and Perspectives from Pacific Gas and Electric 

Company, San Francisco, &DOLIRUQLD$FFHVVLRQ1R0/$

Pollution Prevention Act of 1990. 42 USC 13101 et seq. (1990). 

5HVRXUFH&RQVHUYDWLRQDQG5HFRYHU\$FWRI (RCRA). 42 USC 6901 et seq. 

Safe Drinking Water Act, as amended. 42 USC 300f. et seq. 

TCC (Texas Low Level Radioactive Waste Disposal Compact Commission). 2014. Imports. 

Austin, Texas. Available at http://www.tllrwdcc.org/imports.

Todd, D.K. 1960. Groundwater Hydrology. Second Edition, New York, New York. 

86&%86&HQVXV%XUHDX Current Population Reports. Series P60, 

Washington, D.C. Available at http://www.census.gov/main/www/cprs.html. 

:LOOLDPV-'0/:DUUHQ.6&XPPLQJV-/+DUULVDQG5-1HYHV3&RQVHUYDWLRQ

Status of Freshwater Mussels of the United States and Canada.” Fisheries 18:6–22, 

Philadelphia, Pennsylvania. 

:LWPDQ-'36XEWLGDO&RH[LVWHQFH6WRUPV*UD]LQJ0XWXDOLVPDQGWKH=RQDWLRQRI

Kelps and Mussels.” Ecological Monographs –,WKDFD1HZ<RUN

September 2014 4-1 185(*௅

4.0 Environmental Impacts of At-Reactor 

Continued Storage of Spent Fuel 

This chapter evaluates the environmental impacts of continued at-reactor storage of spent 

nuclear fuel (spent fuel) in a spent fuel pool or independent spent fuel storage installation 

(ISFSI). The U.S. Nuclear Regulatory Commission (NRC) evaluated the environmental impacts 

of at-reactor continued storage for three timeframes: short-term storage, long-term storage, and 

indefinite storage. Chapter 2 provides descriptions of the various activities that occur during 

continued storage. The environmental impacts of away-from-reactor ISFSI storage are 

HYDOXDWHGLQ&KDSWHU

In the short-term storage timeframe, the NRC evaluates the impacts of continued storage of 

spent fuel for 60 years beyond the licensed life for operations of a reference reactor. The NRC 

assumes that all spent fuel has been transferred from the spent fuel pool to an ISFSI by the end 

of this 60-year timeframe. The NRC also assumes that a repository becomes available by the 

end of this 60-year timeframe. 

Short-term storage of spent fuel for 60 years beyond licensed life for operations includes the 

following: 

x continued storage of spent fuel in spent fuel pools (at-reactor only) and ISFSIs, 

x routine maintenance of spent fuel pools and ISFSIs (e.g., maintenance of concrete pads), 

and 

x handling and transfer of spent fuel from spent fuel pools to ISFSIs. 

The NRC then evaluates the impacts of continued storage for another 100 years after shortterm storage. This 100-year timeframe is referred to as the long-term storage timeframe. The 

Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel (GEIS) 

assumes that a repository would become available by the end of the 100-year timeframe 

(160 years total continued storage after the end of the reactor’s licensed life for operation). 

Long-term storage activities include the following: 

x continued storage of spent fuel in ISFSIs, including routine maintenance, 

x one-time replacement of ISFSIs and spent fuel canisters and casks, and 

x construction and operation of a dry transfer system (DTS) (including replacement). 

The NRC also evaluates the environmental impacts of a third timeframe that assumes a 

repository does not become available, thus requiring onsite storage in spent fuel pools until the 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-2 September 2014 

end of the short-term storage timeframe and storage in ISFSIs indefinitely. The activities during 

the indefinite storage timeframe are the same as those that would occur for long-term storage; 

however, without a repository these activities occur repeatedly. Figure 1-1 provides a graphical 

representation of the three timeframes. 

Section 1.8.3 provides a list of the assumptions made in this GEIS regarding continued storage. 

Impacts from decommissioning the spent fuel pool, ISFSI, and DTS are not evaluated in this 

chapter but are considered in the cumulative impacts analysis in Chapter 6, as are the impacts 

from spent fuel transportation to a repository. Construction of a new spent fuel pool cooling 

system, to support decommissioning, is also addressed in the cumulative impacts analysis. The 

environmental impacts of operating a new cooling system during continued storage are 

bounded by the impacts of an operating reactor and are therefore not discussed further in this 

chapter. The NRC assumes that the initial at-reactor ISFSIs would be constructed under a 

general or site-specific license during the term of reactor operations (including license renewal); 

therefore, the construction impacts of these initial at-reactor ISFSIs are not specifically analyzed 

in this GEIS, but are taken into account in establishing the baseline affected environment 

described in Chapter 3. These ISFSIs would, however, be subject to periodic relicensing 

reviews and accompanying environmental reviews under the National Environmental Policy 

Act of 1969 (NEPA). Further, the NRC assumes that the ISFSIs are completely replaced every 

100 years. This replacement activity would require separate site-specific authorization from the 

NRC before the start of any replacement activities. NRC authorization to relicense or replace 

an ISFSI and NRC authorization to construct, operate, and replace a DTS are separate 

licensing actions that would require an NRC review. They are considered Federal actions under 

NEPA and would be undertakings under the National Historic Preservation Act (NHPA). 

As discussed in Chapter 2, there are two existing away-from-reactor ISFSIs—the GEH Morris 

and Three Mile Island Unit 2 (TMI-2) ISFSIs. However, as explained below, the environmental 

impacts described in this chapter for at-reactor ISFSIs are representative of the impacts at both 

of these away-from-reactor ISFSIs.

x The GEH Morris ISFSI is at the site of a spent fuel reprocessing facility (a production facility) 

that was constructed by General Electric, but never operated. Because it was to be a 

production facility licensed under siting and safety requirements similar to those for reactors 

(e.g., Title 10 of the Code of Federal Regulations 3DUW>&)53DUW@3'RPHVWLF

Licensing of Production and Utilization Facilities”), the GEH Morris facility is sited and 

constructed in a manner substantially similar to a reactor spent fuel pool. In fact, it is 

cXUUHQWO\OLFHQVHGWRVWRUHSUHVVXUL]HGZDWHUUHDFWRU3:5IXHODVVHPEOLHVDQG

 ERLOLQJZDWHUUHDFWRU%:5IXHODVVHPEOLHVIRUDWRWDORIDERXW MTU, which is no 

PRUHWKDQWKHOLFHQVHGFDSDFLW\RIPDQ\%:5VSHQWIXHOSRROV7KHUHIRUHWKH

environmental impacts described in the following chapters of this GEIS for at-reactor spent 

fuel pools are representative of the impacts at the GEH Morris facility. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-3 185(*௅

x The TMI௅2 ISFSI is a modified NUHOMS spent fuel storage system (designated 

NUHOMS-12T) with 30 horizontal storage modules (DOE 2012). It was licensed by the 

NRC in March 1999 and contains spent fuel from the damaged TMI-2 reactor (a single 

reactor core). Although the NUHOMS௅12T storage module contents are core debris (not 

fuel assemblies) and the debris storage canisters could not be treated like fuel cladding, the 

design of the NUHOMS௅12T accounts for these technical differences. Each NUHOMS௅12T 

module provides for the horizontal dry storage of up to 12 TMI௅2 stainless-steel canisters 

inside a dry shielded canister, which is placed inside a concrete horizontal storage module. 

The NUHOMS௅12T modification includes venting of the dry shielded canister through highefficiency particulate air grade filters during storage. The vent system allows for release of 

hydrogen gas, generated due to radiolysis, and monitoring and/or purging of the system 

during operation (DOE 2012). The TMI௅2 ISFSI is actually no larger than a typical at-reactor 

ISFSI and meets the same NRC regulatory standards as at-reactor ISFSIs. Therefore, the 

environmental impacts described in this chapter for at-reactor ISFSIs are representative of 

the impacts at the TMI௅2 ISFSI. 

In this chapter, the NRC uses the License Renewal GEIS (NRC 2013a) to inform some of the 

impact determinations regarding continued storage. In many of these cases, the analysis in this 

GEIS considers how the environmental impacts of continued storage compare to the impacts 

considered in the License Renewal GEIS. In the License Renewal GEIS, the NRC evaluated 

the potential impacts in each resource area by reviewing previous environmental analyses for 

SDVWOLFHQVHUHQHZDOUHYLHZVVFLHQWLILFOLWHUDWXUHDQGRWKHUDYDLODEOHLQIRUPDWLRQ:KHUH

appropriate, this GEIS also considers analyses and impact determinations made in previous 

ISFSI licensing and renewal environmental assessments (EA) and environmental impact 

statements (EISs) and in reactor license renewal and new reactor licensing EISs to inform the 

impact determinations in this analysis. 

SectionVWKURXJKHYDOXDWHWKHSRWHQWLDOLPSDFWVRQYDULRXVUHVRXUFHDUHDVVXFKDV

land use, air quality, water quality, transportation, and public health. Sections 4.18 and 4.19 

discuss accidents and terrorism. Section 4.20 provides a summary of the environmental 

LPSDFWVDQG6HFWLRQFRQWDLQVWKHUHIHUHQFHV:LWKLQHDFKUHVRXUFHDUHDWKH15&KDV

provided an analysis of the potential impacts for the short-term storage timeframe, the long-term 

storage timeframe, and indefinite storage and provided an impact determination—SMALL, 

MODERATE, or LARGE—for each timeframe. The definitions of SMALL, MODERATE, and 

/$5*(DUHSURYLGHGLQ6HFWLRQFor some resource areas, the impact determination 

language is specific to the authorizing regulation, executive order, or guidance. 

4.1 Land Use 

This section describes land-use impacts caused by the continued storage of spent fuel in spent 

fuel pools and at-reactor ISFSIs. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-4 September 2014 

4.1.1 Short-Term Storage 

Spent fuel pool operations during the short-term storage timeframe would not require the use of 

any land beyond that which was cleared and graded during nuclear power plant construction. 

Continued operation of the spent fuel pool during short-term storage is not anticipated to require 

new or additional monitoring or maintenance activities that would affect current land use. In 

addition, inspection, testing, and surveillance activities that are conducted throughout the life of 

spent fuel pools necessary to ensure compliance with Federal, State, and local requirements 

regarding the environment and public safety are not expected to affect land-use conditions 

(NRC 2013a). 

As described in Section 3.1, most nuclear power plant sites have constructed ISFSIs for onsite 

dry cask storage of spent fuel. Dry cask storage at operating nuclear power plant sites provides 

supplemental storage for portions of the spent fuel pool inventory. As further described in 

Section 3.1, only a small fraction of the land committed for a nuclear power plant is required to 

construct and operate an ISFSI (see Table 3-1). 

Operation of an ISFSI involves removing the spent fuel from spent fuel pools, packaging the 

spent fuel in dry casks, and placing the dry casks on concrete storage pads. ISFSI operations 

would not require the use of any land beyond that which was cleared and graded during facility 

construction. The ISFSI would be surrounded by security fencing to restrict and control access 

LQDFFRUGDQFHZLWKUHTXLUHPHQWVIRUWKHSURWHFWLRQRIVWRUHGVSHQWIXHOLQ&)52QO\D

small portion of the land committed for a nuclear power plant is required for an at-reactor ISFSI 

(see Table 3-1). Therefore, access restrictions associated with operation of an ISFSI during the 

short-term storage timeframe would affect only a small amount of land within the larger nuclear 

plant site. 

ISFSIs are designed as passive systems that require no power or regular maintenance other 

than routine visual inspections and checks of the cask ventilation system (e.g., for blockages of 

ducts). Continued operation of an at-reactor ISFSI is not anticipated to require new or additional 

maintenance activities that would affect current land use. The NRC has prepared several EAs 

for site-specific licenses for construction and operation of at-UHDFWRU,6)6,V15&DD

2003, and 1992). 

Based on the assessment above, 60 years of continued at-reactor storage in a spent fuel pool 

or at-reactor ISFSI would not require disturbance of any new land at a nuclear power plant or 

result in operational or maintenance activities that would change the current land use. 

Therefore, the NRC concludes that the potential environmental impact on land use would be 

SMALL during the short-term storage timeframe. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

4.1.2 Long-Term Storage 

The potential environmental impacts on land use from long-term storage in an ISFSI would be 

similar to those described for short-term storage. Only a small fraction of the land committed for 

a nuclear power plant is required for an ISFSI (see Table 3-1). Operation and maintenance of 

an ISFSI would not require the use of any land beyond that which was already cleared and 

graded during facility construction. Access restrictions associated with operation of an ISFSI 

during the long-term storage timeframe would affect only a small amount of land within the 

larger nuclear plant site. 

During long-term storage, in addition to routine maintenance and monitoring, the NRC assumes 

that a DTS is constructed and operated to facilitate the transfer, handling, and repackaging of 

spent fuel after the end of the short-term timeframe. As described in Section 2.1.4, the 

reference DTS considered in this GEIS consists of two major structures: (1) a two-level concrete 

and steel structure that provides confinement and shielding during fuel-transfer, handling, and 

repackaging operations and (2) an attached, single-level steel building for receipt and handling 

of the spent fuel transportation packages. These two major structures would be constructed on 

a reinforced-concrete basemat that would occupy about 0.04 ha (0.1 ac). Maintenance and 

monitoring activities associated with a DTS would include routine inspections and testing of the 

spent fuel and cask transfer and handling equipment (e.g., lift platforms and associated 

mechanical equipment) and process and effluent radiation monitoring, which do not require the 

use of any land beyond that which would be cleared and graded during DTS construction. 

As described in Section 3.1, the physical area required for operating a commercial nuclear 

SRZHUSODQWVLWHUDQJHVIURPKDDFWRKDDF15&D7KHUHIRUH

only a small fraction of the land committed for a nuclear power plant would be required to 

construct and operate a DTS. Once the DTS is constructed, access to the facility site would be 

UHVWULFWHGLQDFFRUGDQFHZLWK&)53DUWWRDFWLYLWLHVWKDWVXSSRUWIDFLOLW\RSHUDWLRQV7KH

restricted access area for the reIHUHQFH'76GHVFULEHGLQ6HFWLRQLVDERXWKDDF

The NRC assumes that the at-reactor ISFSI and DTS would be replaced during the long-term 

storage timeframe. The number of storage casks that would be replaced and the size of the 

replacement concrete storage pad would depend on the remaining inventory of spent fuel to be 

transported to a permanent repository after the 100-year timeframe. The replacement facilities 

for the at-reactor ISFSI and DTS would be constructed on land near the existing facilities. 

Long-term storage of spent fuel at an at-reactor ISFSI would not result in operational or 

maintenance activities that would change land-use conditions. Construction and operation of a 

DTS and replacement of the ISFSI and DTS would affect a small fraction of the land already 

committed for a nuclear power plant. Therefore, the NRC concludes that the environmental 

impacts on land use during the long-term storage timeframe would be SMALL. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-6 September 2014 

4.1.3 Indefinite Storage 

This section describes the potential environmental impacts on land use if a repository is not 

available to accept spent fuel. For this analysis, the NRC assumes that spent fuel would 

continue to be stored in at-reactor ISFSIs indefinitely. The potential environmental impacts on 

land use from indefinite storage would be similar to those described for long-term storage. 

Aging management is assumed to include replacement of the ISFSI and DTS every 100 years 

and necessitate repackaging of spent fuel at a DTS. Replacement of the ISFSI and DTS would 

occur on land near existing facilities. The older ISFSI and DTS would be demolished, and the 

land reclaimed. 

Access to the ISFSI and DTS would be restricted to activities that support facilities operations in 

accordance with 10 CFR 3DUW5HVWULFWHGDFFHVVXQGHUWKHLQGHILQLWHVWRUDJHWLPHIUDPH

would result in land that would not be available for other productive land uses for an indefinite 

amount of time. However, as noted previously, only a small portion of the land already 

committed for a nuclear power plant is required for an at-reactor ISFSI and DTS. Therefore, the 

amount of land that would not be available for other land uses under the indefinite storage 

timeframe would be small. 

Indefinite storage of spent fuel in at-reactor ISFSI facilities would not result in operational or 

maintenance activities that would change land-use conditions. Construction of a DTS and 

replacement of the ISFSI and DTS every 100 years would affect a small fraction of the nuclear 

plant site. After replacement, the older ISFSI and DTS would be demolished and the land would 

be reclaimed. Therefore, the NRC concludes that the environmental impacts on land use from 

indefinite storage would be SMALL. 

4.2 Socioeconomics 

This section describes the socioeconomic factors that could be directly or indirectly affected by 

continued storage of spent fuel in spent fuel pools and at-reactor ISFSIs. Changes in 

employment and tax payments caused by continued storage can have a direct and indirect 

effect on public services and housing demand, as well as traffic volumes in the communities in 

the region around each nuclear power plant site. As discussed in Chapter 3, the socioeconomic 

region of influence is where spent fuel storage workers and their families reside, spend their 

income, and use their benefits, thus directly and indirectly affecting the economic conditions of 

the region. 

4.2.1 Short-Term Storage 

During the short-term storage timeframe, some systems used during reactor operations would 

remain in operation to ensure spent fuel pool cooling prior to the transfer of spent fuel from the 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

pools to an at-reactor ISFSI. A small number of workers—OLNHO\EHWZHHQDQG—would 

continue to maintain, monitor, and transfer spent fuel from spent fuel pools to an at-reactor 

ISFSI after the cessation of reactor operations. A small number of workers (30–ZRXOGDOVR

continue to maintain and monitor the at-reactor ISFSI. Because the existing storage workforce 

would remain to monitor and maintain storage facilities after reactor operations cease, there 

would be no need for any additional spent fuel pool and at-reactor operations workers.1 

Therefore, there would be no increase in demand for housing and public services because of 

continued storage. Continued storage activities are also not likely to affect local transportation 

conditions in the vicinity of the storage facility. Transportation activities would continue at 

reduced levels after the cessation of reactor operations as spent fuel storage operations and 

decommissioning workers would continue to commute to the site. The number of commuting 

storage operations workers, however, would be reduced after all spent fuel has been transferred 

from the pool to an ISFSI. 

The amount of tax payments during the short-term storage timeframe would depend on a 

number of factors, including State tax law and established tax payment agreements with local 

tax authorities. Property tax and other payments, including the portion for at-reactor spent fuel 

storage, would continue, although the amount of tax payments would likely be reduced after 

reactor operations cease. Nevertheless, the amount of tax payments related to continued 

storage is not expected to change during the short-term timeframe. 

The socioeconomic effects of reactor operations have become well established as regional 

socioeconomic conditions have adjusted to the presence of the nuclear power plant. During the 

period of reactor operations local communities have adjusted to fluctuations in workforce 

caused by regularly scheduled refueling and maintenance outages (NRC 2013a). By 

comparison, the contributory effect on socioeconomic conditions from continued short-term 

spent fuel storage would be SMALL, because (1) the number of storage operations workers 

required to maintain and monitor spent fuel storage in pools or an at-reactor ISFSI is very small, 

(2) tax payments would continue, and (3) there would be no increased demand for housing and 

public services. Any reduction in State and local taxes paid by the licensee would be directly 

attributable to the cessation of reactor operations and the reduced value of the property rather 

than to continued storage. Therefore, the socioeconomic impacts of continued onsite storage 

during the short-term timeframe would be SMALL. 

4.2.2 Long-Term Storage 

As discussed in Section 2.1.4, in contrast to short-term storage, long-term storage of spent fuel 

would require the construction and operation of a DTS and replacement of the DTS and ISFSI. 

 

1 Typically shutdown units that are co-located with operating units either have a small dedicated staff or 

have workers from the operating units assigned and dedicated to the shutdown unit (e.g., spent fuel pool 

maintenance and monitoring activities). 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-8 September 2014 

The construction of a DTS and replacement at-reactor ISFSI would require a much smaller 

workforce than required for nuclear power plant construction or extended maintenance and 

refueling outages. As discussed in Section 3.2 of this GEIS, the construction workforce for an 

at-reactor ISFSI ranged from approximately 20 to 60 workers over approximately 1 year. The 

reference DTS is a two-level concrete and steel structure with an attached single-level, weatherresistant, pre-HQJLQHHUHGVWHHOEXLOGLQJRQKDDF:LWKUHJDUGWRWKHZRUNIRUFH

required for the construction of the DTS, the NRC reviewed a proposal to construct and operate 

a 3.2-ha (8-ac) spent fuel-transfer facility at the Idaho National Laboratory (NRC 2004a). The 

SURSRVDOHVWLPDWHGFRQVWUXFWLRQZRUNHUVZRXOGEHHPSOR\HGIRU years. Given that the 

Idaho National Laboratory facility is an estimated 80 times larger than the Transnuclear, Inc.-

Electric Power Research Institute (Transnuclear-EPRI) DTS design, the NRC estimates that no 

more than 60 to 80 short-term construction workers would be needed for between 1 to 2 years 

to build the DTS and at-reactor ISFSI pad. The construction workforce would likely be 

composed of local workers. Given the small number of workers, short construction timeframe, 

and the availability of housing, there would likely be no noticeable increase in the demand for 

permanent housing. 

Similar to short-term storage, a small number of workers (30–ZRXOGFRQWLQXHWRPDLQWDLQ

and monitor the storage of spent fuel in the at-reactor ISFSI. The ISFSI workforce requirements 

would remain unchanged from the period of reactor operations. Therefore, continued storage 

would not create any increased demand for housing or public services. In addition, activities 

associated with long-term storage are also not likely to affect local transportation conditions in 

the vicinity of the continued storage site. 

Similar to short-term timeframe, tax payments during the long-term timeframe would depend on 

a number of factors, including State tax law and established tax payment agreements with local 

tax authorities. Property tax and other payments, including the portion for continued at-reactor 

storage, would continue during the long-term timeframe. The replacement of the at-reactor 

ISFSI and construction, operation, and subsequent replacement of the DTS could be viewed as 

property improvements by local tax assessors causing the amount of the property tax payment 

to be increased. However, construction activities are expected to have a minor effect on the 

local economy. Nevertheless, even with the addition of a DTS, the amount of tax payments 

related to continued storage is not expected to significantly change during the long-term 

timeframe. 

As previously noted for short-term storage, regional socioeconomic conditions have become 

well established during the period of reactor operations for all nuclear power plants 

(NRC 2013a). By comparison, the contributory effect from long-term storage would be 

SMALL for all socioeconomic categories because (1) few workers will be required to maintain 

and monitor spent fuel storage, construct and operate a DTS, and replace the at-reactor ISFSI 

and DTS; (2) construction activities will be of short duration; (3) continued tax payments will 

remain relatively unchanged; and (4) there will be no increased demand for housing and public 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-9 185(*௅

services. Therefore, the NRC concludes that the socioeconomic impacts of continued storage 

during the long-term timeframe would be SMALL. 

4.2.3 Indefinite Storage 

This section describes the socioeconomic impacts if a repository is not available to accept spent 

IXHOIURPDQH[LVWLQJQXFOHDUSRZHUSODQWVLWH:LWKQRUHSRVLWRU\DYDLODEOHan at-reactor ISFSI 

would be continuously monitored and maintained. Impacts from indefinite storage would be 

similar to those described for long-term storage. The NRC assumes the ISFSI pads and DTS 

would be replaced every 100 years and that this would require a small workforce. Property tax 

revenue would remain relatively unchanged while spent fuel remains stored onsite. Therefore, 

the socioeconomic impacts of continued indefinite onsite storage would be SMALL. 

4.3 Environmental Justice 

This section describes the potential human health and environmental effects from the continued 

onsite storage of spent fuel in spent fuel pools and at-reactor ISFSIs on minority and lowincome populations living in the vicinity of nuclear power plant sites. 

The NRC strives to identify and consider environmental justice issues in agency licensing and 

regulatory actions primarily by fulfilling its NEPA responsibilities for these actions. Under 

([HFXWLYH2UGHU)5)HGHUDODJHQFLHVDUHUHVSRQVLEOHIRULGHQWLI\LQJDQG

addressing potential disproportionately high and adverse human health and environmental 

impacts on minority and low-income populations. Environmental justice refers to a Federal 

policy that ensures that minority, low-income, and tribal communities that have historically been 

excluded from environmental decision-making are given equal opportunities to participate in 

decision-making processes. 

In 2004, the Commission issued a Policy Statement on the Treatment of Environmental 

Justice 0DWWHUVLQ15&5HJXODWRU\DQG/LFHQVLQJ$FWLRQV)5ZKLFKVWDWHV37KH

Commission is committed to the general goals set forth in Executive Order 12898, and strives 

to meet those goals as part of its National Environmental Policy Act (NEPA) review process.” 

In addition, the Commission stated in its decision on the Private Fuel Storage (PFS) facility 

application that environmental jusWLFHDVDSSOLHGDWWKH15&3PHDQVWKDWWKHDJHQF\ZLOOPDNH

an effort under NEPA to become aware of the demographic and economic circumstances of 

local communities where nuclear facilities are to be sited, and take care to mitigate or avoid 

special impacts attributable to the special character of the community” (NRC 2002a, 2004b). 

The NRC normally addresses environmental justice issues and concerns by first identifying 

potentially affected minority and low-income populations and then determining whether there 

would be any potential human health or environmental effects and whether these effects may be 

disproportionately high and adverse in site-specific licensing actions. Adverse health effects are 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-10 September 2014 

measured in terms of the risk and rate of fatal or nonfatal adverse impacts on human health. 

Disproportionately high and adverse human health effects occur when the risk or rate of 

exposure to an environmental hazard for a minority or low-income population is significant and 

exceeds the risk or exposure rate for the general population or for another appropriate 

comparison group. Disproportionately high environmental effects refer to impacts or risks of 

impacts on the natural or physical environment in a minority or low-income community that are 

significant and appreciably exceed the environmental impact on the larger community. 

Potential impacts on minority and low-income populations as the nuclear power plant transitions 

from reactor operations to decommissioning and continued storage would mostly consist of 

radiological (human health) and socioeconomic (environmental) effects. During continued 

storage, the incremental radiation dose from spent fuel stored in spent fuel pools and at-reactor 

ISFSIs is expected to remain unchanged from the period of reactor operations and within 

UHJXODWRU\OLPLWVVHH6HFWLRQ5DGLRORJLFDODQGHQYLURQPHQWDOPRQLWRULQJSURJUDPV

similar to those implemented during nuclear power plant operations, would ensure that the 

radiation dose from continued spent fuel storage would remain within regulatory limits. In 

addition, socioeconomic conditions affected by the continued storage of spent fuel as they relate 

to minority and low-income populations living near nuclear power plant sites would remain 

unchanged. Because spent nuclear fuel is already being stored in spent fuel pools and ISFSIs 

(where available) at all commercial nuclear power plants in the United States, the continued 

storage of spent fuel would not create any new effect on minority and low-income populations 

beyond what is currently being experienced during reactor operations. 

As discussed in Section 3.3, the special pathway receptors analysis is an important part of the 

environmental justice analysis because consumption patterns may reflect the traditional or 

cultural practices of minority and low-income populations in the area of the continued storage 

site, such as migrant workers or Native Americans. All NRC licensees have to assess the 

impact of facility operations on the environment through their radiological environmental 

monitoring programs (REMPs). These programs assess the effects of site operations on the 

environment that could affect special pathway receptors. However, once reactor operations 

cease, the REMP would be modified to consider only the potential sources of radiation and 

radioactivity that may be released from a spent fuel pool or an at-reactor ISFSI. Air monitoring, 

thermoluminescent dosimeters, and groundwater monitoring would likely be used to detect 

releases from the spent fuel pools and at-reactor ISFSI, but collection of other environmental 

sampling data would depend on site-specific conditions (e.g., proximity to surface waterbody). 

In most cases, NRC environmental justice analyses are limited to evaluating the human health 

effects of the proposed licensing action and the potential for minority and low-income 

populations to be affected. As explained in the Commission’s policy statement, environmental 

justice-related issues as well as demographic conditions (i.e., the presence of potentially 

affected minority and low-income populations) differ from site to site, and environmental justice 

issues and concerns usually cannot be resolved generically with regard to NRC licensing 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-11 185(*௅

actions. Consequently, environmental justice, as well as other socioeconomic issues, is 

normally considered in site-VSHFLILFHQYLURQPHQWDOUHYLHZV)5 However, the NRC 

has determined that a generic analysis of the human health and environmental effects of 

continued storage on minority and low-income populations is possible, because minority and 

low-income populations are not expected to experience disproportionately high and adverse 

human health and environmental effects from the continued storage of spent fuel. 

As previously stated in Chapters 2 and 3, this GEIS and the Rule are not licensing actions and 

do not authorize the continued storage of spent fuel. The environmental analysis in this GEIS 

fulfills a small part of the NRC’s NEPA obligation with respect to the licensing or relicensing of a 

nuclear reactor or spent fuel storage facility. Further, for site-specific licenses, the NEPA 

analysis would include consideration of environmental justice prior to any NRC licensing action. 

As with other resource areas, a site-specific analysis allows the NRC to make an impact 

determination for each NRC licensing action. A generic determination of the human health and 

environmental effects during continued storage is possible because the NRC has evaluated how 

environmental effects change when a nuclear power plant site transitions from reactor 

operations to decommissioning. Based on this knowledge, the NRC can provide a generic 

assessment of the potential human health and environmental effects during continued storage. 

4.3.1 Short-Term Storage 

As previously explained in Section 4.2.1, the socioeconomic effects of reactor operations have 

become well established because regional socioeconomic conditions will have adjusted to the 

presence of the nuclear power plant (NRC 2013a). After the cessation of reactor operations, a 

small number of workers (20–ZRXOGFRQWLQXHWRPDLQWDLQDQGPRQLWRUVSHQWIXHOSRROV

These workers would also transfer spent fuel from the spent fuel pools to an at-reactor ISFSI. 

Once all of the spent fuel is transferred from the spent fuel pools to dry cask storage, spent fuel 

pool storage operations worker positions would be eliminated. For at-reactor ISFSIs, a small 

number of workers (30–ZRXOGEe needed to maintain and monitor the ISFSI. Consequently, 

socioeconomic impacts due to continued storage would be unchanged in comparison to the 

period of reactor operations for minority and low-income populations. 

Generally, the continued maintenance and radiological monitoring associated with spent fuel 

storage, either in spent fuel pools or at-reactor ISFSIs, during the short-term timeframe ensures 

that any human health and environmental effects would remain within regulatory limits for the 

general population. Based on a review of recent REMP reports, human health impacts would 

not be expected in special pathway receptor populations living near a nuclear power plant site 

as a result of subsistence consumption of water, local food, fish, and wildlife during the 

short-term timeframe. A modified REMP would remain in effect after the nuclear power plant 

ceases operations through the short-term timeframe. Monitoring would confirm that radiological 

doses would remain within regulatory limits and minority and low-income populations would 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-12 September 2014 

experience no new human health and environmental effects during the short timeframe beyond 

what had already been experienced during reactor operations. 

As discussed for the other resource areas in Chapter 4, overall human health and 

environmental effects from continued storage during the short-term timeframe would be limited 

in scope and SMALL for all populations. Therefore, minority and low-income populations are 

not expected to experience disproportionately high and adverse human health and 

environmental effects during this timeframe. In addition, as indicated in the Commission’s policy 

statement, environmental justice impacts would also be considered during site-specific 

environmental reviews for specific licensing actions (69 FR 

4.3.2 Long-Term Storage 

In addition to monitoring and maintenance, long-term storage includes the construction and 

operation of a DTS and replacement of the at-reactor ISFSI and DTS. Construction and 

operation of a DTS would constitute a Federal action under NEPA and site-specific analysis 

would include an analysis of the potential effects on minority and low-income populations. 

NRC environmental justice analyses are generally limited to evaluating the human health and 

environmental effects of the proposed licensing action and the potential for minority and lowincome populations to be disproportionately affected. As stated in the NRC policy statement, 

environmental justice assessments would be performed as necessary in the underlying 

OLFHQVLQJDFWLRQIRUHDFKSDUWLFXODUIDFLOLW\)5'76OLFHQVHUHYLHZVZRXOGQRWUHO\

on the analysis in this GEIS, because the site-specific NEPA analysis would consider the sitespecific impacts on minority and low-income populations. 

Potential impacts on minority and low-income populations from the construction, operation, and 

replacement of the DTS and at-reactor ISFSI would mostly consist of environmental and 

socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and housing 

impacts). Noise and dust impacts during construction would be short term and primarily limited 

to onsite activities. Minority and low-income populations residing along site access roads could 

be directly affected by increased commuter vehicle and truck traffic. However, because of the 

temporary nature of construction and the relatively low numbers of workers (60–80 short-term 

construction workers), these effects are likely to be minimal and limited in duration. Increased 

demand for rental housing during construction could cause rental costs to rise temporarily, 

disproportionately affecting low-income populations living near the site who rely on inexpensive 

housing. However, given the short duration of construction (1–2 years), the relatively small 

number of workers needed, and the proximity of some nuclear power plant sites to metropolitan 

areas, it is expected that many of the workers would commute to the construction site, thereby 

reducing the need for rental housing. Based on this information and the analysis of human 

health and environmental impacts presented in this chapter, the construction of the DTS and 

replacement of the ISFSI would not have disproportionately high and adverse human health and 

environmental effects on minority and low-income populations. Similar to the short-term 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-13 185(*௅

storage, a small number of workers (30–ZRXOGEHQHHGHGWRPDLQWDLQDQGPRQLWRUWKH

at-reactor ISFSI after cask transfers to the replacement facility. Consequently, employment 

opportunities, although reduced from reactor operations, would remain unaffected for minority 

and low-income populations. Based on this information, there would be no disproportionately 

high and adverse human health and environmental effects on minority and low-income 

populations from the construction and operation of the DTS and replacement of the DTS and 

at-reactor ISFSI. 

For long-term spent fuel storage, REMPs, similar to those implemented during nuclear power 

plant operations and short-term storage, would ensure that the radiation dose from DTS 

operations and continued spent fuel storage would remain within regulatory limits. Similar to 

short-term storage, a modified REMP would be in place to confirm that radiological doses 

remain within regulatory limits and minority and low-income populations would experience no 

new human health and environmental effects during the long-term timeframe beyond those 

experienced during reactor operations. 

The continued maintenance and monitoring of spent fuel in at-reactor ISFSIs would have 

minimal human health and environmental effects on minority and low-income populations near 

these storage facilities. As discussed for the other resource areas in Chapter 4, overall human 

health and environmental effects from continued storage during the long-term timeframe would 

be limited in scope and SMALL for all populations, except for historic and cultural resources 

where impacts could be SMALL to LARGE. Long-term storage impacts on historic and cultural 

resources are discussed in Section 4.12. The magnitude of adverse effects on historic 

properties and the impacts on historic and cultural resources during the long-term timeframe 

largely depend on where the facilities are sited, what resources are present, the extent of 

proposed land disturbance, if the area has been previously surveyed to identify historic and 

cultural resources, and if the licensee has management plans and procedures that are 

protective of historic and cultural resources. Before ground-disturbing activities occur, the sitespecific environmental review and compliance with the NHPA process could identify historic 

properties and historic and cultural resources that could be impacted. Thus, the potential 

impacts on historic and cultural resources could be SMALL to LARGE. However, measures 

such as implementation of historic and cultural management resource plans and procedures, 

agreements, and license conditions can be used to avoid, minimize, or mitigate adverse effects 

on historic properties and impacts on historic and cultural resources. Based on this information, 

minority and low-income populations are not expected to experience disproportionately high and 

adverse human health and environmental effects from the continued long-term storage of spent 

fuel. In addition, as indicated in the Commission’s policy statement )5, 

environmental justice impacts would also be considered during site-specific environmental 

reviews for specific licensing actions. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-14 September 2014 

4.3.3 Indefinite Storage 

This section describes the environmental impacts on minority and low-income populations if a 

repository LVQRWDYDLODEOHWRDFFHSWVSHQWIXHO:LWKQRUHSRVLWRU\DYDLODEOHan at-reactor ISFSI 

would be continuously monitored and maintained. Impacts from indefinite onsite storage would 

be similar to those described in Section 4.3.2. 

The continued maintenance and monitoring of spent fuel would have minimal human health and 

environmental effects on minority and low-income populations living near at-reactor ISFSIs. As 

discussed for the other resource areas in Chapter 4, overall human health and environmental 

effects from continued storage during the indefinite timeframe would be limited in scope and 

SMALL for all populations, except for nonradioactive waste generation and disposal and historic 

and cultural resources where impacts could be SMALL to MODERATE or SMALL to LARGE, 

respectively. The magnitude of adverse effects on historic properties and impacts on historic 

and cultural resources during the long-term timeframe largely depend on where the facilities are 

sited, what resources are present, the extent of proposed land disturbance, if the area has been 

previously surveyed to identify historic and cultural resources, and if the licensee has 

management plans and procedures that are protective of historic and cultural resources. Before 

ground-disturbing activities occur, the site-specific environmental review and compliance with 

the NHPA process could identify historic properties and historic and cultural resources that 

could be impacted. Regardless, minority and low-income populations are not expected to 

experience disproportionately high and adverse human health and environmental effects from 

the indefinite storage of spent fuel. In addition, as indicated in the Commission’s policy 

statement (69 FR , environmental justice impacts would also be considered during sitespecific environmental reviews for specific licensing actions. 

4.4 Air Quality 

This section describes impacts on air quality caused by continued storage in spent fuel pools 

and at-reactor ISFSIs. Because there would be no increase in emissions during continued 

storage, the requirements for a conformity determination under 40 CFR Part 93 do not apply to 

the operation of a spent fuel pool or an at-reactor ISFSI. The requirements for a conformity 

determination with respect to the replacement of an ISFSI and the construction, operation, and 

replacement of a DTS are considered in the long-term storage section (see Section 4.4.2). 

4.4.1 Short-Term Storage 

Once reactor operations cease and continued storage begins, most pollutant-generating 

activities at the nuclear power plant site would either cease or continue at lower levels. 

Therefore, as described below, the environmental impacts on air quality during continued 

storage would be less than the impacts during reactor operations. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

The License Renewal GEIS concluded that impacts for continued power-generation operations 

in attainment, nonattainment, and maintenance areas are SMALL for all plants, at least in part 

because licensees would be required to operate within State permit requirements (NRC 2013a). 

Specifically, the License Renewal GEIS analyzes a number of specific activities related to 

continued power-generation operations that result in emissions of air pollutants. These include 

testing of emergency diesel generators, use of fossil-fuel boilers (for evaporator heating, plant 

space heating, and feed water purification), testing of fossil-fuel-fired fire pumps, cooling-tower 

drift, and transmission-OLQHHPLVVLRQV:KHQWKHQXFOHDUSRZHUSODQWFHDVHVRSHUDWLRQVDQGWKH

site enters the short-term storage timeframe, many of these activities will also cease. For 

example, testing requirements may be reduced or eliminated for emergency diesel generators, 

which are no longer needed to maintain and restore reactor core or spent fuel pool cooling once 

the reactor is permanently shutdown. Also, cooling towers would no longer be rejecting up to 

two-thirds of the thermal power of a reactor, which would dramatically reduce cooling-tower drift. 

Because emissions of air pollutants resulting from continued storage of spent fuel in either spent 

fuel pools or at-reactor ISFSIs would be substantially smaller than air emissions during power 

generation, air quality impacts from continued storage would also be minor. 

Routine maintenance and monitoring activities at the at-reactor ISFSI would occur during shortterm storage. Because dry cask storage systems do not have active systems (e.g., diesel 

generators), these activities would not involve significant releases of air pollutants. 

Thermal releases from the at-reactor ISFSI can cause localized atmospheric heating. 

Downwind from an at-reactor ISFSI storing 1,600 MTU, it is estimated that ambient temperature 

changes would not be noticeable (i.e., the temperature would increase no more than qC 

>0.09qF@) at 1 km (0.6 mi) from the site (NRC 1984). Temperature changes this small could not 

be differentiated from temperature changes that naturally occur, such as from passage of the 

sun throughout the day and passing clouds. Over time, the spent fuel in the casks will cool and 

less heat will be released resulting in less local atmospheric heating. The heat released by 

storing dry casks on the surface should be distinguished from the greenhouse gas emissions 

GLVFXVVHGLQ6HFWLRQRIWKLV*(,6+HDWUHOeased from a dry cask is a local phenomenon, 

whereas greenhouse gases released into the atmosphere potentially contribute to impacts 

beyond the local environment. 

Because emissions of air pollutants resulting from short-term continued storage of spent fuel 

would be substantially smaller than air emissions during power generation, which was 

determined to have SMALL impacts in the License Renewal GEIS, the NRC concludes the 

impacts associated with continued spent fuel storage would be SMALL for all location 

classifications (i.e., attainment, nonattainment, and maintenance). Further, the impact from heat 

released to the atmosphere from ISFSIs would be SMALL because the small variations in 

downwind temperatures caused by heat released from the ISFSI could not be differentiated 

from natural temperature fluctuations. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-16 September 2014 

4.4.2 Long-Term Storage 

As noted in Section 1.8, all the spent fuel would be moved out of the spent fuel pool and into 

at-reactor dry cask storage by the beginning of this timeframe. Routine maintenance and 

monitoring activities at the at-reactor ISFSI would continue during long-term storage. Because 

dry cask storage systems do not have active systems (e.g., diesel generators), these activities 

would not involve significant releases of air pollutants. As described in Section 1.8.3, the NRC 

assumes that the ISFSI needs to be replaced and the fuel repackaged during this timeframe. 

To facilitate the transfer of the spent fuel to new casks, the NRC also assumes that a DTS is 

constructed and replaced once during the long-term storage timeframe. 

The construction and replacement of a DTS would involve onsite fabrication involving heavy 

equipment (earthmoving, concrete batch plant, cranes, etc.), which would cause emissions of 

air pollutants. Given the relatively smaller size of the DTS compared to an at-reactor ISFSI, the 

time, materials, and equipment required to build the DTS would be no more than those used to 

construct an ISFSI. The NRC previously determined that the environmental impact on air 

quality from construction of the Diablo Canyon ISFSI, which would hold up to 140 dry storage 

casks from two reactors on a 2-KD-ac) site and would be larger than the reference DTS, 

would be minimal (NRC 2003). Therefore, the air emissions and impacts on air quality for 

construction and replacement of the DTS would also be minimal. The DTS relies on electrical 

power for operations. As a result, there are no routine emissions of air pollutants from the DTS 

during operations, such as might occur from a boiler or diesel generator. A diesel generator 

could be used as a source of backup electrical power. Testing and use of a backup diesel 

generator would be infrequent and would cause emissions no greater than those caused by 

emergency diesel generators at operating nuclear power plants, which are minor. 

Activities associated with ISFSI replacement and DTS operations, including cask repair, bare 

fuel handling as part of repackaging operations, and cask replacement, are expected to be of 

relatively short duration and limited extent in any year during long-term continued storage. 

These activities are likely to involve only a portion of the ISFSI, and in any year would likely 

involve only a fraction of the air emissions that were associated with initial construction of the 

at-reactor ISFSI. As a result, there may be temporary increases in levels of suspended 

particulate matter from construction and replacement activities. In addition, exhaust from 

vehicles would add to levels of hydrocarbons, carbon monoxide, and nitrogen oxides. However, 

these emissions of air pollutants are not expected to noticeably affect important attributes of air 

quality in the region. 

Previous NRC NEPA analyses for site-specific licensing actions support this conclusion for 

attainment, maintenance, and nonattainment areas. For example, the NRC analyzed the 

LPSDFWVRIFRQVWUXFWLQJDQGRSHUDWLQJDQ,6)6,DW+XPEROGW%D\15&DZKLFKLVORFDWHG

in an attainment area, and determined that the air quality impacts were SMALL. The NRC also 

analyzed the impacts of constructing and operating additional reactor units at existing nuclear 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

power plant sites such as Calvert Cliffs Unit 3 (NRC 2011a) and Fermi Unit 3 (NRC 2013b), 

which are located in nonattainment areas. In both examples, the NRC determined that the air 

impacts were SMALL, at least in part because licensees would be required to operate within 

State permit requirements. The level of activities and associated air emissions from long-term 

storage would not be greater than those for the construction and operation of another reactor 

unit at an existing power plant site. 

Emissions of air pollutants during ISFSI replacement and construction, operation, and 

replacement of a DTS would be well below de minimis levels in 40 CFR Part 93 and the 

requirements for a conformity determination would not apply. De minimis emission levels in 

40 CFR Part 93 are provided for each criteria pollutant and for different levels of nonattainment, 

but not all of these limits are relevant to at-reactor continued storage. No operating nuclear 

power plants are currently located in extreme, severe, or serious ozone nonattainment areas; in 

serious PM10 nonattainment areas; or in lead nonattainment areas. Therefore, the applicable 

de minimis annual emission rate for all operating nuclear power plants in nonattainment and 

maintenance areas is 100 T/yr for all criteria pollutants, except volatile organic compounds for 

plants within an ozone transport region, for which the de minimis OHYHOLV7\U15&D

The NRC estimated the peak annual emissions for preconstruction and construction of the 

HQWLUH)HUPL8QLWQXFOHDUSRZHUSODQWWREH7\UQLWURJHQR[LGHDQG7\UYRODWLOH

organic compounds (NRC 2013b), which is only slightly above de minimis levels. Because the 

DTS and ISFSI are only a small fraction of the size of an entire nuclear power plant, the 

emissions of air pollutants during ISFSI replacement and DTS construction and replacement 

would be well below de minimis levels. 

Thermal releases from storing dry casks on the surface would cause some local atmospheric 

heating. As described previously for short-term storage, this effect is not expected to be 

noticeable and would decrease during the long-term storage timeframe as decay heat in the 

ISFSI decreases over time. 

Emissions of air pollutants during long-term continued storage of spent fuel would be minimal, 

and the NRC concludes the impacts would be SMALL for all location classifications (i.e., 

attainment, nonattainment, and maintenance). The impact from heat released to the atmosphere 

from ISFSIs would be SMALL because the small variations in downwind temperatures would not 

be noticeable and would decrease throughout this period as decay heat diminishes. 

4.4.3 Indefinite Storage 

This section describes the environmental impacts on air quality if a repository never becomes 

available to accept spent fuel. Indefinite storage would consist of the same activities and result 

in the same impacts as those for long-term storage (Section 4.4.2), except that they would 

continue indefinitely into the future. Thermal releases from storing dry casks on the surface 

would cause some local atmospheric heating, which would continue to decrease as decay heat 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-18 September 2014 

from spent fuel diminishes. Therefore, the NRC concludes that the environmental impacts on 

air quality from indefinite storage due to air emissions and thermal releases would each be 

SMALL. 

4.5 Climate Change 

In this section, the NRC evaluates the effect of continued storage on climate change. The 

NRC’s evaluation of the effects of climate change on the intensity and frequency of natural 

phenomena hazards that may cause spent fuel storage accidents is provided in Section 4.18. 

4.5.1 Short-Term Storage 

This section describes greenhouse gas emissions related to short-term continued storage of 

spent fuel. The activities at a nuclear power plant during short-term continued storage involve 

the emission of greenhouse gases, primarily carbon dioxide (CO2). The quantities of 

greenhouse gas emissions are often described in terms of a CO2 footprint expressed as metric 

tons of CO2 equivalent. The NRC’s previous estimates of a reference reactor’s CO2 footprint 

during the decommissioning period include activities in addition to those related to continued 

storage of spent fuel. However, these estimates provide a reasonable upper bound on the 

CO2 footprint for short-term continued storage because the activities that occur as a direct result 

of continued storage would generate less CO2 than decommissioning activities. 

The NRC estimated the CO2 footprint for a reference 1,000-0:HUHDFWRUIRUD-year 

decommissioning period, assuming the licensee chooses the SAFSTOR decommissioning 

option (NRC 2013c). The greenhouse gas emissions resulting from the SAFSTOR 

decommissioning option would include all emissions of greenhouse gases that would be 

associated with the immediate decommissioning (or DECON) option, and also include the 

greenhouse gases that would be emitted by vehicles used by the caretaker workforce for the 

intervening 40-year period of SAFSTOR.2 Therefore, greenhouse gas emissions associated 

with the SAFSTOR option bound those associated with the DECON option. The NRC assumed 

that SAFSTOR lasts for 40 years and is followed by 10 years of major decommissioning 

activities. The predominant sources of greenhouse gas emissions during major 

decommissioning activities are fossil-fuel powered demolition equipment and worker 

transportation vehicles for the estimated 200 decommissioning workers (NRC 2013c). 

Continued storage activities at the spent fuel pool and at-reactor ISFSI do not involve significant 

sources of fossil-fuel consuming activities, other than the use of vehicles by the commuting 

 

2 In the third option, the ENTOMB option, radioactive systems, structures, and components are encased 

in a structurally long-lived substance, such as concrete. The entombed structure is appropriately 

maintained, and continued surveillance is carried out until the radioactivity decays to a level that permits 

termination of the license. No licensee has ever chosen the ENTOMB option, and it is not considered 

further in this GEIS. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-19 185(*௅

workforce, and the occasional use of onsite vehicles for inspection and maintenance of spent 

fuel storage facilities. Therefore, greenhouse gas emissions from decommissioning activities 

would be more than the greenhouse gas emissions associated with the smaller workforce 

responsible for continued storage. The CO2 footprint of decommissioning is on the order of 

,000 MT of CO2 equivalent (NRC 2013c), or an annual emission rate of about  MT, 

averaged over the period of decommissioning, compared to a total U.S. annual CO2 emissions 

rate of 6ELllion MT of CO2 equivalent in 2011 (EPA 2013). 

Based on its assessment of the relatively small short-term continued storage greenhouse gas 

footprint compared to the U.S. annual CO2 emissions, the NRC concludes that the atmospheric 

impacts of greenhouse gases from short-term continued storage would not be noticeable and 

would therefore be SMALL. 

4.5.2 Long-Term Storage 

This section describes the greenhouse gas production of continued storage during long-term 

continued storage. Over the long-term storage timeframe, sources of greenhouse gas 

emissions include vehicles used by the commuting workforce and workers conducting routine 

maintenance activities for the at-reactor ISFSI and construction and demolition equipment 

required to initially construct, and eventually replace, a DTS and to replace the at-reactor ISFSI. 

Given that activities at the site have been reduced to continued storage of spent fuel at the 

at-reactor ISFSI, the CO2 footprint for the commuting workforce would be no greater than that 

associated with the SAFSTOR workforce described previously. Using the greenhouse gas 

emission rate of 10,000 MT of CO2 equivalent over 40 years associated with the SAFSTOR 

option, this is approximately  MT of CO2 equivalent over the 100-year long-term storage 

timeframe (NRC 2013c). 

The NRC’s estimated CO2 footprint for a reference 1,000-0:HUHDFWRUSURYLGHVDXVHIXOXSSHU

bound for the CO2 footprint that would be associated with construction and replacement of the 

ISFSI and DTS, which are much smaller facilities. The CO2 footprint for construction equipment 

used to build a 1,000-0:HUHDFWRULVDERXW9,000 MT of CO2 equivalent. The CO2 footprint 

for decommissioning equipment used on a 1,000-0:HUHDFWRULVDERXW9,000 MT of 

CO2 equivalent (NRC 2013c). 

Combining the total CO2 footprints for the commuting workforce, construction and replacement 

activities, and averaging over the 100-year long-term storage timeframe, the annual 

CO2 footprint is estimated to be no more than 830 MT of CO2 equivalent, compared to a total 

U.S. annual CO2 emissions rate of 6ELOOLRQ MT of CO2 equivalent in 2011 (EPA 2013). Based 

on its assessment of the relatively small long-term continued storage greenhouse gas footprint 

compared to the U.S. annual CO2 emissions, the NRC concludes that the atmospheric impacts 

of greenhouse gases from long-term continued storage would not be noticeable and would 

therefore be SMALL
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-20 September 2014 

4.5.3 Indefinite Storage 

This section describes the greenhouse gas production of continued storage if a repository never 

becomes available to accept spent fuel. The main difference when compared to the impacts 

during long-term storage is that without a repository these activities would occur on an ongoing 

basis over a longer period of time so the total amount of emissions would be greater. However, 

the annual emission levels for the various phases would remain the same. 

The NRC concludes that the relative contribution from indefinite onsite storage of spent fuel to 

greenhouse gas emission levels would be SMALL based on the same considerations as those 

cited previously in the long-term storage section. 

4.6 Geology and Soils 

This section describes the potential environmental impacts on geology and soils caused by the 

continued onsite storage of spent fuel. 

4.6.1 Short-Term Storage 

Continued spent fuel pool operation is not anticipated to increase impacts on the local geology 

and soils. However, spent fuel pool leaks could result in radiological contamination of offsite 

soils. The degree of contamination of offsite soils would depend on the rate of release from the 

spent fuel pool, the direction of groundwater flow, the distance to offsite locations, and the 

velocity or transport rates of radionuclides through soils and radioactive decay rates. 

Contamination in groundwater is likely to be observed as part of a licensee’s REMP prior to the 

contamination plume reaching the offsite environment, and corrective action would be taken 

consistent with Federal and State requirements. In addition, most radionuclides are likely to be 

absorbed by the concrete structures of the spent fuel building and by the soil surrounding the 

leak location. As a result, the NRC expects that most soil contamination from spent fuel pool 

leaks would remain onsite and, therefore, offsite soil contamination is unlikely to occur. 

Therefore, the NRC concludes that the environmental impact of spent fuel pool leaks to offsite 

soils (i.e., outside the power plant’s exclusion area) would be SMALL. Appendix E contains 

additional information regarding the analysis of the impacts of spent fuel pool leaks on soils. 

Continued ISFSI operation is not expected to affect the underlying geology because ISFSIs 

have no moving parts to affect the subsurface (see e.g., NRC 2012a). Although soils may be 

affected by spills and leaks of radiological and hazardous materials, ISFSIs are designed to 

prevent leakage and licensee employees conduct routine inspections to verify that the ISFSIs 

are performing as expected. Leaks could result in spills of oil and hazardous material from 

operating equipment and stormwater runoff carrying grease. However, these activities are 

monitored and, in the case of stormwater runoff, regulated under National Pollutant Discharge 

Elimination System (NPDES) permit requirements (NRC 2002b). 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-21 185(*௅

Because no new land would be disturbed for the continued operation and maintenance of the 

existing pool and ISFSI and the impacts from spent fuel leaks to offsite soils would be SMALL, 

the NRC concludes that the continued storage of spent fuel during short-term storage on 

geology and soils would be SMALL.

4.6.2 Long-Term Storage 

During the long-term storage timeframe, routine maintenance and monitoring of the ISFSI would 

continue. Similar to short-term storage, the operation of any ISFSI is not anticipated to have 

any additional impacts on soils beyond those associated with construction. 

The construction of a DTS is anticipated to have minimal impacts on soils due to the small size 

RIWKH'76ZKLFKLVDERXWKDDF7KHW\SHVRILmpacts on soils from construction of a 

DTS would be similar to those anticipated for any power plant facility construction and would 

include soil compaction, soil erosion, and potential surface leaks of oils, greases, and other 

construction materials. Due to the relatively small size of the DTS, the impacts would be limited 

to the immediate area. Any laydown areas associated with construction would be reclaimed 

once the construction phase is complete. The GEIS also assumes that the ISFSI and DTS 

would require replacement and would occur on land near existing facilities. There would be no 

permanent increase in the overall area of land disturbed because the old facilities would be 

demolished and the land could be reclaimed. 

The construction and operation of the DTS, along with the replacement of the DTS and ISFSI 

facilities, would have minimal impacts on soils on the small fraction of the land committed for the 

facilities. There are no anticipated impacts on the geology of the area as the result of these 

activities. Therefore, the NRC concludes that the environmental impact on geology and soils 

would be SMALL during long-term storage.

4.6.3 Indefinite Storage 

In this section, impacts are evaluated assuming a repository does not become available. As 

previously noted, the ISFSI would require continued maintenance and monitoring. In addition, 

the ISFSI, storage casks, and DTS are assumed to be replaced every 100 years using a staged 

approach. As described above, no additional land would be required for these activities. At the 

end of the next 100-year cycle it is anticipated that the replacement of the ISFSI and DTS would 

occur on previously disturbed land, thereby minimizing impacts on soils. Given the temporary 

nature of the impacts on geology and soils, and the occurrence of the impacts within previously 

disturbed areas, the NRC concludes that the environmental impacts on geology and soils from 

the indefinite onsite storage of spent fuel would be SMALL. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-22 September 2014 

4.7 Surface-Water Quality and Use 

This section describes potential environmental impacts on the quality and consumptive use of 

surface water caused by continued storage of spent fuel in spent fuel pools and ISFSIs. 

4.7.1 Short-Term Storage 

During the short-term timeframe, most environmental impacts on surface-water resources will 

cease due to the end of reactor operations. For example, consumptive water loss per 

1,000 0:HIRUGLIIHUHQWFRROLQJV\VWHPVXVHGDWRSHUDWLQJSRZHUSODQWVUDQJHVIURP

 L/min (8,100 gpm) for plants that use once-WKURXJKFRROLQJV\VWHPWR/PLQ

(14,000 gpm) at plants with mechanical draft cooling towers (NRC 2013a). After permanent 

cessation of operations, the amount of heat rejected by these cooling systems would drop from 

over 10,000 BTU/hr to approximately the initial 40-BTU/hr decay heat load associated with 

cooling a spent fuel pool shortly after fuel is discharged from a reactor (EPRI 2002). Other 

potential impacts on surface-water resources would result from use of water to shield workers 

from radiation in the reactor area, continued stormwater management, and minor chemical 

VSLOOV:LWKPRUHWKDQSHUFHQWUHGXFWLRQLQWKHDPRXQWRIKHDWWREHGLVFKDUJHGDQGD

corresponding reduction in cooling-water demand, potential impacts from these activities would 

be significantly less severe than those associated with normal plant operation. The same 

activities described above also may affect surface-water quality. Surface waters are most likely 

to be affected by stormwater runoff, erosion, and by discharge of hazardous substances. 

However, these activities are monitored and regulated under NPDES permit requirements 

(NRC 2002b). 

4.7.1.1 Spent Fuel Pools 

As described above, because cooling-water demand would be significantly reduced after reactor 

operations have ceased, the NRC has determined that impacts on surface-water consumptive 

use from the continued storage of spent fuel in spent fuel pools will not be detectable or be so 

minor that they would not noticeably alter the water supply. 

Surface-water quality may be affected by groundwater contamination. The NRC has completed 

a review of its overall regulatory approach to groundwater protection (NRC 2011b). The NRC 

started this review in response to incidents of radioactive contamination of groundwater and 

soils at nuclear power plants. Contaminated groundwater at some sites may discharge to 

nearby surface waters, resulting in indirect effects on surface-water quality. The concentrations 

of radionuclides in offsite surface waters would depend on the rate of release from the spent 

fuel pool, direction and rate of groundwater flow, the distance to nearby offsite surface waters 

toward which groundwater flows, the velocity or transport rates of radionuclides through the 

subsurface, and radioactive decay rates. However, because surface waters in the vicinity of 

nuclear power plants are usually large to meet reactor cooling requirements, a large volume of 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-23 185(*௅

surface water is usually available to dilute groundwater contaminants that flow into the surface 

waterbody. This dilution results in contaminants that may have been present above applicable 

groundwater-quality standards being diluted well below limits considered safe. 

The NRC, in Appendix E, estimated an annual discharge rate for leakage from the spent fuel 

pool of 380 L/d (100 gpd) with contaminants at certain concentrations assumed to be present at 

the start of short-term storage. These concentrations were compared to annual effluent ranges 

IRU%:5VDQG3:5V(YHQLQWKHXQOLNHO\HYHQWWKDWVSHQWIXHOSRROOHDNDJHIORZHG

continuously (24 KRXUVSHUGD\GD\VSHU\HDUXQGHWHFWHGto local surface waters, the 

quantities of radioactive material discharged to nearby surface waters would be comparable to 

values associated with permitted, treated effluent discharges from operating nuclear power 

plants (see Table E-2). Based on the above considerations, the NRC concludes that the impact 

of spent fuel pool leaks on surface water would be SMALL. More information about the NRC’s 

analysis of the environmental surface-water-quality impacts of continued storage of spent fuel 

on nearby surface waters from groundwater contamination can be found in Appendix E of this 

GEIS. 

4.7.1.2 ISFSIs 

As passive, air-cooled storage systems, ISFSIs do not consume water and they generate 

minimal liquid effluents that may be discharged to surface waterbodies during normal operation. 

For example, in its consideration of water-use impacts for the renewal of the Calvert Cliffs 

ISFSI, the NRC determined that both direct and indirect impacts would be SMALL (NRC 2012a). 

This includes consideration of cask-loading operations and stormwater runoff carrying grease, 

oil, and spills from operating equipment that support the ISFSI. 

4.7.1.3 Conclusion 

Because short-term storage of spent fuel would use less surface water and have fewer activities 

that could affect surface-water quality than an operating reactor, which was previously 

determined to have a SMALL impact, and because leaks from spent fuel pools would have a 

SMALL impact on surface-water quality, the NRC concludes that impacts on surface-water 

quality and consumptive use during the short-term storage timeframe would each be SMALL. 

4.7.2 Long-Term Storage 

During long-term storage, there is no demand for surface water for routine maintenance and 

monitoring of an at-reactor ISFSI. In addition, as during short-term continued storage described 

above, water-quality impacts from ISFSI operations would be minimal. However, during 

long-term continued storage, there could be temporary consumptive use of surface water for 

demolishing and replacing the ISFSI and constructing and eventually replacing a DTS. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-24 September 2014 

During ISFSI demolition, a small amount of water could be sprayed from water trucks to 

minimize dust clouds. Additional water may be required to make concrete to replace facilities. 

For example, it would require about 380,000 L (100,000 gal) of water to make the concrete to 

replace an entire 46 × P×IWISFSI pad that is 1 m (3 ft) thick. A comparable 

amount could be required to replace dry cask storage system components, such as storage 

casks. If the activity were to take several months to complete, the average daily consumptive 

water use would be a few thousand gallons, which is less than the consumptive water loss 

estimated for an operating reactor for 1 minute (NRC 2013a). Therefore, the consumptive 

water-use impacts for demolishing and replacing the ISFSI would be minimal. 

The NRC assumes that a DTS would need to be constructed and replaced during the long-term 

storage timeframe. The construction and operation of a DTS involves very little temporary 

consumptive use of water. :KLOHsome water would be required for construction of the DTS 

concrete basemat and shell, it is expected that ready-mix concrete would be used and supplied 

by commercial vendors. Given the relatively small size of the DTS compared to an ISFSI, less 

water would be required to build the DTS than would be used to construct the ISFSI. During 

operations, water would be brought to the facility by tanker truck or temporary connection to 

public water supply for general purpose cleaning and canister decontamination. Additional 

water might be consumed by activities such as drinking, conducting personal hygiene, and 

disposing of sewage. 

The NRC concludes that the potential consumptive use and surface-water quality impacts from 

continued ISFSI operations would be minimal. Consumptive use of surface water for ISFSI 

replacement and DTS construction, operation, and replacement would involve amounts of water 

that are a small fraction of water use during reactor operations. Therefore, the NRC concludes 

that the potential impacts on surface-water use and quality for the long-term storage timeframe 

would be SMALL. 

4.7.3 Indefinite Storage 

If no repository becomes available, storage of spent fuel would continue indefinitely. As a 

result, the potential impacts on surface-water resources would be similar to those described for 

long-term storage (see 6HFWLRQEHFDXVHWKHVDPHDFWLYLWLHVZRXOGrecur. Every 

100 years, surface water would be required for demolishing and replacing the ISFSI and DTS. 

This additional consumptive use would be temporary. Therefore, the NRC concludes that the 

potential impacts on surface-water use and quality for the indefinite storage of spent fuel would 

each be SMALL. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

4.8 Groundwater Quality and Use 

This section describes the potential environmental impacts on groundwater water quality and 

consumptive use caused by continued storage of spent fuel in spent fuel pools and at-reactor 

ISFSIs. 

4.8.1 Short-Term Storage 

During short-term storage, most groundwater consumptive-use and quality impacts that had 

been caused by reactor operations would cease. Groundwater withdrawals may continue at 

some reactor sites during short-term storage because groundwater may be pumped for potable 

water, sanitary uses, and maintenance of spent fuel pools. This usage would likely be at a 

much reduced rate compared to normal reactor operations at the site. At other sites, offsite 

public water sources or onsite groundwater could also be used. This shift in usage would likely 

coincide with the reduction and eventual elimination of surface-water withdrawals, when they 

are no longer needed to support reactor cooling. However, surface-water resources may be 

used for some activities at some sites. Dewatering systems (e.g., foundation sumps, 

underdrains, and wells) to control high water tables, seepage of water into the subgrade of 

structures, or for hydraulic containment of contaminants may also remain active during 

decommissioning. 

The NRC determined in the License Renewal GEIS that consumptive use of groundwater during 

reactor operation would be SMALL because groundwater supplies are commonly not used or 

are used as a backup water source. During normal reactor operations, at most reactors, the 

withdrawal rate from production aquifers is kept below 380 L/min (100 gpm) to avoid 

groundwater-XVHFRQIOLFWV15&D:KHQUHDFWRURSHUDWLRQVFHDVHWKHXVHRI

groundwater is greatly reduced, especially at sites where reactor operations use groundwater as 

DEDFNXSZDWHUVRXUFHHJ+%5RELQVRQ6WHDP(OHFWULF3ODQW>15&E@, because 

cooling-water system demands are substantially lower after the facility is shut down and spent 

fuel is removed from the reactor vessel (NRC 2002b). 

4.8.1.1 Spent Fuel Pools 

Because consumptive water-use impacts on groundwater resources during short-term storage 

of spent fuel in spent fuel pools would be significantly less than during normal reactor operation, 

the resultant impacts on groundwater at offsite wells would be nondetectable or so minor that 

they would not noticeably alter groundwater resources. As a result, the NRC has made a 

generic conclusion that the consumptive water-use impacts on groundwater resources during 

short-term storage of spent fuel in spent fuel pools would be minor or minimal. 

Continued short-term storage of spent fuel in spent fuel pools could result in radiological 

impacts on groundwater quality. As discussed in Appendix E, in the unlikely event that a leak 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-26 September 2014 

from a spent fuel pool goes undetected and the resulting groundwater plume reaches the offsite 

environment, it is possible that the leak could be of sufficient magnitude and duration to 

contaminate a groundwater source above a regulatory limit (e.g., a maximum contaminant level 

for one or more radionuclides). The NRC acknowledges that should offsite groundwater 

contamination occur, the radiological impacts on groundwater quality resulting from a spent fuel 

pool leak during the short-term timeframe could noticeably alter, but not destabilize a 

groundwater resource. 

However, the impacts of a spent fuel pool leak on offsite groundwater receptors depend on 

many factors, including the volume and rate of water released from the spent fuel pool, the 

radionuclide content and concentration and water chemistry of the spent fuel pool water, the 

direction of groundwater flow, the distance to an offsite groundwater receptor, the velocity or 

transport rates of radionuclides through the subsurface, and radioactive decay rates. Further, 

as discussed in Appendix E, spent fuel pool design (e.g., stainless-steel liners and leakagecollection systems) and operational controls (e.g., monitoring and surveillance of spent fuel pool 

water levels) make it unlikely that a leak will remain undetected long enough to exceed any 

regulatory requirement (e.g., the NRC dose limit or U.S. Environmental Protection Agency 

>EPA@-mandated Maximum Contaminant Level) in the offsite environment. Although a small 

number of spent fuel pool leaks have caused radioactive liquid releases to the environment, 

based on the available data, none of these releases have affected the health of the public 

(NRC 2006a). In addition, licensees have implemented onsite groundwater monitoring 

programs that satisfy the requirements of &)5. Performing onsite groundwater 

monitoring throughout the short-term storage timeframe, in conjunction with other onsite and 

offsite radiological monitoring conducted as part of a licensee’s REMP, will allow licensees to 

detect radiological contamination in the event of a spent fuel pool leak, and should facilitate 

detection of a leak in sufficient time to prevent the offsite migration of contamination at levels 

that could exceed regulatory requirements (e.g., the NRC dose limit or EPA-mandated 

Maximum Contaminant Level). In addition, a variety of physical processes associated with 

radionuclide transport (see Section E.2.1.2) and hydrologic characteristics associated with 

typical nuclear power plant settings (see Section E.2.1.3) would act to mitigate the impacts from 

the offsite migration of future spent fuel pool leakage. These physical processes and hydrologic 

characteristics include radionuclide adsorption, dilution, and decay; delayed transport times due 

to relatively flat hydraulic gradients in the shallow water tables, lengthy distance to local 

groundwater users, and the likelihood that local groundwater usage is in deeper confined 

aquifers, respectively. Further, current and future spent fuel pool sites are required to have 

routine REMPs in place that should take samples at offsite groundwater sources (e.g., potable 

or irrigation) in areas where the hydraulic gradient or recharge properties are suitable for 

contamination (NRC 1991a,b). Finally, any detection of onsite contamination would likely result 

in additional monitoring, including additional sampling of any nearby private wells, as part of an 

H[SDQGHGHQYLURQPHQWDOPRQLWRULQJSURJUDP:LWKWKHVHPHDVXUHVDQGFKDUDFWHULVWLFVLQ

place, it is unlikely that offsite migration of spent fuel pool leaks will occur or go undetected. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

Based on these factors, the NRC concludes that the radiological impacts on groundwater quality 

resulting from a spent fuel pool leak during the short-term timeframe would be SMALL. 

The NRC is aware that unintentional releases of nonradiological hazardous substances have 

infrequently occurred after reactors shut down. Except for a few substances (e.g., diesel fuel), 

surface spills of hazardous substances that might lead to groundwater contamination are often 

localized, quickly detected, and relatively easy to remediate (NRC 2002b). During the shortterm timeframe, the licensee will decommission the site, which will result in the ultimate cleanup 

of the portions of the reactor facility that are not needed for continued short-term storage in a 

spent fuel pool. In addition, permit requirements (e.g., NPDES permit) and the requirements for 

compliance with the Resource Conservation and Recovery Act (RCRA) and the Safe Drinking 

:DWHU$FWZRXOGPLQLPL]HSRWHQWLDOULVNVIRUQRQUDGLRORJLFDOFRQWDPLQDWLRQHQWHULQJ

groundwater during short-term spent fuel storage in spent fuel pools. 

Therefore, the NRC concludes that during short-term storage, the nonradiological impacts on 

groundwater quality would be minimal. 

4.8.1.2 ISFSIs 

ISFSIs, which are passive systems, consume minimal water and generate minimal 

nonradiological liquid effluents during normal operation (see e.g., NRC 2012a). The only 

potential impact on groundwater quality from operating an ISFSI consists of the infiltration of 

stormwater runoff carrying grease and oil, and spills from operating equipment that supports the 

ISFSI. Because ISFSI storage requires minimal water and produces minimal, localized, and 

easy-to-remediate liquid effluents on or near the ground surface, ISFSI storage impacts on 

groundwater quality and use would not be detectable or would be so minor that they would not 

noticeably alter groundwater resources. As a result, the NRC concludes that the potential 

consumptive water-use and quality impacts on groundwater during ISFSI storage of nuclear 

fuels would be minimal. 

4.8.1.3 Conclusion 

Based on the discussion above, the NRC concludes that consumptive water-use impacts on 

groundwater resources during short-term storage of spent fuel in spent fuel pools and at-reactor 

ISFSIs would be SMALL. For groundwater quality, the NRC concludes that radiological and 

nonradiological impacts during the short-term storage of spent fuel in pools and ISFSIs would 

be SMALL. 

4.8.2 Long-Term Storage 

The consumptive water use associated with routine maintenance and monitoring of the ISFSI 

discussed for short-term storage would continue during long-term storage. In addition, the NRC 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-28 September 2014 

assumes that a DTS would need to be constructed and operated during long-term storage. The 

construction and operation of a DTS involves very little consumptive use of groundwater. 

Concrete used for construction of the basemat and shell would likely arrive ready mixed and 

would not require additional water. For example, the NRC previously identified that little or no 

water would be consumed by the construction of the Calvert Cliffs and Prairie Island ISFSIs 

(NRC 1991c, 1992). Because the size of the DTS would be small compared to an ISFSI, less 

water would be required to construct the DTS than would be used to construct the ISFSI. 

During DTS operations, water would be brought to the facility by tanker truck or temporary 

connection to public water supply for general purpose cleaning and canister decontamination. 

Additional water might be consumed by activities such as drinking, conducting personal 

hygiene, and disposing of sewage. 

The impacts on groundwater quality from the operation of the ISFSI during long-term storage 

would be similar to the impacts discussed previously for short-term storage (Section 4.1.1). 

:KLOHRSHUDWLRQRIWKH'76GRHVFRQVXPHZDWHUQRJURXQGZDWHUTXDOLW\DIIHFWLQJGLVFKDUJHV

are expected. Therefore, the consumptive groundwater-use and quality impacts from 

construction of the DTS and operation of the ISFSI, including the DTS would be minimal during 

long-term storage. 

:LWKUHJDUGWR,6)6,DQG'76UHSODFHPHQWDFWLYLWLHVWKHFRQVXPSWLYH-use and groundwaterquality impacts would be similar to those associated with initial construction of the ISFSI. For 

example, the NRC staff determined that construction of the Calvert Cliffs and Prairie Island 

ISFSIs (NRC 1991c, 1992) would have negligible to no impacts on water resources. Similarly, 

the groundwater-quality and consumptive-use impacts associated with ISFSI and DTS 

replacement activities during long-term storage would be minor. 

Because the potential impacts on groundwater water quality and consumptive water uses during 

long-term storage would be similar to the impacts during short-term dry storage, the NRC 

concludes that the impacts on groundwater quality and consumptive use associated with the 

long-term storage of spent fuel in an at-reactor ISFSI would be SMALL. 

4.8.3 Indefinite Storage 

If no repository becomes available, storage of spent fuel in an ISFSI would continue indefinitely. 

As a result, the potential impacts on groundwater resources would be similar to those described 

for long-term storage (Section 4.8.2) because the same activities would be happening at the 

storage site. Every 100 years, groundwater may be required for demolishing and replacing the 

ISFSI and DTS. This additional consumptive use would be temporary. Therefore, the NRC 

concludes that the potential impacts on groundwater use and quality if a repository is not 

available would each be SMALL. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-29 185(*௅

4.9 Terrestrial Resources 

This section describes potential environmental impacts on terrestrial resources caused by the 

continued storage of spent fuel in spent fuel pools and at-reactor ISFSIs. 

As explained in Section 3.8, a wide variety of terrestrial habitats are present at nuclear power 

plant sites, which include spent fuel pools and at-reactor ISFSIs. The generic environmental 

impact analyses in this section consider both existing generic analyses and site-specific 

analyses that the NRC completed for licensing and relicensing of nuclear power plants and 

ISFSIs. The significance of potential impacts on plants and animals and their habitats depends 

on the importance or role of the plant or animal within the ecological community that is affected.

4.9.1 Short-Term Storage 

During the short-term storage timeframe, many activities that occurred during the operation of 

the reactor that could affect terrestrial resources would cease. However, terrestrial resources 

will likely continue to be affected during this timeframe by the continued operation of the spent 

fuel pool cooling system, and by the operation and maintenance of systems and structures at 

the nuclear power plant site and the at-reactor ISFSI. 

4.9.1.1 Spent Fuel Pools 

The following discussion describes the impacts of spent fuel pool operations during short-term 

storage, using the impact analyses from the License Renewal GEIS to inform the NRC’s 

analysis of these impacts during short-term storage. Operation of a spent fuel pool and its 

associated cooling system during short-term storage would require the withdrawal of water and 

discharge of effluents into a nearby waterbody. The NRC evaluated the effects of the continued 

operation of nuclear power plants, which included the operation of associated spent fuel pools, 

on terrestrial resources in the License Renewal GEIS (NRC 2013a). The NRC then looked at 

the systems that would be needed to cool the spent fuel pool during short-term storage, and 

compared the impacts associated with water use during operations and water use after the end 

of operations.

Water-Use Conflicts with Terrestrial Resources at Plants with Cooling Ponds or Cooling 

Towers Using Makeup Water from a River 

:DWHUIURPQHDUE\ODNHVULYHUVDQGRFHDQVis needed for both closed and once-through 

cooling systems. :DWHU-use conflicts with terrestrial resources could occur if water from a single 

waterbody is required to simultaneously cool a spent fuel pool and support other water users 

such as agricultural, municipal, or industrial users. A conflict could arise if the surface-water 

resource is diminished because of decreased water availability due to low flow or drought 

conditions; increased demand for agricultural, municipal, or industrial usage; or a combination of 

factors (NRC 2013a).
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-30 September 2014 

The License Renewal GEIS evaluated the potential impacts on terrestrial biota and concluded 

that the impacts from water-use conflicts with terrestrial resources could, in certain situations, 

result in noticeable impacts on WHUUHVWULDOUHVRXUFHV15&D)RUH[DPSOH:ROI Creek 

Generating Station in Kansas, which operates a cooling pond to cool plant systems, withdraws 

makeup water for the pond from the Neosho River located downstream of the John Redmond 

reservoir. The riparian communities downstream of the reservoir may be temporarily affected 

by the plant’s water use during periods when the reservoir level is low and makeup water is 

REWDLQHGIURPWKH1HRVKR5LYHU15&D:DWHU-use conflicts during reactor operations, 

such as those described previously, could result in SMALL to MODERATE impacts due to the 

uncertainty associated with water availability to a plant for future water use (see, e.g., 

NRC 2008a).

However, the water-withdrawal requirements for a spent fuel pool are considerably lower than 

those for a power reactor (see Table 4-1 DQG6HFWLRQ). The NRC staff assumes that a 

licensee would continue to withdraw surface water for the nuclear power plant’s service-water 

system to provide cooling makeup water for the spent fuel pools during short-term storage. As 

noted in Section 4.8.1, a licensee could also use groundwater or a combination of surface water 

and groundwater given the reduced cooling demands of the spent fuel pool over time. :DWHU

withdrawals would continue to be subject to applicable water appropriation or allocation permit 

UHTXLUHPHQWVDVZHOODV&OHDQ:DWHU$FW6HFWLRQEUHTXLUHPHQWVIRUPLQLPL]LQJDGYHUVH

environmental impacts associated with the use of cooling-water-intake structures, as may be 

prescribed in NPDES permits. As part of the permit review, the responsible State, or governing 

water-basin commission where applicable, would assess the local water availability to help 

prevent water-use conflicts. 

Table 4-15HIHUHQFH3ODQW:LWKGUDZDO5DWHVDQG+HDW/RDGV

Reactor 

Once-Through Cooling Closed-Cycle Cooling Spent Fuel Pool 

:LWKGUDZDO5DWHJSP(a) 800,000(b) 12,000(c) 2,800(d)

Heat Load (106 BTU/hr) 10,000(b) 10,000(b) (b,e)

(a) The exact amount of water withdrawn depends on a variety of conditions, including water temperature, cooling 

system, size of the nuclear plant, and operational conditions. 

(b) Approximate values based on a typical 1,000-0:HQXFOHDUSRZHUSODQW

(c) EPRI 2002. 

(d) Value calculated based on a ratio of once-through cooling flow and heat load for a reactor, compared to design 

heat load for a spent fuel pool. Actual flow would vary based on site-specific characteristics, such as age and 

amount of spent fuel in the pool, surface-water temperature, etc. Value represents the maximum rate of water 

withdrawal expected during the timeframe analyzed in this GEIS, and would decrease as time after shutdown 

increases. 

(e) Design heat load for a spent fuel pool. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-31 185(*௅

Regardless of the makeup source, return service water, including heat removed from the fuel 

pool, would be discharged to the surface waterbody in an open cycle, as further discussed in 

Section 4.10.1.1. A delegated State agency or the EPA would also require the licensee to 

continue to operate under a modified or new NPDES permit, which would limit the chemical 

quality and temperature characteristics of the facility’s surface water discharge so that no waterquality impairment or use conflict occurs. In addition, the State agency or the EPA would review 

DQGLIQHFHVVDU\XSGDWHWKH13'(6SHUPLWHYHU\\HDUV Therefore, the NRC concludes that 

water-use conflicts during short-term storage would have minimal impacts on terrestrial 

resources. 

Other Potential Impacts from the Spent Fuel Pool Cooling System 

The License Renewal GEIS determined that all other potential impacts on terrestrial ecology 

from the operation of the cooling system would be SMALL at all nuclear power plant sites. 

These additional impacts include the following:

x exposure of terrestrial organisms to radionuclides,

x cooling-system impacts on terrestrial resources (plants with once-through cooling systems 

or cooling ponds), and

x cooling-tower impacts on vegetation.

The License Renewal GEIS determined that these impacts on terrestrial ecology would be 

SMALL at all power plants based on review of literature, operational monitoring reports, 

consultations with utilities and regulatory agencies, and license renewal supplemental EISs 

(SEISs) published to date. The License Renewal GEIS indicated that exceptions have been 

observed at some nuclear plants; however, licensees have addressed the impacts by changing 

plant operations to prevent impacts. 

For example, the License Renewal GEIS reviewed scientific literature on the effects of 

radiological doses to biota, and compared those results with the dose rates that have been 

estimated for terrestrial biota at several nuclear power plants, including plants with spent fuel 

pools. Based on this assessment, the NRC staff determined that exposure of terrestrial 

organisms to radionuclides near nuclear power plants was sufficiently less than the U.S. 

Department of Energy (DOE) and the International Atomic Energy Agency (IAEA) guidelines for 

radiation dose rates from environmental sources. Further, the levels of plant effluents are 

limited by radiation standards for human exposure, and those limitations are generally 

considered to be sufficiently protective of biota other than human. Given that the License 

Renewal GEIS and site-specific analyses included potential impacts from both operating 

reactors and spent fuel pools, and that the frequency and quantity of radionuclides released will 

decrease after reactor shutdown, previous EISs for power reactors contain impact 

determinations that bound the effects of continued storage on terrestrial resources. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-32 September 2014 

Similarly, during the short-term timeframe, because reactor operations have ceased, the other 

impacts described above will be less than during operations. Also, because the cooling system 

requirements for the spent fuel pool (e.g., intake and discharge water volume and heat load 

rejected) are much less than for an operating reactor, the impacts of the operation of the cooling 

system will be much less than those considered in the License Renewal GEIS. Therefore, the 

NRC has determined that the impacts of the spent fuel pool cooling system on terrestrial 

ecology will be minimal during short-term storage. 

Impacts from the Operation and Maintenance of Systems and Structures at the Nuclear 

Power Plant Site 

The License Renewal GEIS evaluated other potential impacts on terrestrial resources from 

sources other than the operation of the spent fuel pool cooling system. These additional 

impacts include the following:

x electromagnetic fields on flora and fauna,

x bird collisions with plant structures and transmission lines, and

x transmission-line right-of-way management impacts on terrestrial resources.

The NRC determined in the License Renewal GEIS that these impacts on terrestrial ecology 

would be SMALL. During the short-term timeframe, electrical power will still be required to 

operate the spent fuel pool cooling system and to provide power to the system associated with 

the operation of ISFSIs (e.g., lighting). Licensees may choose to power these systems by 

maintaining the existing transmission-line infrastructure or replacing this infrastructure with a 

smaller capacity distribution system. This new distribution system would have smaller impacts 

than the existing transmission lines because of the smaller profile, reduced electromagnetic 

field, and reduced vegetative maintenance required around the distribution lines. In addition, 

fewer structures will be required to be maintained during the short-term timeframe, which would 

reduce the likelihood of bird collisions with nuclear power plant structures. As a result, the NRC 

has determined that the impacts from the operation and maintenance of systems and structures 

at the nuclear power plant site on terrestrial ecology will be minimal during short-term storage.

4.9.1.2 ISFSIs 

Normal operation of an ISFSI does not require water for cooling and the facility would produce 

minimal gaseous or liquid effluents. Therefore, no water withdrawal and minimal discharges 

would be associated with the operation of ISFSIs. Some radiological exposure and 

maintenance activities would occur during operation. Maintenance may include some grounddisturbing or rights-of-way management activities. However, impacts on terrestrial resources 

from short-term storage, including routine maintenance activities, would be temporary.
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-33 185(*௅

After they are constructed, at-reactor ISFSIs have similar impacts on terrestrial resources, 

regardless of their location, due to the passive nature and small size of an at-reactor ISFSI and 

because minimal liquid or gaseous effluents are generated during normal operations. This is 

supported by a number of site-specific EAs performed in support of licensing actions that have 

looked at the environmental impacts on terrestrial resources during ISFSI operations. For 

example, a number of these reviews found that the ISFSIs would not contribute any significant 

impacts on terrestrial resources during normal operations (see, e.g., N5&DD

Normal operation of an ISFSI would not generate any significant noise, would not significantly 

affect the area available for terrestrial wildlife, and would not adversely affect terrestrial 

environments or their associated plant anGDQLPDOVSHFLHVVHHHJ15&DD

2003). In addition, while the air temperature in the immediate vicinity of the casks will be higher 

than ambient temperature, the affected area is limited by the distance from the casks to 

receptors and is not expected to affect terrestrial resources (see, e.g., NRC 2009a). To the 

extent that animals and birds are affected by ISFSI operations, they would likely either 

accustom themselves to regular operations or would relocate away from the facility (see, e.g., 

NRC 2012a). Further, licensees are required to adhere to the protection of eagles and 

migratory birds under the Federal Bald and Golden Eagle Protection Act and Migratory Bird 

Treaty Act. In addition, coordination with State natural resource agencies may further ensure 

that power plant operators take appropriate steps to avoid or mitigate impacts on State species 

of special concern that may not be protected under other Federal statutes.

4.9.1.3 Conclusion 

Impacts associated with the operation of spent fuel pools and at-reactor ISFSIs would be 

bounded by the impacts analyzed in the License Renewal GEIS and example ISFSI EAs 

previously discussed. For operation of the spent fuel pool cooling system, impacts would be 

bounded by those discussed in the License Renewal GEIS, primarily due to the reduced cooling 

system requirements for the spent fuel pool (e.g., intake and discharge water volume and heat 

load rejected). For ISFSI operations, impacts would be similar to those described in example 

ISFSI EAs because of the passive nature and small size of ISFSIs, and because minimal liquid 

or gaseous effluents are generated during normal operations. Therefore, the NRC concludes 

that impacts on terrestrial resources from the operation of spent fuel pools and ISFSIs during 

the short-term storage timeframe would be SMALL. 

4.9.2 Long-Term Storage 

During the long-term timeframe, routine maintenance and monitoring of the ISFSIs continues, 

and the NRC assumes that a DTS is constructed and replaced, the fuel is moved from existing 

dry storage casks to new dry storage casks, and a new ISFSI is constructed.

Impacts from the ongoing maintenance and monitoring of ISFSIs on terrestrial resources during 

long-term storage would be similar to the impacts on terrestrial resources from short-term 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-34 September 2014 

storage, described in Section 4.9.1. These impacts would be minimal due to the small size of 

the ISFSIs, because water is not used for cooling, and because minimal liquid or gaseous 

effluents are generated during normal operations.

ISFSIs are designed as passive systems that require no new or additional long-term 

maintenance; however, an at-reactor ISFSI is assumed, for this GEIS, to require replacement 

within the long-term storage timeframe, which would require repackaging of spent fuel at a DTS. 

Replacement of the ISFSI would occur within the plant’s operational area near existing facilities. 

The older ISFSI would be demolished and the land reclaimed and maintained for the next 100 

years.

Impacts on terrestrial resources from ISFSI replacement activities would be similar to those 

impacts evaluated for the decommissioning of an existing at-reactor ISFSI and the construction 

of a new at-reactor ISFSI.

During the removal of an existing at-reactor ISFSI, increases in noise levels and changes in 

localized air quality as a result of fugitive dust and equipment exhaust emissions would likely 

result in animals and birds temporarily avoiding the activity area. Expected ground-disturbing, 

re-grading, and reseeding activities associated with removal of the ISFSI are not expected to 

substantially affect local vegetation. Unless the reclaimed area will be used for another 

purpose, wildlife would likely re-inhabit the area as vegetation begins to reestablish itself 

(see, e.g., NRC 2012a).

The impacts of the replacement and management of an ISFSI would be minimal because the 

construction footprint of an ISFSI is relatively small, the ISFSI would be sited in a previously 

disturbed area, and the licensees would likely be required to implement best management 

practices as part of their NPDES permits to address issues such as stormwater runoff. This is 

supported by a number of site-specific EAs performed in support of licensing actions that have 

looked at the environmental impacts of the construction of an ISFSI on terrestrial resources. 

For example, the NRC concluded in the EA for the Calvert Cliffs ISFSI renewal that the impact 

on ecological resources from decommissioning would be SMALL and would not be significant in 

part because the 2.4-ha (6-ac) ISFSI area was previously disturbed by ISFSI construction 

(NRC 2012a). Also, the NRC did not identify any significant impacts on terrestrial resources 

from construction of the Humboldt Bay ISFSI in part due to the fact that ground-disturbing 

activities would be limited to 0.4 ha (1 ac) and the ISFSI would not be located near any 

terrestrial IHDWXUHV15&D6LPLODUO\WKHFRQVWUXFWLRQIRRWSULQWIRUWKH'LDEOR&DQ\RQ

ISFSI was limited to 2.0 ha ( ac) and was sited in a previously disturbed area (NRC 2003). In 

addition, the NRC indicated that controls would be in place to minimize any site runoff, spillage, 

and leaks (NRC DStormwater control measures, which would be required to 

comply with NPDES permitting, would also minimize the impacts of site runoff, spillage, and 

leaks on nearby wetlands.
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

Like an ISFSI, a DTS would be located within the operational area near existing facilities and, 

like ISFSI replacement and maintenance activities, a DTS would require construction, 

replacement, and maintenance activities. Impacts on terrestrial resources from repackaging, 

operation, and replacement of the DTS would be limited. Like ISFSIs, a DTS could likely be 

sited on previously disturbed ground or away from sensitive terrestrial features because of the 

UHODWLYHO\VPDOOFRQVWUXFWLRQIRRWSULQWIRUD'76DERXWKD>DF@FRPSDUHGWRWKHHQWLUH

power plant site and because there is a sufficient amount of previously disturbed area on most 

nuclear power plant sites. The NRC assumes that construction and eventual replacement of a 

DTS would be temporary (1 to 2 years) and would require a small fraction of the land (about 

 KD>DF@FRPPLWWHGIRUDQXFOHDUSRZHUSODQW7KHFRQVWUXFWLRQOD\GRZQDUHDZRXOGEH

reclaimed and revegetated after construction or replacement is completed. There may be 

temporary increases in traffic, soil erosion, noise, fugitive dust, and habitat reduction from 

construction, replacement, and refurbishment activities that could affect terrestrial resources. 

The plant operator could implement best management practices to minimize land disturbances, 

vegetation removal, erosion, noise, and dust. DTSs and ISFSIs do not require water for cooling. 

Minimal liquid or gaseous effluents are generated during normal operation. Thus construction, 

repackaging, and replacement activities for ISFSIs and DTSs would have minimal impacts on 

terrestrial resources for reasons previously explained. In addition, the NRC expects that normal 

operations of DTSs and ISFSIs would not generate any significant noise, would not significantly 

affect the area available for terrestrial wildlife, and would not adversely affect terrestrial 

environments or their associated plant and animal species. Therefore, the NRC concludes that 

impacts on terrestrial resources during the long-term storage timeframe would be SMALL. 

4.9.3 Indefinite Storage 

During indefinite storage, the activities that occur during long-term storage would continue and 

the ISFSI and DTS would be replaced every 100 years. The NRC concluded in Section 4.9.2 

that impacts on terrestrial resources during long-term storage would be SMALL because 

continued operations, repackaging, DTS construction, and DTS and ISFSI replacement would 

not adversely affect terrestrial environments or their associated plant and animal species. In 

addition, replacement of the ISFSI and DTS would likely occur on land near existing facilities 

and could be sited on previously disturbed ground away from terrestrial species and habitats. 

By alternating the ISFSI between two onsite locations, the NRC expects the upper limit of land 

disturbances to be bounded by doubling the land area developed for existing ISFSIs presented 

in Table 3-1. The older ISFSIs and DTSs would be demolished and the land likely reclaimed. 

Therefore, the NRC concludes that the impacts on terrestrial resources from indefinite storage 

of spent fuel at at-reactor ISFSIs would be SMALL. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-36 September 2014 

4.10 Aquatic Ecology 

This section describes potential aquatic ecology impacts caused by the continued storage of 

spent fuel in spent fuel pools and at-reactor ISFSIs. Impacts on aquatic resources include 

impingement and entrainment; thermal impacts; effects of cooling-water discharge on dissolved 

oxygen, gas supersaturation, and eutrophication (the over-enrichment of water by nutrients such 

as nitrogen phosphorus); effects of nonradiological contaminants on aquatic organisms; 

exposure of aquatic organisms to radionuclides; water-use conflicts with aquatic organisms; and 

losses from predation, parasitism, and disease among organisms exposed to sublethal 

stresses. 

4.10.1 Short-Term Storage 

During the short-term storage timeframe, many activities that occurred during the operation of 

the reactor that could affect aquatic resources would cease. However, aquatic resources will 

likely continue to be affected during this timeframe by the continued operation of the spent fuel 

pool cooling system and the at-reactor ISFSI. 

4.10.1.1 Spent Fuel Pools 

The following discussion describes the impacts of spent fuel pools during short-term storage, 

using the impact determinations from the License Renewal GEIS to inform the NRC’s analysis 

of these impacts during short-term storage. 

Operation of a spent fuel pool and its associated cooling system during the short-term storage 

timeframe would require the withdrawal of water and discharge of effluents into a nearby 

waterbody. To make this comparison, the NRC evaluated the effects of the continued operation 

of nuclear power plants, which included the operation of associated spent fuel pools, on aquatic 

ecology in the License Renewal GEIS (NRC 2013a). The NRC then looked at the systems that 

would be needed to cool the spent fuel pool during short-term storage, and compared the 

impacts associated with water use during operations to the impacts associated with water use 

after the end of operations. 

Impingement and Entrainment of Aquatic Organisms 

Aquatic organisms can be impinged or entrained when cooling-water intakes for spent fuel pools 

withdraw water that provides habitat to fish, shellfish, plankton, or other aquatic resources. 

Impingement, which mostly involves fish and shellfish, occurs when organisms are held against 

the intake screen or netting placed within intake canals. Exhaustion, starvation, asphyxiation, 

descaling, and physical stresses may kill or injure impinged organisms. The License Renewal 

GEIS describes some of the fish species commonly impinged at operating power plants as well 

as other vertebrate species that may also be impinged on the traveling screens or on intake 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

netting placed within intake canals 

(NRC 2013a). These species would likely 

continue to be impinged as a result of 

operation of the spent fuel pool cooling 

system during the short-term storage 

timeframe. 

Entrainment occurs when organisms pass 

through the intake screens and travel 

through the spent fuel pool condenser 

cooling system. Heat, physical stress, or 

chemicals used to clean the cooling system 

may kill or injure the entrained organisms. Due to these physical stresses, the NRC assumes 

100 percent mortality for all entrained organisms. Typically entrained aquatic organisms include 

ichthyoplankton (fish eggs and larvae), larval stages of shellfish and other macroinvertebrates, 

zooplankton, and phytoplankton. Juveniles and adults of some species may also be entrained if 

they are small enough to pass through the intake screen openings, which are commonly 1 cm 

(0.4 in) at the widest point. The License Renewal GEIS describes some of the fish species 

commonly entrained at operating power plants (NRC 2013a). These species would likely 

continue to be entrained as a result of operation of the spent fuel pool cooling system during the 

short-term storage timeframe. 

The severity of impacts associated with impingement and entrainment is dependent upon 

several factors including the amount of water withdrawn relative to the size of the cooling-water 

source, location and configuration of intake structures, type of waterbody from which water is 

withdrawn, conditions within that waterbody, proximity of withdrawal structures to sensitive 

biological habitats (e.g., spawning and nursery habitats), sensitivity of populations of impinged 

and entrained organisms to potential losses of individuals, and mitigation measures in place to 

reduce impingement and entrainment (NRC 2013a). Among these factors, the volume of water 

withdrawn relative to the size of the water source can be a good predictor of the number of 

organisms that would be impinged or entrained within a given aquatic system (EPA 2002). 

Impingement monitoring at the Palisades Nuclear Plant in Michigan demonstrates this 

differHQFH,QZKHQWKHSODQWXVHGRQFH-through cooling with a water-withdrawal rate of 

/PLQ JSP ILVKZHUHLPSLQJHG\HDUO\,QFRROLQJWRZHUV

were added to the plant, and it began operating as a closed-cycle plant. The intake withdrawal 

UDWHZDVUHGXFHGWR/PLQ JSPDQGLPSLQJHPHQWGURSSHGWR fish per 

year (Consumers Energy Company and Nuclear Management Company 2001). These results 

showed that an approximate 80 percent decrease in water withdrawal resulted in an 

approximate 98 percent decrease in impingement at Palisades Nuclear Plant. 

Impingement 

Impingement is the entrapment of all life stages of 

fish and shellfish on the outer part of an intake 

structure or against a screening device during 

periods of water withdrawal (40 &)5

Entrainment 

Entrainment is incorporation of all life stages of fish 

and shellfish with intake water flow entering and 

passing through a cooling-water-intake structure and 

into a cooling-water system (40 &)5
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-38 September 2014 

The License Renewal GEIS concluded that the impacts from impingement and entrainment 

would be SMALL, MODERATE, or LARGE at operating plants with once-through cooling, 

cooling ponds, or hybrid cooling (NRC 2013a). The magnitude of the impact would depend on 

plant-specific characteristics of the cooling system (including location, intake velocities, 

screening technologies, and withdrawal rates) and characteristics of the aquatic resource 

(including population distribution, status, management objectives, and life history). However, for 

operating plants with closed-cycle cooling, the License Renewal GEIS generically concluded 

that impingement and entrainment is SMALL (NRC 2013a). The main reason the License 

Renewal GEIS could generically conclude that the impacts would be SMALL at all closed-cycle 

cooling plants is because power plants with closed-cycle cooling require much less water than 

those with once-through cooling. For example, EPRI estimated that the average flow rate for a 

reference 1,000-0:HQXFOHDUSODQWZLWKFORVHG-F\FOHZRXOGEH/PLQ gpm), 

which is approximately 1 to 3 percent of the flow rate for a reference 1,000-0:HSODQWZLWK

once-WKURXJKFRROLQJWR/PLQWRJSP(35,

Reactors are typically cooled either by transferring excess heat directly to a water source 

(referred to as open-cycle cooling) or to the atmosphere through a cooling tower (referred to as 

closed-cycle cooling). For nuclear power plants with closed-cycle cooling systems, cooling 

water for the service-water system (which cools the spent fuel pool) is usually withdrawn from a 

surface waterbody, circulated through the service-water system, and sent to the cooling tower 

DVDVRXUFHRIPDNHXSZDWHUIRUWKHPDLQFRROLQJV\VWHP:KLOHLWLVW\SLFDOO\XVHGDVDVRXUFH

of makeup water, the discharge from the service-water system can also be returned to the 

surface waterbody, functioning, in essence, like an open-cycle cooling system. Because the 

heat load associated with the spent fuel pool during continued storage is significantly smaller 

than a reactor at full power and because of the costs associated with operating the cooling 

towers, the NRC assumes that, for nuclear power plants with closed-cycle cooling systems, 

those systems will be operated in a manner similar to an open-cycle cooling system to cool the 

spent fuel pool during the short-term timeframe. As discussed below, the NRC expects that the 

flow rate associated with the water needed to cool the spent fuel pool after operations will be 

significantly less than the overall water needed during operation of the reactors, regardless of 

the cooling technology used to cool tKHUHDFWRUV:KHQFRPSDUHGWRDRQFH-through cooling 

system, the water needed to cool the spent fuel pool is orders of magnitude less than the water 

needed during reactor operations. 

To operate spent fuel pools during short-term storage, the service-water system would likely 

continue to operate to cool the spent fuel pools. Cooling systems associated with spent fuel 

pools require substantially less water volume and carry a lower heat load than operating nuclear 

power plants, as indicated in Table 4-1. For example, based on the current operation of spent 

fuel pools, the NRC estimates that approximately 10,600 L/min (2,800 gpm) would be withdrawn 

at each spent fuel pool. Operating reactors with closed-cycle cooling systems, on the other 

KDQGZLWKGUDZDSSUR[LPDWHO\/PLQJSPDQGRSHUDWLQJSODQWVZLWKRQFHWKURXJKFRROLQJUHTXLUHWR/PLQWRJSP(35I 2002). 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-39 185(*௅

In addition, the amount of water withdrawn to cool spent fuel pools is likely to decrease over the 

short-term storage timeframe because the spent fuel pool would require less cooling as the 

spent fuel cools. Based on the reduced operational requirements for spent fuel pool cooling 

systems (e.g., reduced water-withdrawal and discharge rates), the impingement and 

entrainment impacts from an operating nuclear plant bound the potential impacts from operating 

spent fuel pools during short-term storage. 

Because operating the spent fuel pool cooling system during the short-term timeframe will use 

less water than operating the cooling system for an operating plant with a closed-cycle cooling 

system, which was considered in the License Renewal GEIS, the NRC concludes that 

impingement and entrainment impacts from operating spent fuel pools during continued storage 

would have minor impacts on aquatic resources. 

Heat Shock 

:DWHU-based cooling systems for spent fuel pools generally discharge heated effluent into 

nearby waterbodies. Heat shock can occur if the water temperature meets or exceeds the 

thermal tolerance of a species for some duration (NRC D,QPRVWVLWXDWLRQVILVKDUH

capable of moving out of an area that exceeds their thermal tolerance limits, although many 

aquatic resource species lack such mobility. Heat shock is typically observable only for fish 

species, particularly those that float when dead. The License Renewal GEIS provides additional 

details on observed fish kills and other potential environmental impacts from heat shock. 

The severity of impacts for heat shock depends on the characteristics of the cooling system 

(including location and type of discharge structure, discharge velocity and volume, and 

three-dimensional characteristics of the thermal plume) and characteristics of the affected 

aquatic resources (including the species present and their physiology, habitat, population 

distribution, status, management objectives, and life history). Site-specific design features, such 

as locating the discharge structures in areas where warmer water would be rapidly diluted, may 

mitigate adverse thermal effects (Beitinger et al. +DOOHWDOGHWHUPLQHGWKDWWKH

potential for thermal discharge impacts is greatest in shallow, enclosed, and poorly mixed 

waterbodies. 

The License Renewal GEIS concluded that for operating plants with a once-through cooling 

system or cooling ponds, the level of impact for thermal discharge on aquatic biota (primarily 

due to heat shock) was SMALL at many plants and MODERATE or LARGE at some plants. For 

example, some nuclear plants have reported occasional fish kills from heat shock (see, e.g., 

15&ED([HORQ)RURSHUDWLQJSODQWVZLWKFORVHG-cycle cooling, the 

NRC conducted a review of the literature and license renewal SEISs published to date and 

determined that reduced populations of aquatic biota attributable to occurrences of heat shock 

have not been reported for any existing nuclear power plants with cooling towers operated in 

closed-cycle mode. Based on this review and because of the smaller thermal plumes at plants 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-40 September 2014 

with closed-cycle cooling compared to plants with once-through cooling systems, the License 

Renewal GEIS concluded that impacts from heat shock would be SMALL at all plants with 

closed-cycle cooling. The thermal plume is generally smaller at plants with closed-cycle cooling 

because less water is being discharged (NRC 2013a). 

As described above, cooling systems associated with spent fuel pools operating during the 

short-term storage timeframe would require substantially less water volume and carry a lower 

heat load compared to operating nuclear power plants with closed-cycle cooling systems (see 

Table 4-1). In addition, the heat load in the spent fuel pool would decrease over time as the fuel 

continues to decay. Because the amount of water discharged from a spent fuel pool, regardless 

of the type of cooling system, would still be significantly less than the amount of water 

discharged from an operating plant with closed-cycle cooling, the extent of the thermal plume 

would likely be smaller. In addition, the licensee would be required to obtain an NPDES permit 

for thermal discharges, and the permit would limit the amount and temperature of thermal 

effluent to be discharged. The NPDES permit would also require the licensee to monitor and 

ensure the effluent is within the set thermal limit. Based on this information, the thermal impacts 

from an operating nuclear plant with closed-cycle cooling (which was determined to be SMALL 

in the License Renewal GEIS) likely bounds the potential thermal impacts from operating spent 

fuel pools beyond the licensed term of the nuclear plant. 

The NRC has determined that thermal impacts from operating spent fuel pools beyond the 

licensed term of the plant would have a minor impact on aquatic resources because operating 

the spent fuel pool cooling system during the short-term storage timeframe will use less water 

than operating a closed-cycle cooling system for an operating reactor and a spent fuel pool 

considered in the License Renewal GEIS. 

Water-Use Conflicts with Aquatic Resources at Plants with Cooling Ponds or Cooling 

Towers Using Makeup Water from a River 

:DWHU-use conflicts with aquatic resources could occur if water from a single waterbody is 

required to simultaneously cool a spent fuel pool; support aquatic resources, and support other 

water users (e.g., agricultural, municipal, or industrial users). A conflict could arise if the 

surface-water resource is diminished either because of decreased water availability due to 

droughts; increased demand for agricultural, municipal, or industrial usage; or a combination of 

factors. The License Renewal GEIS determined that water-use conflicts during plant operation 

are a concern for streams or rivers because of the duration of license renewal and potentially 

increasing demands on surface water. However, the water-withdrawal requirements for a spent 

fuel pool during short-term storage are considerably lower than for an operating plant (see 

Table 4-1). In addition, the spent fuel pool operator would be subject to applicable water 

appropriation or allocation permit requirements and NPDES permit provisions, which would limit 

the amount of water that could be withdrawn and the quality of effluent discharged, respectively, 

as previously described in Section 4.9.1.1. Because operating the spent fuel pool cooling 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-41 185(*௅

system during short-term storage will use significantly less water than operating the cooling 

system for an operating plant considered in the License Renewal GEIS, the NRC has 

determined that water-use conflicts from operating spent fuel pools during short-term storage 

would have minimal impacts on aquatic resources. 

Other Potential Impacts from the Cooling System 

The License Renewal GEIS determined that all other potential impacts on aquatic ecology from 

the operation of the cooling system would be SMALL at all nuclear power plants. These 

additional impacts include the following: 

x cold shock, which can occur when organisms acclimated to the elevated temperatures of a 

thermal plume are abruptly exposed to temperature decreases when the artificial source of 

heating stops; 

x the creation of thermal plume migration barriers, which would occur if the mixing zone of the 

thermal plume covers an extensive cross-sectional area of a river and exceeds the fish 

avoidance temperature (NRC 2013a); 

x changes in the distribution of aquatic organisms; 

x accelerated development of aquatic insect maturation due to warmer temperatures; 

x stimulation of the growth of aquatic nuisance species; 

x effects of cooling-water discharge on dissolved oxygen, gas supersaturation, and 

eutrophication; 

x effects of nonradiological contaminants on aquatic organisms; 

x exposure of aquatic organisms to radionuclides; and 

x losses from predation, parasitism, and disease among organisms exposed to sublethal 

stresses. 

In the License Renewal GEIS, the NRC determined that these impacts would be SMALL at all 

nuclear power plants. The NRC based its conclusion on the following: 

x Any fill kills or other events related to the impacts described previously were relatively rare 

and did not result in population level impacts. 

x The heat from the thermal plume usually dissipated rapidly. 

x Heated plumes are often small relative to the size of the receiving waterbody. The License 

Renewal GEIS provides additional details regarding these potential impacts and the studies 

reviewed to support the SMALL conclusion. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-42 September 2014 

In evaluating the exposure of aquatic organisms to radionuclides, the License Renewal GEIS 

reviewed scientific literature on the effects of radiological doses to biota, and compared those 

results with the dose rates that have been estimated for aquatic biota at several nuclear power 

plants, including plants with spent fuel pools. Based on this assessment, the NRC determined 

that exposure of aquatic organisms to radionuclides near nuclear power plants was sufficiently 

less than the DOE and IAEA guidelines for radiation dose rates from environmental sources. 

Further, the levels of plant effluents are limited by radiation standards for human exposure, and 

those limitations are generally considered to be sufficiently protective of biota other than human. 

Given that the License Renewal GEIS and site-specific analyses included potential impacts from 

both operating reactors and spent fuel pools, and that the frequency and quantity of 

radionuclides released will decrease after reactor shutdown, previous EISs for power reactors 

contain impact determinations that bound the effects of continued storage on aquatic resources.

As described above, the water-withdrawal rate, discharge rates, and extent of the thermal plume 

would be greater for an operating plant than a spent fuel pool during short-term storage (see 

Table 4-1). Based on this information, the other potential impacts from an operating a nuclear 

plant with closed-cycle cooling (which was determined to be SMALL in the License Renewal 

GEIS) likely bound the potential impacts from operating spent fuel pools during short-term 

storage. Because operating the spent fuel pool cooling system during short-term storage will 

use less water than operating the cooling system for an operating plant considered in the 

License Renewal GEIS, the NRC has determined that other potential impacts from operating 

spent fuel pools during the short-term storage timeframe would have minimal impacts on 

aquatic resources. 

4.10.1.2 ISFSIs 

The NRC reviewed example ISFSI EAs to inform its analysis of the environmental impacts of 

ISFSIs on aquatic resources during short-term storage. 

During normal operations, ISFSIs do not require water for cooling and the facility would produce 

minimal gaseous or liquid effluents. Therefore, no water withdrawal or discharges would be 

associated with the operation of ISFSIs. Some maintenance activities could occur during ISFSI 

operation. However, impacts on any aquatic features would be minimal. Stormwater control 

measures, which would be required to comply with NPDES permitting, would also minimize the 

flow of disturbed soils or other contaminants into aquatic features. In addition, the plant 

operator would likely implement best management practices to minimize erosion and 

VHGLPHQWDWLRQDQGFRQWURODQ\UXQRIIVSLOOVRUOHDNV15&D)RUH[DPSOHthe EAs 

for the Calvert Cliffs, Humboldt Bay, and Diablo Canyon ISFSIs did not identify any significant 

impacts on aquatic resources during normal operations of an onsite dry cask storage facility 

15&DD&RQVHTXHQWO\JLYHQWKDW,6)6,VGRQRWUHTXLUHZDWHUIRUFRROLQJ
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-43 185(*௅

and the facility would produce minimal gaseous or liquid effluents, impacts on aquatic resources 

from the operation of ISFSIs during short-term storage would not have noticeable impacts on 

aquatic resources. 

4.10.1.3 Conclusion 

Given that the impacts associated with the operation of spent fuel pools would likely be bounded 

by the impacts analyzed in the License Renewal GEIS due to the lower withdrawal rates, lower 

discharge rate, smaller thermal plume, and lower heat content for a spent fuel pool compared to 

an operating reactor with closed-cycle cooling, the NRC concludes that impacts on aquatic 

resources from the operation of spent fuel pools during short-term storage would be minimal. In 

addition, the impacts from operation of at-reactor ISFSIs would be minimal because ISFSIs do 

not require water for cooling, produce minimal gaseous or liquid effluents, and ground-disturbing 

activities for ISFSI maintenance would have minimal impacts on aquatic ecology. Therefore the 

NRC concludes that the potential environmental impacts on aquatic resources would be SMALL 

during the short-term storage timeframe. 

4.10.2 Long-Term Storage 

Routine maintenance and monitoring of the ISFSIs would continue during long-term storage. 

Likewise, the impacts from routine maintenance and monitoring of ISFSIs during the short-term 

storage timeframe would continue during the long-term storage timeframe and would remain the 

same. 

Due to the relatively small construction footprint of a DTS, a DTS could likely be sited and 

constructed on land near existing facilities, on previously disturbed ground, and away from 

sensitive aquatic features. In addition, the replacement DTS and ISFSI facilities could likely be 

sited on previously disturbed ground away from sensitive aquatic features. For example, the 

NRC did not identify any significant impacts on aquatic resources from construction of the 

Humboldt Bay ISFSI in part due to the fact that ground-disturbing activities would be limited to 

KDDFDQGWKH,6)6,ZDVQRWORFDWHGQHDUDQ\DTXDWLFIHDWXUHV15&D6LPLODUO\

WKHFRQVWUXFWLRQIRRWSULQWIRUWKH'LDEOR&DQ\RQ,6)6,ZDVOLPLWHGWRKDDFDQGZDVVLWHd in 

a previously disturbed area that did not contain any sensitive aquatic features (NRC 2003). In 

DGGLWLRQWKH15&DLQGLFDWHGWKDWFRQWUROVZRXOGEHLQSODFHWRPLQLPL]HWKHIORZ

of any site runoff, spillage, and leaks into sensitive aquatic features. For example, stormwater 

control measures, which would be required to comply with NPDES permitting, would minimize 

the flow of disturbed soils or other contaminates into aquatic features. The plant operator could 

also implement best management practices to minimize erosion and sedimentation. 

ISFSIs and DTSs do not require water for cooling and produce minimal gaseous or liquid 

effluents. In addition, replacement ISFSIs and DTSs would be sited on previously disturbed 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-44 September 2014 

ground away from sensitive aquatic features. The older ISFSIs and DTSs would be demolished 

and the land reclaimed. Therefore, the NRC concludes that impacts on aquatic resources 

during long-term storage would be SMALL. 

4.10.3 Indefinite Storage 

During indefinite storage, the activities that occur during long-term storage would continue and 

the ISFSIs and DTSs would be replaced every 100 years. Therefore the impacts that occurred 

during long-term storage would continue. The NRC concluded in Section 4.10.2 that impacts on 

aquatic resources would be SMALL because ISFSIs do not require water for cooling and would 

have minimal impacts on aquatic resources. In addition, replacement of the ISFSIs and DTSs 

would occur near existing facilities and would be sited on previously disturbed ground away 

from sensitive aquatic features. The older ISFSIs and DTSs would be demolished and the land 

reclaimed. Therefore, the NRC concludes that the impacts on aquatic resources from indefinite 

storage of spent fuel in at-reactor ISFSIs would be SMALL. 

4.11 Special Status Species and Habitat 

This section describes potential environmental impacts on special status species and their 

habitats caused by the continued storage of spent fuel in spent fuel pools and at-reactor ISFSIs. 

Special status species and habitats may include those identified in Section 4.9 for terrestrial 

resources and Section 4.10 for aquatic resources. 

4.11.1 Short-Term Storage 

Impacts on Federally listed species, designated critical habitat, essential fish habitat, and other 

special status species and habitats during short-term storage may occur from spent fuel pool or 

ISFSI operations. 

4.11.1.1 Spent Fuel Pools 

Given that Federally listed species, designated critical habitat, essential fish habitat, State-listed 

species, marine mammals, migratory birds, and bald and golden eagles may be affected by 

operation of cooling systems for nuclear power plants, special status species and habitats could 

also be affected by the operation of cooling systems for spent fuel pools during the short-term 

storage timeframe. Possible impacts on Federally listed species, designated critical habitat, 

essential fish habitat, State-listed species, marine mammals, migratory birds, and bald and 

golden eagles would be similar to those described in Sections 4.9.1 and 4.10.1 for terrestrial 

and aquatic resources. 

The Endangered Species Act (ESA) IRUELGV3WDNH ́RIDOLVWHGVSHFLHVZKHUH3WDNH ́PHDQVto 

3KDUDVVKDUPSXUVXHKXQWVKRRWZRXQGNLOOWUDSFDSWXUHRUFROOHFWRUDWWHPSWWRHQJDge in 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

any such conduct.” Prior to entering the short-term storage timeframe, the NRC would have 

addressed impacts on Federally listed species and designated critical habitats through the ESA 

6HFWLRQFRQVXOWDWLRQSURFHVVat the time of original licensing, license renewal of the power 

plant (including the spent fuel pool cooling system), and for any other agency action as defined 

by the ESA that could affected listed species. For agency actions as defined by the ESA where 

listed species or designated critical habitat may be affected, the NRC would initiate ESA Section 

FRQVXOWDWLRQ with the National Marine Fisheries Service (NMFS) or the U.S. )LVKDQG:LOGOLIH

Service ():6). This consultation may be either formal or informal, depending on the specific 

adverse effect. In the case of an adverse effect for which the NRC would issue a biological 

DVVHVVPHQWWKDWLQLWLDWHVIRUPDOFRQVXOWDWLRQWKH):6RU10)6 would issue a Biological 

Opinion LQDFFRUGDQFHZLWKWKHSURYLVLRQVRIIRUPDOFRQVXOWDWLRQDW CFR 402.14. 7KH):6

or NMFS could issue, with a Biological Opinion, an incidental take statement that contains 

provisions exempting a certain incidental take of Federally listed species and reasonable and 

prudent measures necessary or appropriate to minimize impacts on Federally listed species and 

designated critical habitats. 

After FRQFOXVLRQRIDQLQLWLDOFRQVXOWDWLRQ CFR 402.16 directs Federal agencies to reinitiate 

consultation where discretionary Federal involvement or control over the action has been 

retained or is authorized by law, and where (a) the amount or extent of taking specified in the 

incidental take statement is exceeded, (b) new information reveals effects on Federally listed 

species or designated critical habitats that were not previously considered, (c) the action is 

modified in a manner that causes effects not previously considered, or (d) new species are 

listed or new critical habitat is designated that may be affected by the action. For example, the 

Oyster Creek nuclear plant exceeded its incidental take limit established by the NMFS for 

.HPS¶VULGOH\VHDWXUWOHV7KH15&WKHUHIRUHZDVUHTXLUHGWRUHLQLWLDWH(6$6HFWLRQ

consultation with NMFS, which included the reevaluation of the impacts on the Kemp’s ridley 

VHDWXUWOHVDQGSRWHQWLDOPLWLJDWLRQPHDVXUHV15&D7KXVWKH(6$6HFWLRQ

consultation process would help identify any impacts on Federally listed species or designated 

critical habitat, potentially require monitoring and mitigation to minimize impacts on listed 

species, and ensure that any takes that occur as a result of cooling-system operations are 

exempted by the incidental take statement. Regulations and guidance regarding the ESA 

6HFWLRQFRQVXOWDWLRQSURFHVVDUHSURYLGHGin  CFR Part 402 and in the Endangered Species 

Consultation Handbook ):610)6 1998), respectively.

Federally listed species and designated critical habitats would continue to be protected under 

the ESA during the short-term storage timeframe. As described above the NRC would be 

UHTXLUHGWRUHLQLWLDWHFRQVXOWDWLRQZLWKWKH):6DQG10)6 for NRC actions as defined in the 

ESA that could affect listed species. For example, for nuclear power plants with a Biological 

Opinion, the NRC would need to reinitiate consultation with the F:6or NMFS if there is a 

significant change in the plant parameters described in the Biological Opinion that could affect 

listed species or designated critical habitats in a manner or to an extent not previously 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-46 September 2014 

considered DQGLIWKHFULWHULDLQ&)5.16 DUHPHWIRUUHLQLWLDWLRQRI6HFWLRQFRQVXOWDWLRQ. 

The most likely change in a plant parameter during short-term storage would be a decrease in 

water-withdrawal and discharge rates due to the lower water demands to operate a spent fuel 

pool than to operate a nuclear power reactor. Impacts on special status species and habitats 

would likely decrease due to less impingement, entrainment, and thermal impacts associated 

with lower withdrawal and discharge rates. 

,IRSHUDWLRQRIWKHVSHQWIXHOSRROFRROLQJV\VWHPUHVXOWHGLQD3Wake” of a listed species not 

covered under a Biological Opinion and if the criteria LQ&)5Part 402 are met for initiation or 

reinitiation RI6HFWLRQFRQVXOWDWLRQ, the NRC would be required to initiate or reinitiate ESA 

FRQVXOWDWLRQZLWKWKH):6RU10)67KHRIILFLDOOLVWVRI(6$-listed species are updated by the 

):6DQG10)66SHFLHVPD\EHDGGHGWRWKHOLVWRUGHOLVWHG,IQHZVSHFLHVZHUHOLVWHGXQGHU

the ESA, the NRC would assess any potential impacts on those species at all NRC-licensed 

facilities at the time of listing. Therefore, if a new species were listed after the licensed life of 

the associated nuclear reactor, DQGLIWKHFULWHULDLQ&)5Part 402 are met for initiation of 

Section FRQVXOWDWLRQ the NRC would determine if the newly listed species could occur near a 

spent fuel pool and ZRXOGLQLWLDWH(6$6HFWLRQFRQVXOWDWLRQLIRSHUDWLRQRIDVSHQWIXHOSRRO

could adversely affect the newly listed species. 

The NRC is required under the Magnuson–Stevens Fishery Conservation and Management Act 

to consult with NMFS for any authorized, funded, or undertaken action, including permitting and 

licensing, that could adversely affect essential fish habitat. As part of this consultation, the NRC 

would assess the occurrence of and adverse impacts to essential fish habitat in an Essential 

Fish Habitat Assessment. The implementing regulations for the Magnuson–Stevens Fishery 

&RQVHUYDWLRQDQG0DQDJHPHQW$FW&)5Part 600) describe additional details regarding the 

steps involved in essential fish habitat consultation. 

In addition, NRC and licensee coordination with other Federal and State natural resource 

agencies would further encourage licensees to take appropriate steps to avoid or mitigate 

impacts on special status species, habitats of conservation concern, and other protected 

species and habitats, such as those protected under the )LVKDQG:LOGOLIH&RRUGLQDWLRQ$FW

Coastal Zone Management Act, Marine Mammal Protection Act, the Migratory Bird Treaty Act, 

and the Bald and Golden Eagle Protection Act, as applicable. NRC and licensee coordination 

with other Federal and State natural resource agencies would likely result in avoidance or 

mitigation measures that would minimize impacts on protected species and habitats. 

4.11.1.2 ISFSIs 

Impacts from the operation of ISFSIs on special status species and habitats would be similar to 

those described above for terrestrial and aquatic resources, which would be minimal due to the 

small size of the ISFSIs and because no water is required for cooling. For example, the NRC’s 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

EAs for the Humboldt Bay and Diablo Canyon ISFSIs did not identify any impacts on special 

status species during normal operations of at-UHDFWRU,6)6,V15&D

As described in Section 4.11.1.1, the NRC is required to consult with NMFS for actions that may 

adversely affect essential fish habitat. However, it is unlikely that ISFSIs would adversely affect 

essential fish habitat because they are built on land and do not require water for cooling. In the 

event that an ISFSI could adversely affect essential fish habitat, the NRC would consult with 

NMFS. 

In addition, NRC and licensee coordination with Federal and State natural resource agencies 

would further encourage licensees to take appropriate steps to avoid or mitigate impacts on 

State-listed species, habitats of conservation concern, and other protected species and habitats, 

VXFKDVWKRVHSURWHFWHGXQGHUWKH)LVKDQG:LOGOLIH&RRUGLQDWLRQ$FW&RDVWDO=RQH

Management Act, Marine Mammal Protection Act, the Migratory Bird Treaty Act, and the Bald 

and Golden Eagle Protection Act, as applicable. NRC and licensee coordination with other 

Federal and State natural resource agencies would likely result in avoidance or mitigation 

measures that would minimize impacts on protected species and habitats. 

4.11.1.3 Conclusion 

As described above, the ESA has several requirements that would help ensure protection of 

Federally listed species and designated critical habitat during short-term storage. For spent fuel 

pools, the NRC would have addressed impacts on Federally listed species and designated 

critical habitats through WKH(6$6HFWLRQFRQVXOWDWLRQSURFHVVDWWKHWLPHRIRULJLQDOOLFHQVLQJ

license renewal of the power plant (including the spent fuel pool cooling system), and for any 

other agency action as defined by the ESA that may affect listed species. Following the 

FRQFOXVLRQRIDQLQLWLDOFRQVXOWDWLRQ CFR 402.16 directs Federal agencies to reinitiate 

consultation in circumstances where discretionary Federal involvement or control over the 

action has been retained or is authorized by law and where (a) the amount or extent of taking 

specified in the incidental take statement is exceeded, (b) new information reveals effects on 

Federally listed species or designated critical habitats that were not previously considered, 

(c) the action is modified in a manner that causes effects not previously considered, or (d) new 

species are listed or new critical habitat is designated that may be affected by the action. 

During each consultation, the NRC would characterize the effects of spent fuel pools to listed 

species in terms of its ESA findings of (1) no effect, (2) may affect but is not likely to adversely 

affect, (3) may affect and is likely to adversely affect, or (4) likely to jeopardize the listed 

species or adversely modify the designated critical habitat of Federally listed species 

populations or their critical habitats. Similarly, in complying with the Magnuson–Stevens Fishery 

Conservation and Management Act, the NRC would report the effects of spent fuel pools in 

terms of the Act’s required findings of (1) no adverse impact, (2) minimal adverse impact, or 

(3) substantial adverse impact on the essential habitat of Federally managed fish and shellfish 

populations. Impacts on other special status aquatic species, such as State-listed species, 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-48 September 2014 

would most likely be less than those experienced during the licensed life for operation of the 

reactor due to the smaller size of the spent fuel pool’s cooling system and lower water demands 

when compared to those of an operating reactor. 

For ISFSIs, given the small size and licensees’ ability to site ISFSIs away from sensitive 

ecological resources, the NRC concludes that ISFSIs would likely have minimal impacts on 

State-listed species, marine mammals, migratory birds, and bald and golden eagles. In the 

unlikely situation that the continued operation of an ISFSI could affect Federally listed species or 

designated critical habitat, and if the criteria are met LQ&)5Part 402 for initiation or 

reinitiation RI(6$6HFWLRQFRQVXOWDWLRQ, the NRC would be required to initiate or reinitiate ESA 

6HFWLRQFRQVXOWDWLRQZLWKWKH10)6RU):6. In the unlikely situation that the continued 

operation of an ISFSI could adversely affect essential fish habitat, and if the criteria are met in 

&)5Part 600 for initiation of consultation under the Magnuson–Stevens Fishery 

Conservation and Management Act, the NRC would be required to initiate essential fish habitat 

consultation with NMFS. 

4.11.2 Long-Term Storage 

In addition to routine maintenance, operation, and monitoring of ISFSIs, impacts from the 

construction of a DTS and replacement of the DTS and ISFSIs on special status species and 

habitats would be similar to those described in Sections 4.9.2 and 4.10.2, which would be 

minimal due to the small size of the ISFSIs and DTSs and because no water is required for 

cooling. The same consultations and any associated mitigation requirements described in 

Section 4.11.1 would apply to construction of a DTS and replacement of the DTS and ISFSI 

during long-term storage. The NRC assumes that the ISFSIs and DTSs could often be sited to 

avoid Federally listed species and critical habitat due to the small size of the construction 

footprint and sufficient amount of previously disturbed areas on most nuclear power plant sites. 

For example, the EAs for the Humboldt Bay and Diablo Canyon ISFSIs did not identify any 

significant impacts on special status species from construction and normal operations of the atUHDFWRU,6)6,V15&DIn addition, coordination with Federal and State natural 

resource agencies would encourage licensees to take appropriate steps to avoid or mitigate 

impacts on State-listed species, habitats of conservation concern, and other protected species 

and habitatsVXFKDVWKRVHSURWHFWHGXQGHUWKH)LVKDQG:LOGOLIH&RRUGLQDWLRQ$FW&RDVWDO

Zone Management Act, Marine Mammal Protection Act, the Migratory Bird Treaty Act, and the 

Bald and Golden Eagle Protection Act, as applicable. Therefore, the NRC concludes that 

construction of a DTS and the replacement of the DTS and ISFSI would likely have minimal 

impacts on State-listed species, marine mammals, migratory birds, and bald and golden eagles. 

In the unlikely situation that the continued operation of an ISFSI or operation of a DTS could 

affect Federally listed species or designated critical habitat, and if the criteria are met in 

 CFR Part 402 for LQLWLDWLRQRUUHLQLWLDWLRQRI(6$6HFWLRQFRQVXOWDWLRQWKH15&ZRXOGEH

UHTXLUHGWRLQLWLDWHRUUHLQLWLDWH(6$6HFWLRQFRQVXOWDWLRQZLWKWKH10)6RU):6 In the 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-49 185(*௅

unlikely situation that the continued operation of an ISFSI or operation of a DTS could adversely 

DIIHFWHVVHQWLDOILVKKDELWDWDQGLIWKHFULWHULDDUHPHWLQ&)5Part 600 for initiation of 

consultation under the Magnuson–Stevens Fishery Conservation and Management Act, the 

NRC would be required to initiate essential fish habitat consultation with NMFS. 

4.11.3 Indefinite Storage 

The impacts of indefinite storage on special status species and habitats would be minimal and 

similar to those described in Sections 4.9.3 and 4.10.3. The same consultations and any 

associated mitigation requirements described in Section 4.11.1 would apply to the construction 

of the DTS and replacement of the DTS and ISFSI facilities during indefinite storage. For the 

reasons described in Section 4.11.2, the NRC concludes that the replacement of the DTS and 

ISFSI would likely have minimal impacts on State-listed species, marine mammals, migratory 

birds, and bald and golden eagles. In the unlikely situation that the continued operation of an 

ISFSI or operation of a DTS could affect Federally listed species or designated critical habitat, 

DQGLIWKHFULWHULDDUHPHWLQ&)5Part IRULQLWLDWLRQRUUHLQLWLDWLRQRI(6$6HFWLRQ

FRQVXOWDWLRQWKH15&ZRXOGEHUHTXLUHGWRLQLWLDWHRUUHLQLWLDWH(6$6HFWLRQFRQVXOWDWLRQZLWK

WKH10)6RU):6 In the unlikely situation that the continued operation of an ISFSI or 

operation of a DTS could adversely affect essential fish habitat, and if the criteria are met in 

 CFR Part 600 for initiation of consultation under the Magnuson–Stevens Fishery 

Conservation and Management Act, the NRC would be required to initiate essential fish habitat 

consultation with NMFS. 

4.12 Historic and Cultural Resources 

This section describes potential impacts on historic and cultural resources caused by the 

continued storage of spent fuel in spent fuel pools and at-reactor ISFSIs. 

The NRC is considering impacts on historic and cultural resources in this GEIS through 

implementation of its NEPA requirements in 10 CF53DUW7KLVUXOHPDNLQJLVQRWDOLFHQVLQJ

action; it does not authorize the initial or continued operation of any nuclear power plant, and it 

does not authorize storage of spent fuel. Because the GEIS does not identify specific sites for 

NRC licensing actions, a NHPA Section 106 review has not been performed. However, the 

NRC complies with NHPA Section 106 and the implementing provisions in 36 CFR Part 800 in 

site-specific licensing actions. As discussed in Section 3.11, identification of historic properties, 

adverse effects, and potential resolution of adverse effects would be conducted through 

consultation and application of the National Register of Historic Places criteria in 36 CFR 60.4. 

This information would also be evaluated to determine the significance of potential impacts on 

historic and cultural resources in the NRC’s environmental review documents. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4- September 2014 

As discussed in Section 3.11, most nuclear power plant sites are located in areas along 

waterways that people tended to settle near or travel along, so there is a potential for historic 

DQGFXOWXUDOUHVRXUFHVWREHSUHVHQW:DWHUZD\VSURYLGHGIUHVKZDWHUWKHPRVWDEXQGDQWIRRG

sources, transportation, and trade routes. As a result, prehistoric era archaeological sites and 

historic-era sites tend to be found along these waterways (NRC 2013a). As part of the recent 

License Renewal GEIS update, the NRC reviewed historic and cultural resource reviews that 

were performed for 40 license renewals. In these reviews, historic and cultural resource sites 

tend to occur in the less-developed or undeveloped portions of the site away from the power 

block. Many applicants conducted surveys to identify historic and cultural resources for their 

site-specific reactor license renewal and new reactor license applications, and they have 

developed and implemented historic and cultural resource management plans and procedures 

that protect known historic and cultural resources and address inadvertent discoveries. 

However some licensees may not have historic and cultural resource management plans or 

procedures. 

As discussed in Section 1.8, the NRC assumes that at-reactor ISFSIs are constructed onsite 

under a general or site-specific license during the term of reactor operations (including license 

renewal). NHPA Section 106 reviews are not conducted for construction of generally licensed 

ISFSIs, but have been and will continue to be performed for site-specific licensing actions (new 

reactor licensing, reactor license renewal, away-from-reactor ISFSIs, and specifically licensed 

at-reactor ISFSIs). In addition, as discussed in Section 3.11, less-developed or disturbed 

portions of a power plant site, including areas used to support construction of an at-reactor 

ISFSI (e.g., construction laydown areas), could still contain unknown historic and cultural 

resources. 

As discussed in more detail below, the NRC recognizes that there is uncertainty associated with 

the degree of prior disturbance and the resources, if any, present in areas where future grounddisturbing activities (e.g., initial and replacement DTS and replacement ISFSI) could occur. The 

NRC cannot eliminate the possibility that historic and cultural resources would be affected by 

construction activities during the long-term and indefinite timeframes because the initial ISFSI 

could be located within a less-disturbed area with historic and cultural resources in close 

proximity. Further, resources may be present that would not have been considered significant 

at the time the initial or replacement facilities were constructed, but could become significant in 

the future. For example, an existing nuclear power plant could, in the future, be considered a 

significant historic and cultural resource if its design represents a major advancement in power 

plant technology. 

4.12.1 Short-Term Storage 

During the short-term storage timeframe, the spent fuel pool would remain in operation until the 

transfer of the spent fuel from the pool to an at-reactor ISFSI. As discussed in Section 3.11, 

ground-disturbing activities occurred during initial nuclear power plant construction, and much of 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

the land within and immediately surrounding the power block was extensively disturbed. This 

activity would have eliminated any potential for historic and cultural resources to be present in 

these portions of the power plant site (i.e., power block). Continued operations and 

maintenance activities associated with spent fuel pools would not affect historic and cultural 

resources because spent fuel pools are located in the fuel building within the power block and 

most resources would have been removed during initial plant construction. 

As discussed in Section 3.11, less-developed or disturbed portions of a power plant site, 

including the areas that were used to support construction of the at-reactor ISFSI, could contain 

historic and cultural resources. For purposes of evaluating the impacts of continued storage in 

this GEIS, the NRC assumes that at-reactor ISFSIs are constructed during the period of reactor 

operations. Impacts associated with construction of an at-reactor ISFSI have already occurred 

and are not considered in the short-term storage timeframe. If ground-disturbing activities occur 

as a result of continued operations or maintenance, impacts could be mitigated if the licensee 

has previously identified historic and cultural resources and has management plans and 

protective procedures in place. Routine maintenance and continued operations of an at-reactor 

ISFSI are not expected to affect historic and cultural resources because no ground-disturbing 

activities are anticipated. However, if ground-disturbing activities occur as a result of continued 

operations or maintenance, impacts could be mitigated if the licensee has previously identified 

historic and cultural resources and has management plans and protective procedures in place. 

Because no ground-disturbing activities are anticipated during the short-term storage timeframe, 

there would be no impacts on historic and cultural resources. Therefore, impacts associated 

with continued operations and maintenance of the spent fuel pool and the at-reactor ISFSI on 

historic and cultural resources during the short-term timeframe would be SMALL. 

4.12.2 Long-Term Storage 

During the long-term timeframe, in addition to routine maintenance and monitoring, the NRC 

assumes that an at-reactor ISFSI will be replaced, which will require the construction and 

operation of a DTS. Further, the NRC assumes that the DTS is replaced once during the longterm timeframe. 

Impacts from continued operations and routine maintenance of the at-reactor ISFSI and DTS 

during long-term storage would be similar to those described in the short-term storage 

timeframe. The impacts would be small because there would be no ground-disturbing activities 

as a result of the continued operations and routine maintenance. 

NRC authorization to construct a DTS and replace a specifically licensed at-reactor ISFSI and 

DTS would constitute Federal actions under NEPA, would be undertakings under the NHPA, 

and would require a site-specific environmental review and compliance with NHPA requirements 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4- September 2014 

before making a decision on the licensing action. In accordance with 36 CFR Part 800, a 

Section 106 review would be conducted for each undertaking to determine whether historic 

properties are present in the area of potential effect, and if so, whether these actions would 

result in any adverse effects on these properties. License applicants are required to provide 

historic and cultural resource information in their Environmental Reports. To prepare these 

assessments, applicants conduct cultural resource surveys of any areas of proposed 

development to identify and record historic and cultural resources. Impacts on historic and 

cultural resources would vary depending on what resources are present. Resolution of adverse 

effects, if any, should be concluded prior to the closure of the Section 106 process. For 

generally licensed ISFSIs, impacts could be avoided, minimized, or mitigated if the licensee has 

management plans or procedures that require consideration of these resources prior to 

engaging in ground-disturbing activities. 

The NRC assumes that the replacement at-reactor ISFSI and initial and replacement DTS will 

be constructed on land near the existing facilities. As discussed in Section 3.11, grounddisturbing activities occurred during initial nuclear power plant construction, and much of the 

land within and immediately surrounding the power block was extensively disturbed. If 

replacement of the at-reactor ISFSI and placement of initial and replacement DTS occur within 

the power block, then impacts would likely be small because initial construction of the nuclear 

power plant would have eliminated any potential for historic and cultural resources to be 

present. However, ISFSIs are currently located outside the power block. If the replacement 

ISFSI and initial and replacement DTS are sited within previously disturbed areas, then impacts 

would likely be SMALL because initial construction of the ISFSI could have reduced the 

potential for historic and cultural resources to be present. However, if these facilities are located 

in less-developed or disturbed portions of a power plant site outside of the power block with 

historic and cultural resources present, including areas that were used to support construction of 

the at-reactor ISFSI, then there could be impacts to historic and cultural resources. 

Given the minimal size of the replacement ISFSI and initial and replacement DTS, and the large 

land areas at nuclear power plant sites, licensees should be able to locate these facilities away 

from historic and cultural resources. However, the NRC recognizes that it may not be possible 

for a licensee to avoid adverse effects on historic properties under NHPA or impacts on historic 

and cultural resources under NEPA. As discussed previously, existing at-reactor ISFSIs were 

constructed outside of the power block in less-developed or disturbed areas; thus, undiscovered 

historic and cultural resources could be present. The NRC believes that it is reasonable to 

assume that the replacement ISFSI and the initial and replacement DTS would be constructed 

near existing facilities because licensees may have, through decommissioning activities, 

reduced the NRC-licensed area to a smaller area around ISFSIs, and licensees would already 

have characterized and selected initial ISFSI sites to meet NRC siting, safety, and security 

requirements. The NRC believes that it is reasonable to assume that licensees would generally 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

avoid siting and operating an ISFSI away from the existing licensed area or outside previously 

characterized areas. The magnitude of adverse effects on historic properties and impacts on 

historic and cultural resources during the long-term timeframe largely depends on where the 

facilities are sited, what resources are present, the extent of proposed land disturbance, 

whether the area has been previously surveyed to identify historic and cultural resources, and 

whether the licensee has management plans and procedures that are protective of historic and 

cultural resources. Even a small amount of ground disturbance (e.g., clearing and grading) 

could affect a small but significant resource. In most, but not all instances, placement of storage 

facilities on the site can be adjusted to minimize or avoid impacts on any historic and cultural 

resources in the area. Before these ground-disturbing activities occur, the site-specific 

environmental review and compliance with the NHPA process could identify historic properties 

and historic and cultural resources that could be impacted. Under the NHPA, mitigation does 

not eliminate a finding of adverse effect on historic properties; but, impacts would be assessed 

at the time of the future licensing action. 

Based upon the considerations above, the potential impacts to historic and cultural resources 

during the long-term timeframe would range from SMALL to LARGE. This range takes into 

consideration routine maintenance and monitoring (i.e., no ground-disturbing activities), the 

absence or avoidance of historic and cultural resources, and potential ground-disturbing 

activities that could impact historic and cultural resources. In addition, the analysis considers 

uncertainties inherent in analyzing this resource area over long timeframes. These uncertainties 

include any future discovery of previously unknown historic and cultural resources; resources 

that gain significance within the vicinity and the viewshed (e.g., nomination of a historic district) 

due to improvements in knowledge, technology, and excavation techniques; and changes 

associated with predicting resources that future generations will consider significant. Potential 

adverse effects on historic properties or impacts on historic and cultural resources could be 

minimized through the development of agreements, license conditions, and implementation of 

the licensees’ historic and cultural resource management plans and procedures to protect 

known historic and cultural resources and address inadvertent discoveries during construction 

of the replacement at-reactor ISFSI and initial and replacement DTS. If construction of a DTS 

and replacement of the ISFSI and DTS occurs in an area with no historic or cultural resources 

present or construction occurs in a previously disturbed area that allows avoidance of historic 

and cultural resources then impacts would be SMALL. By contrast, a MODERATE or LARGE 

impact could result if historic and cultural resources are present at a site and, because they 

cannot be avoided, are impacted by ground-disturbing activities during the long-term timeframe. 

Accordingly, the NRC has concluded that the impacts on historic and cultural resources for the 

long-term timeframe would be SMALL to LARGE. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4- September 2014 

4.12.3 Indefinite Storage 

This section describes the potential environmental impacts on historic and cultural resources if a 

repository is not available to accept spent fuel. For this analysis, the NRC assumes that spent 

fuel would continue to be stored onsite indefinitely. During this timeframe, maintenance and 

monitoring would continue and the at-reactor ISFSI and DTS would be replaced every 

100 years. The NRC assumes that the replacement of the at-reactor ISFSI and DTS would be 

constructed on land near existing facilities. As stated in Section 1.8, the NRC assumes that the 

land where the original facilities were constructed would be available for replacement facility 

construction; however, the NRC cannot eliminate the possibility that historic and cultural 

resources would be affected by construction activities during the indefinite timeframe because 

the initial ISFSI could be located within a less-disturbed area with historic and cultural resources 

in close proximity. Further, resources may be present that would not have been considered 

significant at the time the initial or replacement facilities were constructed, but could become 

significant in the future. Impacts regarding the replacement of the ISFSI and DTS would be 

similar to those described in the long-term storage timeframe. 

Based upon the considerations above, the potential impacts to historic and cultural resources 

during the indefinite storage timeframe would range from SMALL to LARGE. This range takes 

into consideration routine maintenance and monitoring (i.e., no ground-disturbing activities), the 

absence or avoidance of historic and cultural resources, and potential ground-disturbing 

activities that could impact historic and cultural resources. In addition, the analysis considers 

uncertainties inherent in analyzing this resource area over long timeframes. These 

uncertainties include any future discovery of previously unknown historic and cultural resources; 

resources that gain significance within the vicinity and the viewshed (e.g., nomination of a 

historic district) due to improvements in knowledge, technology, and excavation techniques or 

changes associated with predicting resources that future generations will consider significant. 

Potential adverse effects on historic properties or impacts on historic and cultural resources 

could be minimized through development of agreements, license conditions, and the 

implementation of the licensees’ historic and cultural resource management plans and 

procedures to protect known historic and cultural resources and address inadvertent discoveries 

during construction of the replacement at-reactor ISFSI and replacement DTS. If construction of 

a DTS and replacement of the ISFSI and DTS occurs in an area with no historic or cultural 

resource present or construction occurs in previously a disturbed area that allows avoidance of 

historic and cultural resources then impacts would be SMALL. By contrast, a MODERATE or 

LARGE impact could result if historic and cultural resources are present at a site and, because 

they cannot be avoided, are impacted by ground-disturbing activities during the indefinite 

timeframe. Accordingly, the NRC has concluded that the impacts on historic and cultural 

resources for the indefinite timeframe would be SMALL to LARGE. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

4.13 Noise 

This section describes potential noise impacts caused by the continued storage of spent fuel in 

spent fuel pools and at-reactor ISFSIs. 

4.13.1 Short-Term Storage 

During short-term storage, spent fuel pool systems would remain in operation to ensure 

adequate cooling prior to the transfer of spent fuel from the pools to an at-reactor ISFSI. Most 

noise would be generated when spent fuel is transferred from the spent fuel pool to the ISFSI. 

Once reactor operations cease, there would be less noise generated because some of the 

noise-generating equipment and activities would either cease or operate at lower levels. 

Therefore, short-term storage noise levels would be less than reactor operation noise levels. 

The License Renewal GEIS (NRC 2013a) analyzed the environmental impacts associated with 

continued reactor operations during the license term of a nuclear power plant. Facility noise 

levels at operating reactor sites PD\VRPHWLPHVH[FHHGG%$RYHUD-hour period, which 

is the threshold EPA identified to protect residential areas against excess noise during outdoor 

DFWLYLWLHV15&D(3$$VGLVFXVVHGLQ6HFWLRQWKHSULPDU\IDFWRUVWKDW

influence impact magnitude are the noise level of the source and the proximity of the source to 

the receptor. Proximity matters because noise levels decrease as distance from the source 

increases. For point sources like stationary equipment, noise is reduced by about 6 dB(A) for 

each doubling of distance from the source, and for a line source, like a road, noise is reduced by 

G%$SHUGRXEOLQJRIWKHGLVWDQFH:DVKLQJWRQ6WDWH'HSDUWPHQWRI7UDQVSRUWDWLRQ2014). 

As stated in the License Renewal GEIS (NRC 2013a), in most cases, the sources of noise are 

far enough away from sensitive receptors that the noise is attenuated to nearly ambient levels 

and is scarcely noticeable. However, in some cases noise from reactor operations can be 

detected relatively close to the site boundary and create a minor nuisance. 

As described earlier in this section, noise levels would be lower once reactor operations cease. 

Noise sources associated with spent fuel pool storage include water cooling-system equipment, 

spent fuel-handling equipment, and in some cases vehicles to transport spent fuel from pools to 

dry cask storage pads. Some of the noise from equipment associated with spent fuel pool 

storage is attenuated because the activities occur inside a building, which functions as a noise 

barrier. Spent fuel handling and transfer would be infrequent, so the noise generated from 

these activities would also occur infrequently. Typically, pool storage sites produce no noise 

impacts on the local environment (NRC 2004c). 

As described in Section 3.12, spent fuel casks resting on concrete pads are essentially passive, 

without any sources generating noise. Noise from routine maintenance and monitoring as well 

as from ancillary activities such as operation of the administration buildings would be minimal. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4- September 2014 

Even in rare cases where an independently operating spent fuel pool causes noise impacts that 

exceed the EPA-recommended threshold for outdoor noise, licensees are usually able to make 

engineering changes to address the problem. For example, at the Maine Yankee nuclear power 

plant the licensee set up the pool storage operations to operate independently from the reactor, 

which was being decommissioned. The fans used as part of the spent pool cooling-system 

JHQHUDWHGQRLVHOHYHOVXSWR G%ZKLFKDWWHQXDWHGWRG%OHVVWKDQNPPLDZD\

15&E7KLVQRLVHOHYHOH[FHHGHGWKHG%$WKUHVKROGUHFRPPHQGHGE\WKH(3$IRU

protection against outdoor activity interference and annoyance. Nearby residents complained to 

the plant staff about the noise level, and the licensee made engineering changes to the fans that 

were causing the noise and the issue was resolved. 

In conclusion, the operation noise levels, duration, and distance between the noise sources and 

receptors generally do not produce noise impacts noticeable to the surrounding community. In 

certain cases, such as the Maine Yankee spent fuel pool island, potential noise impacts on 

receptors closest to the site property line can experience unmitigated noise levels that exceed 

EPA-recommended noise levels. However, noticeable noise levels are generally not expected 

and would be limited to the nearest receptors. Therefore, the NRC concludes that the overall 

impact from noise during short-term storage would be SMALL. 

4.13.2 Long-Term Storage 

In addition to routine maintenance and monitoring, the NRC assumes that long-term storage 

would include the construction, operation, and replacement of a DTS and the replacement of the 

ISFSI. Construction of a DTS would generate higher noise levels than DTS operations. The 

NRC assumes that DTS construction would take 1–2 years. Construction equipment would be 

used to grade and level the site, excavate the facility foundation, handle building materials, and 

build the facility. Construction equipment generates noise levels over 90 dB(A) (at a reference 

GLVWDQFHRIP>IW@IURPWKHVRXUFH15&E$WGLVWDQFHVJUHDWHUWKDQDERXWNP

(1 mi), expected maximum noise levels from construction equipment would be reduced to about 

G%$ which is the EPA-recommended level for protection in residential areas against 

outdoor activity interference and annoyance (NRC 2002b). 

During operation of the DTS, some activities would be conducted inside the building, which 

functions as a noise barrier. Spent fuel transfer between the storage pad and the DTS would be 

infrequent. The NRC expects noise levels from this transfer of spent fuel to be no more than the 

noise level generated transferring spent fuel from the pool to the dry pad, as described in 

Section 4.13.1. In addition, some of the reactor and spent fuel pool storage noise sources 

present during short-term storage (such as the cooling towers and associated equipment) would 

not be present during long-term storage. 

The NRC assumes that the at-reactor ISFSI (i.e., concrete storage casks and pads) and the 

DTS would be replaced within the 100-year timeframe. Similar to the DTS construction, ISFSI 

and DTS replacement uses construction equipment, which can generate noise levels over 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

90 dB(A). The noise levels exceed the EPA-recommended level for protection against outdoor 

activity interference and annoyance (NRC 2002b). However, distance from the source will 

eventually reduce the noise level to below the EPA-recommended level for protection against 

outdoor activity interference and annoyance. 

Construction and replacement of the DTS, although temporary and representing a small portion 

of the overall long-term storage timeframe, would generate noise levels that exceed EPArecommended noise levels. Operational noise levels would not produce noise impacts 

noticeable to the surrounding community. For some activities (e.g., replacement of the DTS 

and ISFSI facilities), potential noise impacts on receptors closest to the site property line can 

experience unmitigated noise levels that exceed EPA-recommended noise levels. However, 

these activities are temporary and noticeable noise levels would be limited to the nearest 

receptors. Therefore, the NRC concludes that the overall impact from noise during long-term 

storage would be SMALL. 

4.13.3 Indefinite Storage 

This section describes the noise impacts in the event a repository is not available to accept 

spent fuel and the spent fuel must be stored indefinitely in ISFSIs. Impacts from indefinite 

storage would be similar to those described for the long-term storage timeframe. The NRC 

does not anticipate that indefinite storage in an ISFSI would generate any new or additional 

noise in comparison with the noise impacts described for the long-term storage timeframe. 

Therefore, the NRC concludes that the overall impact from noise during indefinite storage would 

be SMALL. 

4.14 Aesthetics 

This section describes potential impacts on aesthetic resources caused by continued storage of 

spent fuel in spent fuel pools and at-reactor ISFSIs. 

4.14.1 Short-Term Storage 

No changes to nuclear power plant structures will be required for continued operation of the 

spent fuel pool during continued storage, including routine maintenance and monitoring. 

In the License Renewal GEIS, the NRC determined that the aesthetic impacts associated with 

continued operation of a nuclear power plant, which included the continued operation of the 

spent fuel pool, were SMALL because the existing visual profiles of nuclear power plants were 

not expected to change during the license renewal term (NRC 2013a). Therefore, the NRC 

concludes that the potential impacts from the short-term continued operation of the spent fuel 

pool would be of minor significance to aesthetic resources. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4- September 2014 

For at-reactor ISFSIs, NRC evaluations of existing ISFSIs have found the aesthetic impacts to 

be SMALL. For example, the NRC found that continued operation of the Calvert Cliffs ISFSI 

would have a SMALL impact on aesthetic resources in part because there would be no new 

construction at the facility (NRC 2012a). Similarly for Humboldt Bay, the NRC determined that 

WKHDHVWKHWLFLPSDFWZRXOGEHPLQLPDO15&DEHFDXVHWKH+XPEROGW%D\,6)6,LVDQ

in-ground vault with a low visual profile. Given that the NRC assumes that all ISFSIs are 

constructed during the nuclear power reactor’s licensed life for operation, the visual profile of 

at-reactor ISFSIs during short-term storage is expected to be the same after the permanent 

cessation of reactor operations. The NRC therefore believes that potential impacts from shortterm continued storage in at-reactor ISFSIs would be of minor significance to aesthetic 

resources. 

This assessment of visual impacts depends in part on the degree of public interest and concern 

about potential changes to the existing scenic quality. However, because no changes to the 

visual profile are likely to occur as a result of the continued operation and maintenance of the 

existing spent fuel pool and ISFSI, the NRC concludes that the impacts from short-term storage 

of spent fuel on aesthetics would be SMALL.

4.14.2 Long-Term Storage 

As discussed in the previous section, routine maintenance is not expected to have an impact on 

aesthetic resources. The NRC assumes that a DTS would need to be constructed during the 

long-term storage timeframe. Construction and operation of a DTS would have limited impacts 

on aesthetic resources. A DTS (approximately PîP>26 ft × 18 ft@ and about 14 m 

> ft@ tall) is likely to have a larger visual profile than other ISFSI structures; however, it would 

not be expected to provide a significant visual contrast to the surrounding landscape. There 

would be temporarily adverse impacts on aesthetic resources during construction of the DTS, 

resulting from the presence and operation of the construction equipment used to build the 

facility. However, because a DTS is a relatively small facility (e.g., compared to a nuclear power 

plant) and many of the internal components of the facility would be prefabricated, the 

construction of a DTS would take less time and equipment to build, and it would have a minimal 

impact on aesthetic resources. 

Replacement of the ISFSIs and DTSs within the 100-year timeframe would occur on land near 

existing facilities. The NRC assumes that the overall land disturbed, and hence the visual 

profile of the facility, would not increase because the old ISFSIs and DTSs would be demolished 

and the land reclaimed. Impacts on aesthetic resources would likely temporarily increase during 

the period of construction of the new facilities and demolition of the old, when the most visible 

features are likely to be equipment associated with cask handling. Aesthetic impacts from such 

equipment and its operation would be minimal. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

Because continued operation of the ISFSI, construction and operation of the DTS, and 

replacement of the ISFSIs and DTSs would not significantly alter the landscape of an at-reactor 

ISFSI, the NRC concludes that the potential environmental impacts on aesthetic resources 

during long-term storage would be SMALL. 

4.14.3 Indefinite Storage 

If a repository is not available, current practices of using at-reactor ISFSIs are expected to 

continue indefinitely. At the end of each 100-year cycle, the previously reclaimed land would be 

used to construct the replacement ISFSIs and DTSs. The potential activities and their impacts 

would be the same as those described in Section 4.14.2 for long-term storage, but would 

continue to occur repeatedly. Therefore, the NRC concludes that the indefinite onsite storage of 

spent fuel would result in SMALL impacts on aesthetic resources. 

4.15 Waste Management 

This section describes potential environmental impacts from low-OHYHOUDGLRDFWLYHZDVWH//:

mixed waste, and nonradioactive waste management and disposal caused by the continued 

storage of spent fuel in spent fuel pools and at-reactor ISFSIs. 

Section 3.14 identified the types of waste generated by continued storage of spent fuel, 

LQFOXGLQJ//:PL[HGZDVWHKD]DUGRXVZDVWHand nonradioactive, nonhazardous waste. The 

environmental impacts of hazardous waste and nonradioactive, nonhazardous waste are 

discussed together in this section as nonradioactive waste, unless otherwise noted. 

Impacts from the transportation of waste are discussed in Section 4.16. The public and 

occupational health impacts associated with at-reactor radioactive waste-management activities 

DWQXFOHDUSODQWVDUHDGGUHVVHGLQ6HFWLRQ

4.15.1 Short-Term Storage 

7KHLPSDFWVDVVRFLDWHGZLWKWKHPDQDJHPHQWDQGGLVSRVDORI//:PL[HGZDVWHDQG

nonradioactive waste during short-term continued storage are discussed in the following 

sections. 

4.15.1.1 Low-Level Radioactive Waste 

The continued operation of a spent fuel pool would JHQHUDWHPLQLPDODPRXQWVRI//:VXFKDV

wet wastes from processing and recycling contaminated liquids. In the License Renewal GEIS, 

the environmental impacts associated with the management, onsite storage, and disposal of 

//:for an additional 20 years of operation were determined to be SMALL during normal 

reactor operation 15&D7KH15&FRQFOXGHGLPSDFWVIURP//:ZRXOGEH60$//
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-60 September 2014 

because of the regulatory controls in place, low public dose being achieved, and reasonable 

DVVXUDQFHWKDWVXIILFLHQW//:GLVSRVDOFDSDFLW\ZLOOEHPDGHDYDLODEOHZKHQQHHGHGIRU

facilities to be decommissioned. 

7KHDPRXQWRI//:JHQHUDWHGIURPWKHRSHUDWLRQDQGPDLQWHQDQFHRIDQDW-reactor ISFSI 

during short-term storage is expected to be minimal. For example, in the Calvert Cliffs ISFSI 

renewal EA (NRC 2012a), the NRC determined that the impacts from waste management would 

EH60$//PDLQO\EHFDXVHRIWKHVPDOOTXDQWLWLHVRI//:EHLQJJHQHUDWHGDQGWKHIDFWWKDt 

those wastes would be handled and disposed of according to regulatory requirements. 

Comprehensive regulatory controls, facilities, and procedures are in place at operating reactors 

WRHQVXUHWKDWWKH//:LVSURSHUO\KDQGOHGDQGVWRUHGDQGWKDWGRVHVDQGexposure to the 

public and the environment are negligible at all plants (NRC 2013a). These same regulatory 

controls are expected to remain in effect during short-term continued storage of spent fuel. 

Because short-term continued storage of spent fuel woulGJHQHUDWHPXFKOHVV//:WKDQDQ

operating reactor and licensees would continue to implement Federal and State regulations and 

UHTXLUHPHQWVIRUSURSHUPDQDJHPHQWDQGGLVSRVDORI//:WKH15&FRQFOXGHVWKDWWKH

environmental impact from the management and dLVSRVDORI//:ZRXOGEH60$//IRUDOO

waste-management facilities. 

4.15.1.2 Mixed Waste 

The amount of mixed waste generated from the operation and maintenance of the spent fuel 

pool and the ISFSI is expected to be minimal compared to that of an operating reactor. After 

reactor operations cease, most waste-generating activities, as described in Section 3.14, would 

also cease, except for those associated with continued storage. 

In the License Renewal GEIS, the NRC determined that the radiological and nonradiological 

environmental impacts from the storage and disposal of mixed waste would be SMALL for all 

operating reactor sites (NRC 2013a) because of the small quantities generated and 

comprehensive regulatory controls in place to ensure that this waste is properly managed and 

that doses to the public and environment are negligible. In addition, as an example, the EIS for 

the Fermi Unit 3 combined license states that 0.416 m3\U\G3/yr) of mixed waste would 

be generated during operation. Because the amount of mixed waste generated during shortterm continued storage would be less than the relatively small amount estimated for reactor 

license renewal, the impacts in the License Renewal GEIS would bound the impacts for mixed 

waste during continued storage. 

Comprehensive regulatory controls, facilities, and procedures are expected to remain in place 

during short-term continued storage of spent fuel, which will ensure that mixed waste is properly 

managed so that exposure to the public and the environment are negligible at all storage sites. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-61 185(*௅

Because short-term storage of spent fuel would generate much less mixed waste than an 

operating reactor and licensees would continue to implement Federal and State regulations 

regarding proper management and disposal of mixed waste, the NRC concludes that the 

environmental impacts from the management and disposal of mixed waste would be SMALL. 

4.15.1.3 Nonradioactive Waste 

The amount of nonradioactive waste generated from the operation and maintenance of an 

at-reactor ISFSI is expected to be minimal compared to that of an operating reactor. After 

reactor operations cease, most waste-generating activities would also cease, except for those 

associated with short-term storage. 

The impacts associated with the storage and disposal of nonradioactive wastes at operating 

nuclear power plants were determined to be SMALL in the License Renewal GEIS 

(NRC 2013a), because although the quantities of waste generated are highly variable, they are 

generally less than amounts generated at other industrial facilities. After reactor operations 

cease, most waste-generating activities would also cease, except for those associated with 

continued storage. Because the amount of waste generated during short-term storage would be 

less than that estimated for reactor license renewal, the impacts in the License Renewal GEIS 

would bound the impacts for nonradioactive waste during short-term continued storage. 

For example, in EISs for the licensing of new reactors (e.g., Fermi 3 and Lee), the impacts 

associated with the storage and disposal of nonradioactive waste, including hazardous waste, 

were determined to be SMALL, primarily because the wastes would be handled and disposed of 

according to County and State regulations (NRC 2013b,d). 

The handling and disposal of hazardous wastes are regulated by the EPA or the responsible 

State agencies in accordance with the requirements of RCRA. Nonhazardous wastes are 

managed onsite and are generally disposed of in landfills permitted locally under RCRA 

Subtitle 'UHJXODWLRQV6LPLODUWR//:DQGPL[HGZDVWHQRQUDGLRDFWLYHZDVWHZRXOGFRQWLQXH

to be managed according to local, State, and Federal regulatory requirements. 

Because short-term storage of spent fuel would generate less nonradioactive waste than an 

operating reactor, which was previously determined to have a SMALL impact, and licensees 

would continue to implement Federal and State regulations regarding proper management and 

disposal of nonradioactive waste, the NRC concludes that the environmental impact from the 

management and disposal of nonradioactive waste would be SMALL. 

4.15.2 Long-Term Storage 

Ongoing routine maintenance would continue to generate minimal amounts of waste. The NRC 

assumes that, during this long-term storage timeframe, a DTS would need to be constructed 

and operated. In addition, the DTS and ISFSI facilities (including casks and concrete pads) 

would need to be replaced. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-62 September 2014 

4.15.2.1 Low-Level Radioactive Waste 

Routine maintenance and monitoring of the ISFSI would continue to occur, which would 

generatHPLQLPDODPRXQWVRI//:7KH15&DQWLFLSDWHVQR//:ZRXOGEHJHQHUDWHGE\RQVLWH

construction activities associated with the DTS. 

During long-term storage, storage canisters will reach the end of their design life and require 

replacement. The replacement process will involve the transfer of spent fuel assemblies to new 

canisters and decontamination and disposal of the old canisters. The repackaging process is 

expected to generate types of dry wastes similar to those described for normal operations 

(e.g., clothing and tools) and radioactively contaminated storage canisters that would be 

KDQGOHGDQGGLVSRVHGRIDV//:%HFDXVHVWRUDJHFDQLVWHUVFRPHLQWRGLUHFWFRQWDFWZLWK

spent fuel, it is possible that the metal components could become contaminated or activated 

DQGUHTXLUHGLVSRVDODV//:(35,

All spent fuel repackaging would be performed in the DTS. The repackaging process consists 

of removal of the spent fuel assemblies from the old canister and their placement into a new 

canister. For example, in the Calvert Cliffs ISFSI renewal EA (NRC 2012a), the NRC estimated 

that less than 0.06 m3 (2 ft3SHUFDQLVWHURI//:ZRXOGEHJHQHUDWHGGXULQJFDVNORDGLQJDQG

decontamination, based on a horizontal storage module design such as that described in 

6HFWLRQ7KLV//:ZRXOG consist of garments, tapes, and cloths, and would be 

processed by compaction. In addition, the old canister would require disposal. Because 

storage canisters come into direct contact with spent fuel for an extended period of time, it is 

assumed that the dry storage canister and any internal components have become activated or 

UDGLRDFWLYHO\FRQWDPLQDWHGDQGUHTXLUHGLVSRVDODV//:(35,)RUH[DPSOHWKH

NUHOMS 32P–S100 dry storage canister licensed for use at the Calvert Cliffs ISFSI has a 

compacted nominal volume of 1.3 m3 (yd3) (Transnuclear, Inc. 2004) that must be managed 

DQGGLVSRVHGRIDV//:5HSDFNDJLQJDQGUHSODFHPHQWRIcanisters would generate 

approximately 193 m3 (2 yd3) of FRPSDFWHG//:

In addition to repackaging the spent fuel during long-term storage, the ISFSI would need to be 

replaced. For purposes of this analysis, because the activities associated with the replacement 

and demolition of the ISFSI are similar to decommissioning activities, the TXDQWLWLHVRI//:

generated from the replacement of casks, horizontal storage modules, and concrete pads are 

expected to be similar to those considered in decommissioning funding plans provided to the 

15&LQDFFRUGDQFHZLWK&)5E)RUH[DPSOHPDQ\SODQVVWDWHWKDWQR//:will be 

generated from demolition of ISFSI structures because the dry cask storage systems are 

designed to prevent leaks and the contained spent fuel does not generate sufficiently high levels 

of neutron radiation to activate materials used in construction of the systems. However some 

plans state that neutron activation is possible (Duke Energy 2013, Pacific Gas and Electric 

&RPSDQ\DQGFRXOGUHVXOWLQTXDQWLWLHVRI//:JHQHUDWHGGXULQJ,6)6,GHFRPPLVVLRQLQJ

IURPDERXWWRP3 (94 to 346 yd3). 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-63 185(*௅

Replacing the DTS during long-WHUPVWRUDJHWLPHIUDPHZRXOGUHVXOWLQDVPDOODPRXQWRI//:

generated from removing contamination from the DTS. The primary source of contamination is 

spalled crud from spent fuel cladding. However, the spent fuel is enclosed by a transfer tube 

through most of the spent fuel transfer process. The transfer tube is the only piece of 

HTXLSPHQWWKDWZLOOQRWEHGHFRQWDPLQDWHGDQGWKXVZLOOQHHGWREHGLVSRVHGRIDV//: All 

RWKHUPDMRUHTXLSPHQWDQGVWUXFWXUHVRIWKH'76ZLOOEHGHFRQWDPLQDWHG7KHYROXPHRI//:

is estimated by DOE to be 20--gallon drums, or about 4 to 8 m3 WR\G3) (DOE 1996). 

,QVXPPDU\//:LVJHQHUDWHGGXULQJWKHORQJ-term timeframe during spent fuel repackaging 

operations, by unloading and loading operations, compaction of canisters removed from service, 

by replacement of storage casks, horizontal storage modules, and concrete pads, and by 

replacement of the DTS. Using the maximum values in the range described above, this volume 

RI//:LVH[SHFWHGWREHQRPRUHWKDQDERXW80 m3 (630 yd3). 

The NRC previously determined that waste generated during reactor decommissioning would 

have a SMALL impact (NRC 2013a) and waste generated during ISFSI license renewal would 

also have a SMALL impact (NRC 2012a). 7KHDPRXQWRI//:JHQHUDWHGE\WKHUHSODFHPHQWRI

the ISFSI and DTS would be a fraction of the estimated over P3 (over 9,000 yd3RI//:

generated during reactor decommissioning (NRC 1996). Because waste generated during the 

long-term storage timeframe would be less than that generated during reactor 

decommissioning, the 15&H[SHFWVWKDW//:JHQHUDWHGGXULQJUHSODFHPHQW of an ISFSI and 

DTS would be minimal. 

%HFDXVH//:ZRXOGFRQWLQXHWREHPDQDJHGDFFRUGLQJWR)HGHUDOUHJXODWLRQVDQGWKHGLVSRVDO

FDSDFLW\IRU//:LVH[SHFWHGWREHDYDLODEOHZKHQQHHGHGVHH6HFWLRQWKH15&

GHWHUPLQHVWKHLPSDFWVIURP//:PDQDJHPHnt and disposal would be SMALL during long-term 

storage. 

4.15.2.2 Mixed Waste 

Routine maintenance and monitoring of the ISFSI would continue during long-term storage, and 

would generate minimal amounts of mixed waste. The repackaging of spent fuel, construction 

and operation of a DTS, and the replacement of the ISFSIs and DTSs are not expected to 

generate mixed waste. However, if mixed waste is generated, it would be a small fraction of 

that generated by an operating nuclear power plant and it would be managed according to 

regulatory requirements. 

Due to the type of activities occurring during long-term storage that are expected to generate 

minimal to no mixed waste and because the quantity of mixed waste generated from the 

operation and replacement of the ISFSIs and DTSs is expected to be a small fraction of that 

generated during the licensed life of the reactor, the radiological and nonradiological 

environmental impacts associated with the management and disposal of mixed waste are 

expected to be SMALL during long-term storage. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-64 September 2014 

4.15.2.3 Nonradioactive Waste 

Routine maintenance and monitoring of the ISFSI would continue to generate minimal amounts 

of nonradioactive waste. The construction and operation of a DTS would be expected to 

generate nonradioactive nonhazardous waste similar to that generated during ISFSI 

construction (e.g., construction debris, packaging material, and worker trash, and small 

quantities of nonradioactive hazardous wastes like paint waste, solvents, pesticides, and 

cleaning supplies). 

Repackaging of the canisters could generate some amount of nonradioactive waste if the waste 

were never contaminated. Replacing the DTS and ISFSI facilities (including casks and storage 

pads), would generate nonradioactive waste primarily nonhazardous waste. The 

noncontaminated portions of the storage modules, concrete pads, and DTS building would be 

demolished and disposed of as construction debris in a landfill. 

6LPLODUWR//:HVWLPDWHVWKHDPRXQWRIQRQUDGLRDFWLYHZDVWHJHQHUDWHGIURPFDVNDQGIDFLOLW\

replacement is based on decommissioning estimates. However, specific quantities of 

nonradioactive waste are difficult to estimate because the amount of waste will depend on 

whether the materials were contaminated during storage. 

Based on the NUHOMS cask design described in Section 2.1.2.2, a single storage module 

volume is  m3 ( yd3) of concrete and steel. The amount of material would be similar for 

vertical storage cask designs, as described in Section 2.1.2.2. Some portion of this volume 

would lLNHO\EHGLVSRVHGRIDV//:GXHWRFRQWDPLQDWLRQEXWWKHPDMRULW\RIWKHZDVWHZRXOGEH

disposed of as nonradioactive waste. A 1-m (3-ft) thick ISFSI pad capable of supporting 

 NUHOMS horizontal storage modules, based on the example facility described in 

Section 2.1.2.2, would contain about 13,200 m3 ( yd3) of concrete that would need to be 

demolished and disposed of as demolition debris. The amount of concrete would be similar for 

vertical storage cask designs, as described in Section 2.1.2.2. 

The NRC estimated the volume of nonradioactive (primarily nonhazardous) waste from the 

replacement of the DTS using DTS component weights in Table 8.A.1-3 of the DTS Topical 

Safety Analysis Report (DOE 1996). The total weight of the DTS is estimated to be about 

NJlb), nearly all of which is reinforced concrete. This corresponds to 

about 860 m3 (1,130 yd3) of nonradioactive waste. 

Routine maintenance, fuel repackaging, and construction and operation of the DTS and 

replacement of the DTS and ISFSI are expected to generate nonradioactive waste that would be 

handled in accordance with regulatory requirements and disposed of at an appropriately 

permitted disposal facility. Although a large amount of nonradioactive nonhazardous waste 

would be generated by the removal of the storage modules, storage pads and DTS 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

(approximately 22,000 m3 >29,000 yd3@LWZRXOGVWLOOEHOHVVWKDQWKHDPRXQWRIZDVWH

generated during reactor decommissioning (which NRC already determined would have a 

SMALL impact), and it would not likely have a noticeable impact on local or regional landfill 

capacity and operations. Therefore, the NRC determines that the environmental impact from 

the management and disposal of nonradioactive waste would also be SMALL during long-term 

storage. 

4.15.3 Indefinite Storage 

This section evaluates the potential environmental impacts from the management and disposal 

RI//:PL[HGZDVWHDQGQRQUDGLRDFWLYHZDVWHIURPWKHLQGHILQLWHDW-reactor storage of spent 

fuel. The waste-generating activities during this timeframe include the same activities discussed 

in for long-term storage but with the activities occurring every 100 years. 

4.15.3.1 Low-Level Radioactive Waste 

7KHDFWLYLWLHVDVVRFLDWHGZLWKWKHPDQDJHPHQWDQGGLVSRVDORI//:IURPLQGHILQLWHDW-reactor 

storage of spent fuel would be similar to those described for long-term storage. As stated in 

6HFWLRQLWLVH[SHFWHGWKDWVXIILFLHQW//:GLVSRVDOFDSDFLW\ZLOOEHPDGHDYDLODEOHZKHQ

needed. Similar to long-term storage, the NRC concludes the management and disposal of 

//:FRXOGUHVXOWLQ60$//HQYLURQPHQWDOLPSDFWVGXULQJLQGHfinite storage of spent fuel. 

4.15.3.2 Mixed Waste 

The activities associated with managing and disposing of mixed waste from the indefinite 

at-reactor storage of spent fuel after the licensed life for operations will be similar to those 

discussed for long-term storage. Because of the relatively small quantity of mixed waste 

generated from indefinite storage and licensee adherence to proper management and disposal 

regulations, the NRC concludes that the indefinite management of mixed wastes resulting from 

at-reactor storage of spent fuel would result in SMALL impacts. 

4.15.3.3 Nonradioactive Waste 

Although the activities associated with managing and disposing of nonradioactive waste from 

indefinite at-reactor storage will be similar to those discussed for long-term storage, the amount 

of nonradioactive waste being generated is difficult to accurately estimate over an indefinite 

timeframe. Therefore, the NRC concludes the management and disposal of nonradioactive 

waste could result in SMALL to MODERATE impacts, due to nonradioactive nonhazardous 

waste disposal capacity. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-66 September 2014 

4.16 Transportation 

This section describes potential transportation impacts caused by the continued at-reactor 

storage of spent fuel in spent fuel pools and ISFSIs. 

The potential impacts from transportation activities include fugitive dust emissions, increased 

traffic on local roads, worker and public exposure to radiation, and accident risks. The potential 

impacts from transportation of spent fuel to a repository or to an away-from-reactor storage 

facility are not evaluated in this section. Activities and impacts associated with transportation of 

spent fuel to a repository would occur after continued storage and are addressed as cumulative 

impacts in Chapter 6. The transportation activities to move spent fuel to an away-from-reactor 

,6)6,GXULQJFRQWLQXHGVWRUDJHDUHDGGUHVVHGLQ&KDSWHU$LUHPLVVLRQVDUHHYDOXDWHGLQ

Section 4.4. The generic analysis in this GEIS is supported by a survey of recent site-specific 

analyses that were completed by the NRC for new reactors. This transportation analysis 

considers the impacts of transportation activities during continued storage on the affected 

environment beyond the site boundary. The environmental impacts evaluated include the 

nonradiological impacts on regional traffic and accidents from worker commuting, supply 

shipments, and waste shipments and the public and worker radiological safety impacts from 

VKLSPHQWVRI//:JHQHUDWHGE\continued storage activities. 

4.16.1 Short-Term Storage 

Impacts on traffic from workers commuting to and from the power plant site during the shortterm storage timeframe depend on the size of the workforce, the capacity of the local road 

network, traffic patterns, and the availability of alternate commuting routes to and from the 

facility. :KLOHZRUNIRUFHOHYHOVDUHH[SHFWHGWRYDU\DPRQJFRQWLQXHGVWRUDJHIDFLOLWLHV

(including ISFSIs and spent fuel pools), the limited nature of storage operations relative to 

power plant operations and the low reported and estimated storage workforce size indicate that 

the workforce needed to support short-term storage would be much smaller than the power 

plant workforce. For example, an operational full-time workforce of fewer than 20 workers has 

been documented for wet storage (safe storage mode) at the GEH Morris ISFSI (NRC 2004c) 

and a 200-person workforce has been estimated for dry cask ISFSI fuel-transfer and loading 

operations at the Fort St. Vrain facility (NRC 1991d). For comparison, the operational workforce 

at nuclear power plants ranges from 600 to 2,400 permanent personnel (NRC 2013a) with an 

additional 1,000 or more temporary workers needed to support refueling operations 

(NRC 2011c). The environmental impact on traffic from renewal of operations of nuclear 

reactors was evaluated generically in the License Renewal GEIS (NRC 2013a), which 

concluded the impacts on traffic from commuting workers would be SMALL. Because at-reactor 

ISFSI and spent fuel pool operations represent a small proportion of the operations at any 

reactor site, the NRC concludes the traffic impacts of continuing the storage activities during the 

short-term timeframe would continue to be a fraction of the small traffic impacts realized during 

the period of reactor operations. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

The operation of the at-reactor ISFSI and spent fuel pool would generate a small amount of 

//:HJXVHGSHUVRQDOSURWHFWLRQHTXLSPHQWDQGZDVWHVUHODWHGWRSRRO–to-cask transfer 

activities) relative to power plant operations that would result in infrequent waste shipments to a 

OLFHQVHGGLVSRVDOIDFLOLW\7KH$WRPLF(QHUJ\&RPPLVVLRQ$(&HVWLPDWHGWKHDQQXDO

DPRXQWRI//:JHQHUDWHGIURPDW\SLFDO-0:HRSHUDWLQJOLJKWZDWHUUHDFWRUZDVP3

(141 yd3), UHVXOWLQJLQDVPDQ\DV VKLSPHQWVRIZDVWHSHU\HDUDVVXPLQJP3 (1.8 ft3) 

SHUGUXPDQGGUXPVSHUWUXFN0RUHUHFHQWHVWLPDWHVRIDQQXDO//:JHQHUDWHGE\SRZHU

plants with higher power ratings are comparable (NRC 2011d) or as much as four times higher 

(NRC 2013d) than the previously reported 108 m3 (141 yd3) value but would represent, on 

average, less than one shipment per day. The small and infrequent number of shipments and 

compliance with NRC and U.S. Department of Transportation (DOT) packaging and 

transportation regulations would limit potential worker and public radiological and 

nonradiological impacts from these waste shipments. The radiological impacts on the public 

DQGZRUNHUVRI//:VKLSPHQWVIURPDUHDFWRUKDYHEHHQSUHYLRXVO\ evaluated by the NRC. 

A generic impact determination in Table S–4 in 10 CFR DQGVXSSRUWLQJDQDO\VLV

(AEC FRQFOXGHWKDWWKHHQYLURQPHQWDOLPSDFWVRIWKHWUDQVSRUWDWLRQRIIXHODQGZDVWHWR

and from a light water reactor under normal operations of transport and from accidents during 

WUDQVSRUWZRXOGEH60$//6XEVHTXHQWDQDO\VLVRI//:WUDQVSRUWDWLRQLPSDFWVLQFinal 

Environmental Statement on Transportation of Radioactive Material by Air and Other Modes

15&FRQFOXGHGWUDQVSRUWDWLRQLPSDcts are small. Additional site-specific analyses of 

WUDQVSRUWDWLRQLPSDFWVIRUSRZHUSODQWVWKDWGLGQRWPHHWWKHFRQGLWLRQVRI&)5DOVR

concluded the transportation radiological impacts would be SMALL (NRC 2006b,c; 2008b; 

2011a,d–f; 2013a). BecDXVH//:ZDVWH-generating activities for continued storage would be a 

IUDFWLRQRIWRWDOSRZHUSODQW//:-generating activities, the short-WHUPVWRUDJH//:ZDVWH

shipments would also result in a small fraction of the impacts realized for waste shipment during 

the period of reactor operations. 

Based on the preceding analysis that describes the low volume of traffic and shipping activities 

associated with the continued storage of spent fuel in at-reactor ISFSIs and spent fuel pools, the 

NRC concludes the impacts on traffic and public and worker radiological and nonradiological 

safety from transportation activities would be SMALL during the short-term storage timeframe. 

4.16.2 Long-Term Storage 

As discussed in Section 1.8, the NRC assumes that the spent fuel would need to be repackaged 

during this timeframe, and that the ISFSI would be replaced. To facilitate the repackaging of the 

spent fuel, the NRC assumes that a DTS would be constructed. 

The construction of a DTS would require a small temporary workforce relative to the power plant 

workforce. Because a DTS has not been constructed at any power plant site and construction 

information is limited, the NRC considered a previously reviewed proposal to construct a spent 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-68 September 2014 

fuel-transfer facility at the Idaho National Laboratory (NRC 2004a) that estimated a construction 

ZRUNIRUFHRIZRUNHUVIRU\HDUV%HFDXVHWKHSURSRVHG,GDKRWUDQVIHUIDFLOLW\LVODUJHU

(3.2 KD>DF@, NRC 2004a) than the assumed DTS (KD>DF@6HFWLRQ, the 

Idaho facility bounds the impacts of constructing a DTS. For comparison, the operational 

workforce at nuclear power plants ranges from 600 to 2,400 permanent personnel (NRC 2013a) 

with an additional 1,000 or more temporary workers needed to support refueling operations 

(NRC 2011c). Based on this information, the NRC concludes that worker commuting traffic 

impacts associated with construction of a DTS during the long-term storage timeframe would be 

a small fraction of the power plant operations traffic impacts (described in Section 4.16.1 as 

small) and therefore the DTS construction traffic would also be small. Operation of the DTS 

would involve fewer workers than the construction workforce and therefore the commuting traffic 

impacts during the DTS operations period would also be minor. The remainder of activities 

during the long-term storage timeframe would be similar to activities and impacts, as evaluated 

LQ6HFWLRQLHZRUNHUVFRPPXWLQJDQGDVPDOOQXPEHURI//:VKLSPHQWVDQG

therefore transportation impacts would continue to be small. 

The operation of the DTS would involve shipment of materials and generate a small amount of 

//:HJXVHGFDQLVWHUVGHFRQWDPLQDWLRQVZDEVDLUILOWHUVDQGXVHGSHUVRQDOSURWHFWLRQ

equipment) (DOE 1996) that would result in infrequent waste shipments to a licensed disposal 

facility. Supply and waste shipments would be infrequent because transfer activities would 

RFFXURYHUDORQJSHULRGRIWLPH7KHVPDOODQGLQIUHTXHQWQXPEHURI//:VKLSPHQWVDQG

compliance with NRC and DOT packaging and transportation regulations would limit potential 

worker and public radiological and nonradiological impacts from waste shipments. 

Continued repackaging activities and the replacement of the ISFSIs and DTSs would generate 

DGGLWLRQDO//:DQGQRnradiological waste that would need to be shipped offsite for disposal. 

6HFWLRQSURYLGHVDQestimate of 480 m3 (630 yd3) of //:IURPWKHUHSDFNDJLQJRI

canisters at a proposed ISFSI and replacement of the ISFSI and DTS. Because repackaging 

and replacement would occur as needed during the long-WHUPVWRUDJHWLPHIUDPHWKH//:

shipments would occur infrequently. Repackaging and replacement would generate about 

22,000 m3 (29,000 yd3RIQRQKD]DUGRXVZDVWH6HFWLRQ2.3). Assuming the nonhazardous 

waste from replacement is shipped in roll-RIIFRQWDLQHUVZLWKDFDSDFLW\RIP3 (20 yd3), the 

total number of truck shipments estimated is . If replacement were phased ovHUD-year 

SHULRGDQGVKLSSLQJRFFXUUHGGD\VSHUZHHNabout one shipment per day would be needed. 

The activities would not significantly increase the magnitude of traffic generated by continued 

storage occurring each year. 

The remainder of activities during the long-term storage timeframe would be similar to the 

activities and impacts evaluated in Section 4.16.1 (i.e., workers commuting and a small number 

RI//:VKLSPHQWV
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-69 185(*௅

Due to the small workforce requirements for continued storage and aging management activities 

(relative to the power plant workforce) and the low frequency of supply shipments and 

VKLSPHQWVRI//:IURP'76DQG,6)6,RSHUDWLRQVDQGUHSODFHPHQWDFWLYLWLHVWKH15&

concludes that impacts on traffic and public and worker radiological and nonradiological safety 

during the long-term storage timeframe would each be SMALL. 

4.16.3 Indefinite Storage 

Assuming no repository becomes available, spent fuel would be stored indefinitely in at-reactor 

ISFSIs. Annual transportation activities and associated environmental impacts would be similar 

to those analyzed for long-term storage operations and DTS construction and operations in 

Section 4.16.2, including continued aging management, repackaging, and replacement 

activities. In addition, because the impact analysis pertains to continued storage, the maximum 

inventory of spent fuel in storage at any reactor site would be the same as that evaluated in 

Section 4.16.1. 

Because the NRC concluded in Section 4.16.2 that transportation impacts for continued storage 

and aging management activities would be SMALL, and no significant changes to the annual 

magnitude of traffic or waste shipments were identified in the preceding analysis of 

transportation activities assuming indefinite at-reactor storage, the NRC concludes that the 

transportation impacts during the indefinite storage timeframe would continue to be SMALL. 

4.17 Public and Occupational Health 

This section describes potential impacts on public and occupational health caused by the 

continued storage of spent fuel in spent fuel pools and at-reactor ISFSIs. 

For the purposes of assessing radiological impacts, impacts are considered to be SMALL if 

releases and doses do not exceed dose standards in the NRC’s regulations. This definition of 

SMALL applies to occupational doses as well as to doses to individual members of the public. 

Transportation-related public and occupational health impacts are addressed in Section 4.16. 

4.17.1 Short-Term Storage 

Continued storage of spent fuel in spent fuel pools and ISFSIs is expected to continue in the 

same manner as during the licensed life for operation of a reactor. The License Renewal GEIS 

(NRC 2013a) describes a number of specific activities related to continued normal plant 

operations that result in impacts on public and occupational health. These include normal plant 

operation for power generation, the storage of spent fuel in fuel pools and ISFSIs, normal 

refueling, and other outages that include steam generator replacements. Overall, data and 

analyses presented in the License Renewal GEIS (NRC 2013a) provide ample evidence that 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4- September 2014 

public and occupational doses at all commercial power plants are far below the dose limits in 

10 CFR Part 20 and that the continuing efforts to maintain doses at as low as is reasonably 

achievable levels have been successful. Therefore, because continued storage represents a 

fraction of the activities occurring during reactor operations, the NRC expects that the public and 

occupational doses would continue to remain below the regulatory dose limits. 

Spent fuel pool leaks can result in environmental impacts. As discussed in Section 4.8.1.1 and 

Appendix E, in the event that a leak from a spent fuel pool goes undetected and the resulting 

groundwater plume reaches the offsite environment, it is possible that the leak could be of 

sufficient magnitude and duration to contaminate a groundwater source above a regulatory limit 

(i.e., a maximum contaminant level for one or more radionuclides) and that public health 

impacts could be noticeable, but not destabilizing in such circumstances. As discussed in 

Appendix E, factors such as spent fuel pool design (stainless-steel liners and leakage-collection 

systems) and operational controls (monitoring and surveillance of spent fuel pool water levels), 

onsite and offsite ground water monitoring, make it unlikely that a leak of sufficient quantity and 

duration could occur without detection. In addition, should a spent fuel pool leak occur, the 

physical processes associated with radionuclide transport and hydrologic characteristics typical 

at spent fuel pool locations make it improbable that water leaked from the spent fuel pool would 

migrate offsite. Therefore, based on the low probability of a leak affecting offsite groundwater 

sources, the NRC concludes that impacts on public health resulting from a spent fuel pool leak 

during short-term timeframe would be SMALL. 

The data presented in NUREG–Occupational Radiation Exposure at Commercial Nuclear 

Power Reactors and Other Facilities 2010 (NRC 2012b), as well as a number of ISFSI license 

UHQHZDO($VHJWKH6XUU\,6)6,>15&F@DQG&DOYHUW&OLIIV,6)6,>15&D@SURYLGH

ample evidence that the public and occupational radiological health impacts from the continued 

storage of spent fuel are a small fraction of the doses and impacts presented in the License 

Renewal GEIS (NRC 2013a) that include reactor operations. For example, NUREG–

(NRC 2012b) provides occupational exposure reporting from facilities that no longer have 

operating reactors, such as the Big Rock Point and Trojan ISFSIs. Both of these facilities had 

no measurable occupational exposure in the 2010 reporting period. The GEH Morris facility is a 

spent-fuel-pool-only ISFSI and has never had an operating reactor onsite. Its 2010 annual 

report indicates an average measured total effective dose equivalent of 0.34 mSv (34 mrem) in 

UHODWLRQWRWKH&)53DUWRFFXSDWLRQDOGRVHOLPLWRIP6Y mrem). 

The analyses presented in the License Renewal GEIS (NRC 2013a) and a number of ISFSI 

OLFHQVHUHQHZDO($VHJWKH6XUU\,6)6,>15&F@DQG&DOYHUW&OLIIV,6)6,>15&D@

provide evidence that annual public and occupational doses would be maintained below the 

DQQXDOGRVHOLPLWVHVWDEOLVKHGE\&)53DUWIRUWKHSublic and 10 CFR Part 20 for 

occupational personnel. In addition, a licensed storage facility would be required to maintain an 

as low as is reasonably achievable program, which would likely result in doses lower than those 

described in the License Renewal GEIS (NRC 2013a). 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

Nonradiological risks to occupational health and safety would include exposure to industrial 

hazards and hazardous materials. Industrial hazards are those typical of other industrial facility 

construction and operating hazards and include exposure to chemicals and accidents ranging 

from minor cuts to industrial machinery accidents. Preventative maintenance activities are 

conducted in accordance with Occupational Safety and Health Administration requirements and 

are infrequent and minor. Therefore, nonradiological occupational health impacts are 

considered to be minimal. 

The NRC concludes that the impacts on public and occupational health due to continued 

storage of spent fuel would be SMALL during the short-term storage timeframe. 

4.17.2 Long-Term Storage 

In addition to the impacts considered above for short-term continued storage in an ISFSI, the 

NRC assumes that a DTS is constructed during the long-term storage timeframe. Risks to 

occupational health and safety during construction of the DTS would include exposure to 

industrial hazards, hazardous materials, and radioactive materials. Industrial hazards are those 

typical of other industrial facility construction and operating hazards and include exposure to 

chemicals and accidents ranging from minor cuts to industrial machinery accidents. Because 

construction activities are conducted in accordance with Occupational Safety and Health 

Administration requirements, nonradiological occupational health impacts are considered to be 

minor. 

Once constructed, operation of the DTS would be very similar to the operations conducted at 

current reactor plant sites with licensed ISFSIs where spent fuel is loaded into dry storage cask 

systems and placed on an ISFSI pad. Analyses of ISFSI operations have been conducted in 

numerous EAs such as those for the Calvert Cliffs (NRC 2012a) and Oconee Nuclear Station 

(NRC 2009b) ISFSI renewals. These analyses and REMP reports provide ample evidence that 

public and occupational doses are being maintained well below the dose limits established by 

&)53DUWIRUWKHSXEOLFDQG&)53DUWIRURFFXSDWLRQDOSHUVRQQHO,QDGGLWLRQDOO

NRC-licensed facilities are also required to operate using an as low as is reasonably achievable 

program to ensure radiation doses are maintained as low as is reasonably achievable. 

Based on the reasons provided above, the NRC concludes that the impacts on public and 

occupational health during long-term storage would be SMALL. 

4.17.3 Indefinite Storage 

The public and occupational health impacts of continuing to store spent fuel without a repository 

would be similar to those described for long-term storage. The activities and associated human 

health impacts would remain the same. The main difference is that these activities would occur 

repeatedly. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4- September 2014 

The no repository scenario was analyzed in detail in the Yucca Mountain final EIS (FEIS) 

(DOE 2002) as the no-action alternative. The Yucca Mountain FEIS analyses looked at the 

short- and long-term impacts of continued storage of spent fuel and high-level radioactive waste 

DWFRPPHUFLDODQG DOE sites for 10,000 years. The Yucca Mountain FEIS, in the analysis 

of the no-action alternative, assumes all commercial spent fuel would eventually be stored in dry 

configurations in ISFSIs at the existing locations. Detailed analyses were provided to 

demonstrate the expectation that maintenance, repairs, repackaging, operation, and 

construction at the storage facilities would be conducted in accordance with the requirements of 

the Occupational Safety and Health Administration and 10 &)53DUWVDQGDVGLVFXVVHG

in the sections above. In addition, administrative controls and design features would minimize 

worker nonradioactive and radioactive exposures. The Yucca Mountain FEIS analyses and the 

GLVFXVVLRQSURYLGHGLQ6HFWLRQVXSSRUWWKHFRQFOXVLRQWKDWSXEOLFDQGRFFXSDWLRQDO

radiological health impacts could be maintained within the public and occupational dose limits of 

&)53DUWVDQG7KHUHIRUHWKH15&FRQFOXGHVWKDWWKHLPSDFWVRQSXEOLFDQG

occupational health due to the indefinite storage of spent fuel in at-reactor ISFSIs would be 

SMALL. 

4.18 Environmental Impacts of Postulated Accidents 

This section describes the environmental impacts of postulated accidents involving the 

continued storage of spent fuel. 

During continued storage, numerous features 

combine to reduce the risk associated with accidents 

involving spent fuel storage in spent fuel pools and 

ISFSIs. Safety features in the design, construction, 

and operation of nuclear power plants and ISFSIs, 

which are the first line of defense, are imposed to 

prevent the release of radioactive materials. 

Additional measures are designed to mitigate the 

consequences of failures in the first line of defense. 

These include the NRC’s reactor site criteria in 10 

&)53DUW35HDFWRU6LWH&ULWHULD ́which require 

the site to have certain characteristics that reduce the 

risk to the public and the potential impacts of an 

accident, and emergency preparedness plans and 

protective action measures for the site and environs. 

All these safety features, measures, and plans make 

up the defense-in-depth philosophy used by the NRC 

to protect the health and safety of the public and the 

environment (NRC 2013d). 

Design Basis Events, Design Basis 

Accidents, and Severe Accidents 

Design basis events are conditions of 

normal operation, design basis accidents, 

external events, and natural phenomena, 

for which the plant must be designed to 

ensure the capability to prevent or 

mitigate the consequences of accidents 

that could results in potential offsite 

H[SRVXUHV15&E

Design basis accidents are postulated 

accidents that are used to set design 

criteria and limits for the design and sizing 

of safety-related systems and components 

15&E

Severe accidents, or beyond-designbasis accidents, are accidents that may 

challenge safety systems at a level much 

higher than expected. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

Consistent with the defense-in-depth philosophy, this section describes design basis events for 

which the strategy is to prevent or mitigate the consequences of accidents that could result in 

potential offsite doses. For some design basis events, such as tornadoes, this section 

describes how the storage facility is designed and built to withstand the event without loss of 

systems, structures, and components necessary to ensure public health and safety. In these 

cases, the environmental impacts are small because no release of radioactive material would 

occur. Other design basis events, such as spent fuel-handling accidents, are design basis 

accidents that licensees must assume could occur. In these cases, licensees must show how 

engineered safety features in the facility mitigate a postulated release of radioactive material. 

The environmental impacts of design basis accidents are small because all licensees must 

maintain engineered safety features that ensure that the NRC dose limits for these accidents 

are met. The basis for impact determinations for design basis events (i.e., whether the accident 

is prevented or mitigated) is described for each type of design basis event presented in this 

section. 

Regulations governing accidents that must be addressed by nuclear power facilities, both 

RSHUDWLQJDQGVKXWGRZQDUHIRXQGLQ&)53DUWVDQG7KHHQYLURQPHQWDO

impacts of design basis events, including those associated with the spent fuel pool, are 

evaluated during the initial licensing process. The ability of the plant to withstand these 

accidents is demonstrated to be acceptable before issuance of the operating license. The 

results of these evaluations are found in license documentation, such as the NRC’s safety 

evaluation report, the final environmental impact statement, and in the licensee’s Final Safety 

Analysis Report (FSAR) or equivalent. The licensee is required to maintain the acceptable 

design and performance criteria throughout the life of the plant, including during continued 

storage (NRC 2002b). 

The consequences of a severe (or beyond-design-basis) accident, if one occurs, could be 

significant and destabilizing. The impact determinations for these accidents, however, are 

made with consideration of the low probability of these events. The environmental impact 

determination with respect to severe accidents, therefore, is based on the risk, which the NRC 

defines as the product of the probability and the consequences of an accident. This means that 

a high-consequence low-probability event, like a severe accident, could therefore result in a 

small impact determination, if the risk is sufficiently low. 

This section of the GEIS follows a different format than the rest of the document. Because the 

accident risks for spent fuel pool storage only apply during the short-term timeframe and the 

accident risks for dry cask storage are substantially the same across the three timeframes, the 

GEIS presents the various accident types only once. The three storage timeframes (short-term, 

long-term, and indefinite, as described in Chapter 1) apply as follows: 

x During short-term storage, both design basis and severe accidents are postulated for spent 

fuel stored in the onsite spent fuel pool and at-reactor ISFSI. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4- September 2014 

x For long-term and indefinite storage, the NRC assumes that the spent fuel is moved from 

the spent fuel pool to an at-reactor ISFSI. Therefore, only accidents involving an at-reactor 

ISFSI are possible during the long-term and indefinite storage timeframes. 

4.18.1 Design Basis Events 

During the continued storage of spent fuel, licensees maintain systems, structures, and 

components that ensure public health and safety. The hazards that are considered in the 

design and operation of storage facilities include failure of facility systems, structures, and 

components; man-made hazards, such as nearby military, industrial, and transportation 

facilities; and natural phenomena, such as earthquakes and floods. 

4.18.1.1 Design Basis Events in Spent Fuel Pools 

A number of postulated design basis events are considered in the design of spent fuel pools. 

Design features of spent fuel pools ensure prevention of inadvertent criticality and also ensure 

that the pool is designed to withstand hazards that could result in a significant loss of water. 

This section provides brief summaries of accidents involving spent fuel storage operations 

during the short-term storage timeframe. 

Criticality Accidents 

The presence of fissile nuclides in spent fuel requires that controls must be in place to prevent 

inadvertent nuclear chain reaction, or criticality, while spent fuel is in storage. NRC regulations 

in &)53&ULWLFDOLW\$FFLGHQW5HTXLUHPHQWV ́DQG*HQHUDO'HVLJQ&ULWHULRQ

33UHYHQWLRQRI&ULWLFDOLW\LQ)XHO6WRUDJHDQG+DQGOLQJ ́RI$SSHQGL[$3*HQHUDO'HVLJQ&ULWHULD

for Nuclear Power Plants,” to 10 C)53DUWUHTXLUHWKDWVXEFULWLFDOLW\LQVSHQWIXHOSRROVEH

maintained. To comply with these requirements, licensees design and implement controls 

based on spent fuel pool nuclear criticality safety analyses. These controls include the use of 

neutron-absorbing material in spent fuel pool storage racks. The neutron-absorbing material’s 

physical properties, including its dimensions and boron-10 areal density, help maintain 

subcriticality. These nuclear criticality safety analyses are usually documented in the licensee’s 

FSAR and are the basis for demonstrating compliance with plant technical specifications, NRC 

regulations, and demonstrating adequate subcriticality for both normal operating conditions and 

design basis accidents. 

Many licensees use integrated defense-in-depth design features to reduce the chance of a 

criticality accident if the neutron-DEVRUELQJPDWHULDOGHJUDGHV)RUH[DPSOHVRPH3:5VKDYH

received approval to take credit for the soluble boron in the spent fuel pool. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

Licensees are required to demonstrate that some margin to criticality is maintained for a variety 

of abnormal conditions, including fuel-handling accidents involving a dropped fuel assembly. 

The environmental impacts are small, therefore, because criticality accidents in spent fuel pools 

are prevented. 

Nearby Military, Industrial, and Transportation Facilities 

Nuclear power plant licensees are required to assess hazards from nearby military, industrial, 

and transportation facilities to ensure that potential hazards in the site vicinity have been 

considered in the plant’s design bases. If hazards are identified, such as overpressure from 

explosions from nearby industrial facilities, licensees are required to show that the probability is 

sufficiently low (an order of magnitude of 10௅/yr or less) or that radiological dose criteria in 

10 &)5DDUHPHW6LQFHHLWKHUWKHSUREDELOLW\RUWKHFRQVHTXHQFHVPXVWEH

acceptably small, the environmental risk of spent fuel pool releases caused by hazards from 

nearby military, industrial, and transportation facilities is small. 

Postulated Fuel Assembly or Cask Drop 

,QDFFRUGDQFHZLWK15&UHJXODWLRQVLQ&)5DQGDOLFHQVHHPXVWVKRZWKDWD

plant site and mitigating engineered safety features are acceptable with respect to the 

consequences of postulated spent fuel cask drop accidents. Improper operation of the handling 

equipment (e.g., cranes), poor rigging practices, and equipment failures can lead to a drop of a 

cask or a fuel assembly into a spent fuel pool. Generally, the handling equipment is designed 

and constructed in accordance with the ASME NOG–1 Standard (ASME 2010) to be certified as 

single-failure-proof (any single failure will not drop the load). 

A heavy load (e.g., cask) drop into the pool or onto the pool wall could affect the structural 

integrity of the fuel pool. An unlikely drop of a fuel assembly may cause mechanical damage to 

the fuel. Because a relatively small amount of mechanical damage to the fuel could cause 

significant radiation doses to facility personnel and releases to the environment, the spent fuel 

pool facility has radiation monitors and also provides confinement of radioactive material 

released from damaged fuel. The spent fuel pool facility is a controlled leakage building with a 

safety-grade filtration system in its ventilation system. This filtration system provides the 

necessary confinement to limit offsite dose consequences (NRC 2001). 

The licensee provides the necessary plant description and analyses in its FSAR to demonstrate 

the safety of the spent fuel pool during the initial license application of the reactor to the NRC. 

The licensee also revises the plant description and accident analyses in the FSAR, as needed. 

As part of its continuing regulatory oversight of the plant, the NRC reviews the plant description 

and accident analyses during the initial licensing proceedings, as well as any subsequent 

revision to the FSAR. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4- September 2014 

In general, the NRC’s accident dose review criterion for fuel-handling accidents at most plants, 

including cask drops, is P6YUHP) total effective dose equivalent to an offsite 

individual (NRC 2000). This dose criterion must be met regardless of the probability of the 

design basis event. 

Since the postulated fuel assembly or cask drop is among the design basis accidents analyzed 

E\OLFHQVHHVDQGOLFHQVHHVPXVWVKRZWKDWUDGLDWLRQGRVHOLPLWVLQ&)5DZLOOEH

met, the environmental consequences associated with this type of design basis accident during 

continued storage are small. 

Natural Phenomena Hazards 

$SSHQGL[$3*HQHUDO'HVLJQ&ULWHULDIRU1XFOHDU3RZHU3ODQWV ́WR&)53DUWUHTXLUHV

that structures, systems, and components that are important to safety be designed to withstand 

the effects of natural phenomena, such as earthquakes, tornadoes, hurricanes, floods, tsunamis 

and seiches, without loss of capability to perform their safety functions. General Design 

&ULWHULRQRI$SSHQGL[$3*HQHUDO'HVLJQ&ULWHULDIRU1XFOHDU3RZHU3ODQWV ́WR

10 CFR Part DOVRUHTXLUHVWKDt the design bases for these structures, systems, and 

components reflect (1) appropriate consideration of the most severe of the natural phenomena 

that have been historically reported for the site and surrounding area, with sufficient margin for 

the limited accuracy, quantity, and period of time in which the historical data have been 

accumulated; (2) appropriate combinations of the effects of normal and accident conditions with 

the effects of the natural phenomena; and (3) the importance of the safety functions to be 

performed. 

*HQHUDO'HVLJQ&ULWHULRQ3(QYLURQPHQWDODQG'\QDPLF(IIHFWV'HVLJQ%DVHVDOVRDSSOLHVWR

spent fuel pool design as it relates to information on tornadoes that could generate missiles. 

15&VLWLQJUHJXODWLRQVLQ&)53DUW35eactor Site Criteria,” also require applicants to 

consider, among other things, physical characteristics of sites that are necessary for safety 

analysis or that may have an impact upon plant design (such as maximum probable wind speed 

and precipitation). Licensees and applicants are required to identify and characterize the 

physical characteristics of the site, so that they may be taken into consideration when 

determining the acceptability of the site. Appendix $RI&)53DUW36HLVPLFDQG

Geologic Siting Criteria for Nuclear Power Plants,” describes the nature of investigations 

required to obtain geologic and seismic data necessary to determine site suitability and to 

provide reasonable assurance that a nuclear power plant can be constructed and operated at a 

proposed site without undue risk to the health and safety of the public. Appendix A describes 

the procedures for determining the quantitative vibratory ground motion design basis at a site 

due to earthquakes and describes information needed to determine whether and to what extent 

a nuclear power plant needs to be designed to withstand the effects of surface faulting. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

Each applicant for a construction permit for a power plant is required to investigate the site for 

all seismic and geological factors that may affect the design and operation of the plant to 

provide reasonable assurance that the plant can be constructed and operated without undue 

risk to health and safety of the public. These siting criteria also provide reasonable assurance 

that the spent fuel pool can be operated safely during the short-term storage timeframe. 

Earthquakes 

The NRC requires licensees to design, operate, and maintain safety-significant structures, 

systems, and components, including spent fuel pools, to withstand the effects of earthquakes 

and to maintain the capability to perform their intended safety functions. The agency ensures 

these requirements are satisfied through the licensing, reactor oversight, and enforcement 

processes (NRC 2011e,QWKH15&EHJDQWRDVVHVVWKHVDIHW\LPSOLFDWLRQVRI

increased nuclear power plant earthquake hazards identified for the central and eastern 

United States. The NRC identified the issue as Generic Issue 199 (GI–199) and completed a 

OLPLWHGVFRSHVFUHHQLQJDQDO\VLVLQ'HFHPEHUZKLFKFXOPLQDWHGLQWKHLVVXDQFHRID

safety/risk assessment in August 2010 (NRC 2010). In the 2010 assessment, the NRC chose 

seismic core damage frequency as the appropriate risk metric to changes in the seismic hazard. 

For each power plant, the NRC estimated the change in seismic core damage frequency as a 

result of the updated seismic hazard. This analysis confirmed that operating nuclear power 

plants remain safe with no need for immediate action. The NRC took regulatory action after the 

March 2011 earthquake and tsunami in Japan. In March 2012, the NRC issued a request for 

information to all U.S. nuclear power plants asking licensees to (1) conduct walkdowns of their 

plants, including the spent fuel pools, to identify and address plant-specific vulnerabilities 

(through their corrective action programs) and verify the adequacies of monitoring and 

maintenance procedures; and (2) reevaluate the seismic hazards at the plants against presentday NRC requirements and guidance. These assessments may make use of new consensus 

seismic hazard estimates for the power plants in the central and eastern United States 

developed by the DOE, EPRI, and NRC (NRC 2012c). The NRC has issued guidance to 

complete these walkdowns and reevaluations and will take additional regulatory action, as 

necessary, in response to the findings. 

Floods 

As with earthquakes and other natural phenomena, the NRC requires licensees to design, 

operate, and maintain safety-significant structures, systems, and components, including the 

spent fuel pool, to withstand the effects of floods and to maintain the capability to perform their 

intended safety functions. The analysis to meet this requirement involves estimating a design 

basis flood, which is defined as a flood caused by one or an appropriate combination of several 

hydrometeorological, geoseimic, or structural-failure phenomena, which results in the most 

severe hazards to safety-significant structures, systems, and components (NRC ; Prasad 

et al. 2011). Based in part on the plant physical siting location and characteristics, the design 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4- September 2014 

basis flood can include flooding on the site caused by local intense precipitation or local 

probable maximum precipitation, stream flooding, storm surges, seiches, tsunamis, seismically 

induced dam failures or breaches, flooding caused by landslides, the effects of ice formation in 

waterbodies, or some combination of these phenomena (NRC 2013a). 

All safety-significant structures, systems, and components are required to be protected against 

the design basis flood by siting them above the highest flood water-surface elevation or 

providing adequate flooding protection. The NRC requires that this protection be achieved by 

XVLQJDGU\VLWHFRQFHSWH[WHUQDOEDUULHUVRULQFRUSRUDWHGEDUULHUV15&7KHGU\VLWH

concept involves constructing the nuclear power plant above the design basis flood watersurface elevation using either the natural terrain or engineered fill. External barriers are 

engineered solutions that can include levees, seawalls or floodwalls, bulkheads, revetments, or 

breakwaters. Incorporated barriers are also engineered solutions that involve specially 

designed walls or penetration closures. 

Given these physical siting and engineered factors, the environmental risk of spent fuel pool 

releases caused by design basis floods is small. 

The NRC also took regulatory action after the March 2011 earthquake and tsunami at the 

Fukushima Dai-ichi nuclear power plant. In March 2012, the NRC issued a request for 

information to all U.S. nuclear power plants asking licensees to (1) conduct plant walkdowns 

(visual inspections) to identify and address plant-specific vulnerabilities (through their corrective 

action programs) and verify the adequacies of monitoring and maintenance procedures; and 

(2) reevaluate the flooding hazards at the plants against present-day NRC requirements and 

guidance to ensure that the plant is designed, operated, and maintained in such a manner that 

safety-significant structures, systems, and components, including the spent fuel pool, are able to 

withstand the effects of floods (NRC 2012d). The NRC has issued guidance to complete these 

walkdowns and reevaluations and will take additional regulatory action, as necessary, in 

response to the findings. The information collected in response to the request for information 

will also be applicable to resolution of GI–204, Flooding of Nuclear Power Plant Sites Following 

Upstream Dam Failures (NRC 2013e). 

+LJK:LQGV7RUQDGRHVDQG+XUULFDQHV

The NRC requires licensees to consider both sustained straight winds, such as those caused 

by hurricanes, and brief high rotational and translational winds that are caused by tornadoes 

in the design of safety-related structures. Because tornado wind speeds are generally higher 

than hurricane wind speeds, tornado winds tend to be the limiting consideration in design. 

The NRC¶VGHILQLWLRQRIDGHVLJQEDVLVWRUQDGRRULJLQDOO\SXEOLVKHGLQLQ5HJXODWRU\

Guide GHVFULEHVGHVLJQEDVLVWRUQDGRFKDUDFWHULVWLFVLQHDFKRIWKUHHUHJLRQVRIWKH

8QLWHG6WDWHV15&7KHGHVLJQEDVLVWRUQDGRFKDUDFWHULVWLFVHDVWRIWKHHastern 

IRRWKLOOVRIWKH5RFN\0RXQWDLQVLQFOXGHGDPD[LPXPZLQGVSHHGRINPKUPSK
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

The Pacific coastal region and Rocky Mountain region had design basis tornado characteristics 

that include a maximum wind speed of 480 km/hr (300 mph) and 390 km/hr (240 mph), 

respectively. Operating nuclear power plants in these regions that meet this guidance are 

designed to withstand these wind speeds. By comparison, few hurricanes have achieved wind 

speeds of 310 km/hr (190 mph) (Bender et al. 2010). 

,Q, the NRC updated its design basis tornado definition such that a maximum wind speed 

RINPKUPSKLVDSSURSULDWHIRUWRUQDGRHVIRUWKHFHQWUDOSRUWLRQRIWKH8QLWHG6WDWHV

a maximum wind speed of 320 km/hr (200 mph) is appropriate for a large region of the United 

States along the east coast, the northern border, and western Great Plains; and a maximum 

ZLQGVSHHGRINPKUPSKLVDSSURSULDWHIRUWKHZHVWHUQ8QLWHG6WDWHV15&F

Because design basis tornado windspeeds were decreased as a result of the analysis 

SHUIRUPHGWRXSGDWH5HJXODWRU\*XLGHLWZDVQRORQJHUFOHDUWKDWWKHUHYLVHGWRUQDGR

design basis windspeeds would bound design basis hurricane windspeeds in all areas of the 

United States. As a result, in 2011 the NRC published new guidance for design basis hurricane 

and hurricane missiles for nuclear power plants (NRC 2011f). This guidance describes 

windspeeds and other hurricane characteristics acceptable to the staff for defining a design 

basis hurricane for new nuclear power plants. For example, under this new guidance, which 

would apply to new reactors, design basis 3-second gust windspeeds along the eastern Florida 

FRDVWUDQJHIURPNPKUPSKWRNPKUPSK

Given the required design bases for nuclear power plants, including spent fuel pool structures, 

only severe winds would FDXVHGDPDJHWRD3:5RUD%:5VSHQWIXHOSRRO*HQHUDOO\WKH

safety-related structures of a spent fuel pool facility (e.g., the pool wall) are designed to 

withstand the design basis wind and missiles; however, the facility superstructure and other 

systems may not be classified as safety-related and may sustain some damage from wind and 

wind-generated missiles. In 2001, the NRC estimated the annual frequency of catastrophic pool 

failure from an impact of a tornado-generated missile given a strike of a tornado having at least 

F4 intensity to be less than 10í (NRC 2001). The extremely low probability of tornado-induced 

accidents ensures that the environmental risk of spent fuel pool releases caused by design 

basis high winds is small. 

Climate Change 

$VGHVFULEHGDERYH15&UHJXODWLRQVLQ&)53DUWVDQGUHTXLUHWKDWVSHQWIXHO

pools be designed to withstand the effects of natural phenomena. Climate change can 

influence the frequency and intensity of some natural phenomena. This section of the GEIS 

addresses the environmental impacts from climate change on the continued storage of spent 

fuel in spent fuel pools. The NRC acknowledges that climate change may have impacts across 

a wide variety of resource areas including air, water, ecological, and human health. The U.S. 

Global Change Research Program (GCRP) describes these potential impacts in the report 

Climate Change Impacts in the United States (GCRP 2014). However, in this GEIS, the 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-80 September 2014 

discussion of impacts from climate change on the environment will focus on those affecting the 

continued storage of spent fuel. The contribution of continued storage to greenhouse gas 

HPLVVLRQVDQGFOLPDWHFKDQJHDUHDGGUHVVHGLQ6HFWLRQVDQG

Because spent fuel will only be stored in spent fuel pools during the short-term timeframe, the 

consideration of climate change impacts for pool storage only needs to address the short-term 

timeframe. Climate change can lead to an increased intensity and frequency of severe weather 

events (e.g., flooding, high winds from hurricanes and tornadoes, droughts, and increased 

temperatures in nearby surface waterbodies used as cooling-water supplies). As described 

previously in this section, the NRC requires licensees to design, operate, and maintain safetysignificant structures, systems, and components to withstand the effects of floods and other 

natural phenomena and to maintain the capability to perform their intended safety functions. 

The agency ensures these requirements are satisfied through the licensing, oversight, and 

enforcement processes. The NRC’s oversight authority over the licensed facilities will ensure 

that minimal impacts of natural hazards would be associated with climate change during shortterm continued storage in spent fuel pools. As stated above, potential effects associated with 

climate change on the safety of spent fuel storage are flooding from storm surges and high 

winds caused by extreme weather events like hurricanes. Rise in sea level is controlled by 

complex processes, and it is projected to rise between 0.3 and 1.2 m (1 and 4 ft) by 2100 

(GCRP 2014).3 Based on this projected change, no U.S. nuclear power plant (operational or 

decommissioned) will be underwater solely because of sea level rise before 2100. In addition to 

sea-level rise, spent fuel facilities may be affected by increased storm surges, erosion, shoreline 

retreat, and inland flooding. Coastal area impacts may be exacerbated by land subsidence. 

Section 4.18.2 considers when climate change influences on natural phenomena (e.g., sea-level 

rise along with storm surge) contribute to flooding levels beyond the design basis. NRClicensed spent fuel storage facilities are designed to be robust. They are evaluated to ensure 

that the performance of their safety systems, structures, and components is maintained during 

flooding events, and they are monitored when in use. The lowest grade above the sea level of 

concern for an NRC-OLFHQVHGIDFLOLW\LVFXUUHQWO\DERXWPIW)5,QWKHHYHQW

of climate change-induced sea-level rise, which would occur gradually over long periods of time, 

WKH15&VHHHJ&)53DUW$SSHQGL[%6HFWLRQ;9,3&RUUHFWLYH$FWLRQ ́UHTXLUHV

licensees to implement corrective actions to identify and correct or mitigate conditions adverse 

to safety. Further, as stated above, following the March 2011 accident at the Fukushima Daiichi nuclear power plant in Japan, licensees of operating nuclear power plants are reevaluating 

flood hazards using present-day regulations and regulatRU\JXLGDQFH:KHQFRPSOHWHGWKHVH

reevaluations will provide additional assurance that existing plant design bases reflect the 

current state of knowledge of flood hazards. In addition, the NRC will use the information 

 

3 The 2014 National Climate Assessment (GCRP 2014) also notes that in the context of risk-based 

analysis, some decision makers may wish to use a wider range of scenarios, from 0.2 m (8 in) to 2 m 

(6.6 ft) by 2100. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-81 185(*௅

collected to determine whether further regulatory action is needed concerning flood hazard 

analysis and design basis. 

Climate change can also lead to an increase in the frequency of droughts. Increasing 

temperatures have made droughts more severe and widespread. Trends in droughts vary 

regionally. Short-term (seasonal or shorter) droughts are expected to intensify in most U.S. 

regions, while longer-term droughts are expected to intensify in the Southwest, southern Great 

Plains, and Southeast (GCRP 2014). Except in a few areas where increases in summer 

precipitation are expected to compensate for drought effects, summer droughts are expected to 

intensify across the continental United States (GCRP 2014). Droughts can cause increased 

competition for limited water resources. Although some aspects of spent fuel storage require 

water, the amount of water needed is minimal and water use for spent fuel storage is not 

expected to cause water-use conflicts, even under the changed conditions that could be caused 

E\FOLPDWHFKDQJHVHH6HFWLRQVDQG

Summary 

The postulated design basis accidents considered in this GEIS for spent fuel pools include 

hazards from natural phenomena, such as earthquakes, flood, tornadoes, and hurricanes; 

hazards from activities in the nearby facilities; and fuel-handling-related accidents. In addition, 

the potential effects of climate change are also considered. Based on the above analysis, the 

environmental risk of these postulated accidents involving continued storage of spent fuel in 

pools is SMALL, because all important to safety structures, systems, and components involved 

with the fuel storage are designed to withstand these design basis accidents without 

compromising the safety functions. If climate change influences on natural phenomena create 

conditions adverse to safety, the NRC has sufficient time to require corrective actions to ensure 

spent fuel storage continues with minimal impacts. 

4.18.1.2 Design Basis Events in Dry Cask Storage Systems 

Design basis events are considered in the design of dry cask storage systems in accordance 

with NRC regulations LQ&)53DUW3/LFHQVLQJ5HTXLUHPHQWVIRUWKH,QGHSHQGHQW6WRUDJH

of Spent Nuclear Fuel, High-/HYHO5DGLRDFWLYH:DVWHDQG5HDFWRU-Related Greater Than 

Class &:DVWH ́7KHVHUHTXLUHPHQWVDUHDSSOLFDEOHto dry cask storage systems for continued 

storage of spent fuel at all times, including the period of reactor operations, and all three 

continued storage timeframes (i.e., short-term, long-term, and indefinite storage). 

In the safety analysis reports for specifically licensed dry cask storage facilities, each facility 

licensee examines four categories of design events as defined in American National Standards 

Institute (ANSI) standard ANSI/ANS–ZKLFKLQFOXGHQRUPDORII-normal, and 

accidental events. Design Events I represent those associated with normal operations of an 

ISFSI. These events are expected to occur regularly or frequently. Examples of normal events 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-82 September 2014 

include receipt, inspection, unloading, maintenance, and loading of a transportation package; 

transfer of loaded storage casks to the storage pads; and handling of radioactive waste 

generated as part of the operation. The impacts from these events are similar to those of 

normal operations at the ISFSI. 

Design Events II represent those associated with off-normal operations that can be expected to 

occur with moderate frequency, approximately once per year. These events could result in 

members of the general public being exposed to additional levels of radiation beyond those 

associated with normal operations. Examples of these events include loss of external electrical 

power for a limited duration, off-normal ambient temperatures, a cask drop from less than the 

design allowable lift height, and off-normal transporter operation. Credible off-normal events or 

Design Events II rarely result in any occupational or offsite radiological consequences. During 

normal operations and off-normal conditions, the requirements of 10 CFR Part 20 must be met. 

In addition, the annual dose equivalent to any individual located beyond the controlled area 

PXVWQRWH[FHHGP6YPUHPWRWKHZKROHERG\P6YPUHPWRWKHWK\URLG

DQGP6YPUHPWRDQ\RWKHURUJDQ

Design Events III represent infrequent events that could be reasonably expected to occur over 

the lifetime of the dry cask storage facility, while Design Events IV represent extremely unlikely 

events or design basis accidents that are postulated to occur because they establish the 

conservative design basis for systems, structures, and components important to safety. Design 

Events III and IV include more severe events, such as earthquakes, tornadoes and missiles 

generated by natural phenomena, floods, fire (including wildfires) and explosions, lightning, 

accidents at nearby sites (facilities), aircraft crashes, canister leakage under hypothetical 

accident conditions, storage cask drop or tip-over, and loss of shielding. The dose from any 

credible design basis accident to any individual located at or beyond the nearest boundary of 

the controlled area may not excHHGWKDWVSHFLILHGLQ&)5VSHFLILFDOO\WKHPRUH

OLPLWLQJWRWDOHIIHFWLYHGRVHHTXLYDOHQWRI6YUHPRUWKHVXPRIGHHSGRVHHTXLYDOHQWWR

and the committed dose equivalent to any individual organ or tissue (other than eye lens) of 

6YUHPDOHQVGRVHHTXLYDOHQWRI6YUHPDQGDVKDOORZGRVHHTXLYDOHQWWR

VNLQRUDQ\H[WUHPLW\RI6YUHP

The NRC assumes a DTS, or a facility with equivalent capabilities, will be needed to enable 

retrieval of spent fuel for inspection or repackaging as the duration and quantity of fuel in dry 

storage increases. A DTS would provide repackaging capability at all dry storage sites without 

the need to return to a pool and contingency by enabling repackaging at ISFSI-only sites. A 

DTS would allow onsite transfer of bare fuel assemblies from a source cask to a receiving cask 

(Christensen et al. 2000). The source cask can be a storage cask or a transfer cask. 

Confinement and shielding during fuel-transfer operations are provided by the concrete and 

steel structure. The facility has several subsystems including one used to transfer the fuel 

assemblies. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-83 185(*௅

Two accidents considered in the Topical Safety Analysis Report for the reference DTS 

(DOE 1996) are representative of the types of accidents that could result in environmental 

impacts. These accidents involve a stuck fuel assembly and a loss-of-confinement event. 

A fuel assembly in a reference DTS can become stuck while being retrieved from a cask or 

while being inserted into a cask for repackaging. Both of these scenarios can increase the dose 

at the site boundary because of increased time of operation, and they represent the bounding 

accidents. The design of the fuel-handling machine would have several safety features to make 

these scenarios unlikely. 

Licensees of a reference DTS would be required to incorporate special recovery procedures in 

the facilities operational plan to free the stuck assembly, including use of special equipment 

through the penetrations in the wall with full viewing capabilities provided by closed-circuit 

television cameras. A fuel assembly may be stuck part-way out because a foreign object is 

between the assembly and the fuel cell or because of protrusions inside the cask. The situation 

could be detected because loads recorded by the fuel-assembly load cell would be abnormal 

and appropriate actions could be taken. There would not be any time limit to complete the 

UHFRYHU\RSHUDWLRQVEHFDXVHWKHDVVHPEO\ZRXOGEHVKLHOGHG$VSHFLDO3UHFRYHU\ ́FDVNPD\

be needed if the assembly is significantly distorted. The dose from these bounding scenarios 

ZDVHVWLPDWHGWREHP6YPUHPDWDGLVWDQFHRIPIWIURPWKH'76

assuming it would take 2 weeks to free the stuck fuel assembly. 

In a loss-of-confinement event, TN-EPRI considered a scenario in which high-efficiency 

particulate air filters are inoperable while the receiving cask is open and filled with 21 fuel 

assemblies. The accident impact analysis is based on assuming that volatile radionuclides are 

released from damaged fuel, including up to 10 percent of the noble gases (except that up to 

30 percent of the krypton-LVUHOHDVHGWULWLXPDQGLRGLQH-129. The total dose at 100 m 

(330 IWLVFDOFXODWHGWREH1 P6YPUHP

Because the accident consequences would not exceed the NRC accident dose standard 

FRQWDLQHGLQ&)5WKHHQYLURQPHQWDOLPSDFWRIWKHSRWHQWLDODFFLGHQWVZRXOGEH

SMALL. 

Climate Change 

The natural hazards that could be affected by climate change which are important to dry cask 

storage siting and design include flood and high-wind hazards. As described in Section 2.2, dry 

cask storage occurs during the short-term, long-term, and indefinite storage timeframes. 

Therefore, the analysis for dry cask storage would extend beyond the 60-year short-term 

timeframe considered in the spent fuel pool analysis. Projected future conditions include 

uncertainty. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-84 September 2014 

The amount and rate of future climate change depends on current and future human-caused 

emissions (GCRP 2014). Quantitative expressions, such as the amount of sea-level rise 

identified in Section 4.18.1.1, may only extend to the end of the century. To whatever extent 

climate change alters the magnitude and frequency of natural phenomena during and beyond 

the short-term storage timeframe, the NRC’s oversight authority over the licensed facilities is the 

mechanism that addresses the impact of natural hazards. Under current NRC regulations 

applicable to dry cask storage facilities, the NRC requires that the vendor or licensee include 

design parameters on the ability of the storage casks and spent fuel storage facilities to 

withstand severe weather conditions such as hurricanes, tornadoes, and floods. NRC-licensed 

spent fuel storage facilities are designed to be robust. They are evaluated to ensure that 

performance of their safety systems, structures, and components is maintained in response to 

natural phenomena hazards. In the event of impacts induced by climate change, such as sealevel rise, which occurs gradually over long periods of time, the NRC regulations (e.g., 

10 CFR 3&RUUHFWLYHDFWLRQ ́UHTXLUHOLFHQVHHVWRLPSOHPHQWFRUUHctive actions to identify 

and correct conditions adverse to safety. 

Summary 

In summary, the dry storage cask systems and any DTSs are designed to withstand the design 

basis accidents without losing safety functions. In addition, DTSs will have special recovery 

procedures in their operation plans to recover from these design basis accidents if they occur. If 

climate change influences on natural phenomena create conditions adverse to safety, the NRC 

has sufficient time to require corrective actions to ensure spent fuel storage continues with 

minimal impacts.

4.18.1.3 Conclusion 

All NRC-licensed dry cask storage systems are designed to withstand all postulated design 

basis accidents (Design Events III and IV) with no loss of the safety functions. Licensees of 

DTSs will be required to design the facilities so that all safety-related structures, systems, and 

components can withstand the design basis accidents without compromising safety functions. 

In addition, the potential effects of climate changes are considered. Based on the assessment, 

the environmental impact of the design basis accidents is SMALL because safety-related 

structures, systems, and components are designed to function during and after these accidents. 

4.18.2 Severe Accidents 

This section describes severe accidents, or beyond-design-basis accidents, which are accidents 

that may challenge safety systems at a level higher than that for which they were designed, and 

assesses the environmental impact of severe accidents during continued storage. The 

probability and consequences of severe accidents are usually considered by the NRC in 

probabilistic risk assessments in which risk is determined by multiplying the probability of an 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

event times its consequences. The results of past studies for spent fuel pools and dry cask 

storage systems are summarized in the following sections. 

4.18.2.1 Severe Accidents in Spent Fuel Pools

7KH15&H[DPLQHGWKHULVNRIVHYHUHDFFLGHQWVLQVSHQWIXHOVWRUDJHSRROVLQ:$6+–1400 

15&:$6+–1400 states that spent fuel pool accidents can arise from either loss of 

pool cooling, drainage of the pool, or drop of heavy objects into the pool. Subsequently, the 

NRC developed NUREG–15&ZKLFKH[DPLQHGVHYHUDOVHYHUHDFFLGHQWVWKDWFDQ

affect a spent fuel storage pool, namely loss of cooling or makeup water, inadvertent draining of 

the pool, and structural failure of the pool due to missiles, aircraft crashes, heavy load (shipping 

cask) drop, and beyond-design-basis earthquakes. NUREG–15&Hxamined spent 

fuel pool accidents at decommissioning nuclear power plants. In addition to scenarios leading 

to fuel uncovery in a pool (fuel being uncovered, e.g., because of loss of cooling, loss of offsite 

power, heavy load drops, and fire), NUREG–also examined the risk from seismic events, 

aircraft crashes, and tornadoes to a spent fuel pool. Assessments made in these studies are 

briefly discussed in the following sections. 

Internal Events 

In previous studies, the NRC considered a number of different types of equipment failure, or 

internal events that could lead to a severe accident in a spent fuel pool. For example, all spent 

fuel pools have a spent fuel pool cooling and cleanup system. This safety function of this 

system is intended to ensure that spent fuel remains cool and covered with water during all 

storage conditions. In addition to General Design Criterion 2, which is summarized above, 

pools are required to meet General Design Criterion 61 or equivalent principal design criteria;4

General Design Criterion 61 states, among other things, that systems for fuel storage and 

handling shall be designed with residual heat removal capability to provide reliability and 

testability that reflects the importance to safety of decay heat, other residual heat removal, and 

prevention of significant reduction in fuel storage coolant inventory under accident conditions. 

In general, this means that spent fuel pool cooling and cleanup systems are designed to satisfy 

either of two bases: (1) the cooling portion of the system is designed to seismic Category I 

(Regulatory Guide 15&G4XDOLW\*URXS&5HJXODWRU\*XLGHJXLGHOLQHV

15&HRUWKHIROORZLQJV\VWHPVDUHGHVLJQHGWRVHLVPLF&DWHJRU\,4XDOLW\*URXS&

guidelines and are protected against tornadoes: the fuel pool makeup water system and its 

source; and the fuel pool building and its ventilation and filtration system. Licensees prevent a 

significant reduction in spent fuel pool coolant inventory by providing adequate makeup water 

 

4 86IDFLOLWLHVIRUZKLFKFRQVWUXFWLRQSHUPLWVZHUHLVVXHGEHIRUHKDYHSODQW-specific principal 

design criteria, because the Atomic Energy Commission (NRC predecessor) had yet to develop generic 

requirements for facility design criteria at that time. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-86 September 2014 

capability and designing the spent fuel pool cooling and cleanup system so that the coolant can 

neither be drained nor siphoned below a specified level. 

In NUREG– (NRC 2001), the NRC concluded that the frequency of spent fuel uncovery 

resulting from loss of offsite power ranges from 1.1 × 10–/yr for power losses caused by severe 

weather to 2.9 × 10–8/yr for plant-related and grid-related events. Lack of external power would 

cause cooling systems to fail, resulting in elevated pool water temperatures and accelerated 

evaporation of the pool water. In the event of even a long-term loss of normal pool makeup 

water capability at U.S. power plants, measures that were installed in response to the 

September 11, 2001 terrorist attacks, plus additional measures that are required as a result of 

the post-Fukushima March 12, 2012, mitigating strategies order, would ensure additional 

defense-in-depth protection for cooling of the spent fuel. Therefore, the environmental risk of 

spent fuel pool releases caused by loss of offsite power is considered to be small. 

A discussion of a postulated spent fuel pool fire resulting from loss of pool water, a severe 

accident in a spent fuel pool, is provided in Appendix F. Appendix F describes the NRC’s 

finding that the probability-weighted consequences of atmospheric releases, fallout onto open 

bodies of water, and societal and economic impacts of spent fuel pool fires are SMALL. 

External Events 

In previous studies, the NRC considered how different types of external events, such as 

tornadoes, aircraft crashes, and seismic events, could lead to a severe accident in a spent fuel 

pool. Each of these external events was evaluated to determine the frequency of spent fuel 

uncovery associated with the event. In NUREG– (NRC 2001), the NRC determined that 

seismic events had higher fuel uncovery frequencies than aircraft crashes and tornadoes. For 

this reason, the seismic event is used in this GEIS as a representative external event causing a 

severe accident. 

As discussed in Appendix F, numerous NRC studies have concluded that spent fuel pool 

structures are seismically robust and can withstand loads substantially beyond those for which 

they are designed (NRC 2001). During an earthquake, the walls and floor of the pool would 

carry the seismically induced hydrodynamic pressure from the pool water. Structural (floor, 

liner, or walls) failure could occur in a beyond-design-basis earthquake, if the magnitude of the 

event is significantly larger than that used in the design. If this occurred, water would rapidly 

drain out of the pool. Only a small amount of water would remain and the spent fuel would be 

uncovered and exposed to the air. A beyond-design-basis earthquake would also likely result in 

the loss of electrical power, which, in addition to any damage to pool superstructure, would 

cause a rise in fuel temperature due to loss of cooling. As discussed in Appendix F of this 

GEIS, if the spent fuel heats to a temperature on the order of 1,000qC (1,832qF), zirconium 

FODGGLQJRQWKHVSHQWIXHOFRXOGLJQLWH3VSHQWIXHOSRRO]LUconium fire”). Further, the spent fuel 

rod could burst due to high temperature, which could cause the collapse of the spent fuel itself. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

Radioactive aerosols and vapors released from the damaged spent fuel could be carried into 

the surrounding environment. Based on the discussion in Appendix F, the frequency of fuel 

EHLQJXQFRYHUHGLVYHU\VPDOODQGLVEHWZHHQ × 10 and 2.4 × 106/yr depending upon the 

seismic hazard assessment. 

Climate Change 

In NUREG–15&1), the NRC determined that the overall frequency of catastrophic 

failure caused by a tornado is extremely low (i.e., the calculated frequency of such as event is 

less than 10–9/yr). The GCRP (2014) determined that trends in the intensity and frequency of 

tornadoes and thunderstorm winds are uncertain and are being studied intensively. Although 

research suggests future increases in the frequency of environmental conditions favorable to 

severe thunderstorms, the scarcity of high-quality data, and the fact that these phenomena are 

too small to be directly represented in climate models, makes it difficult to project how the 

character of severe thunderstorms and tornadoes might change in the future (GCRP 2014). 

Therefore, the NRC assumes that the risk posed by tornadoes will be comparable to the risk 

determined in the 2001 study through the short-term storage timeframe. 

In its 2001 study, the NRC determined that the frequency of significant damage to spent fuel 

pool support systems from straight-line winds, such as those from hurricanes, is very low. The 

NRC also estimated that the fuel uncovery frequency for loss of offsite power caused by severe 

weather events was 1.1 × 10–/yr (NRC 2001). The Global Change Research Program 

determined that the United States and surrounding coastal waters may experience more intense 

hurricanes, but not necessarily an increase in the number of these storms that make landfall 

(GCRP 2014). An increase in the intensity of storms that make landfall as a result of climate 

change may increase the likelihood of both structural failures in buildings housing spent fuel 

pools and loss-of-offsite-SRZHUHYHQWV:KLOHWKHPDJQLWXGHRIWKHFKDQJHLQGDPDJH likelihood 

cannot be quantitatively predicted at this time, an increase in storm intensity is not expected to 

change the NRC’s determination that the overall risk of external events on continued storage in 

spent fuel pools is small. 

If climate change influences on sea-level rise create conditions adverse to safety, those 

changes would occur so slowly that the NRC has sufficient time to require licensees to 

implement corrective actions to identify and correct conditions adverse to safety. For example, 

the spent fuel could be transferred into dry casks and either relocated to higher elevation within 

the existing site or transported to a different site. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-88 September 2014 

Summary 

The NRC has examined the risk of severe accidents in spent fuel pools in several studies over 

the years. Based on these assessments, which include consideration of internal and external 

event initiators and climate change, the NRC concludes that the risk of severe accidents in 

spent fuel pools is small. 

4.18.2.2 Severe Accidents in Dry Cask Storage Systems and DTSs 

Both the NRC and EPRI have completed probabilistic risk assessments that consider risks to 

the public of severe accidents involving dry cask storage system operations. Both studies were 

generic in nature and considered a range of events that could result in sufficient damage to dry 

casks to cause radiological releases7KH(35,SUREDELOLVWLFULVNDVVHVVPHQWH[DPLQHG3:5

spent fuel in bolted casks (EPRI 2004). The NRC probabilistic risk assessment H[DPLQHG%:5

spent fuel in a canister-based dry cask storage system 15&I. The results of both 

studies were evaluated by the 15&¶V$GYLVRU\&RPPLWWHHRQ1XFOHDU:DVWHGXULQJLWVQG

meeting on July 20, 2006 (NRC 2006d). 

In NUREG–1864, A Pilot Probabilistic Risk Assessment of Dry Cask Storage System at the 

Nuclear Power Plant, the NRC analyzed various phases of the dry cask storage process from 

loading fuel from the spent fuel pool, preparing the cask for storage and transferring it outside 

the reactor building, moving the cask from the reactor building to the storage pad, and storing 

the cask for 20 years on the storage pad 185(*I. The study assessed a 

comprehensive list of initiating events, including dropping the cask during handling and external 

events during onsite storage (such as earthquakes, floods, high winds, lightning strikes, 

accidental aircraft crashes, and pipeline explosions). The study also modeled potential cask 

failures from mechanical and thermal loads. As shown in Table 18 of NUREG–1864, the largest 

conditional consequences to an individual person of postulated accidents are expected to range 

from 2.8 mSv (280 mrem), at a distance of less than 1.6 km (1 mi), up to 6Y rem) at 

the same distance. For example, DSRVWXODWHG-m (19-ft) drop of a multipurpose canister 

while being lowered from the transfer cask to the storage cask would result in larger 

consequences. This drop can happen due to a design basis earthquake during canister 

handling operation and has the most severe consequence of potential drops. However, the 

probability of a release causing this dose consequence, which includes consideration of the 

initiating event frequency and conditional probability of release, given the event occurs, is about 

3 × 10/yr. 

EPRI’s 2004 study covered various phases of the dry cask storage process. Like the NRC 

study, the EPRI study considered a comprehensive list of initiating events, including dropping 

the cask during handling and events caused by severe natural phenomena. For average 

meteorological conditions, EPRI’s estimates of the conditional downwind consequences from 

accidents to an individual person range from 0.00018 mSv (0.018 mrem) DWDGLVWDQFHRINP
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-89 185(*௅

(0.3 mi) up to 0.194 Sv (19.4 rem) at a distance of 0.4 km ( mi). The lowest consequences 

for events in which there could be any radiological release are associated with dropping a cask. 

The highest consequences are associated with an impact to the cask followed by a fire, such as 

could occur after an impact of an aircraft. The probability of each type of event considered by 

EPRI is OHVVWKDQ[-6/yr. 

Therefore, although the consequences would exceed NRC public dose standards contained in 

10 CFR Part 20 (e.g., 100-mrem/yr dose limits for members of the public), the likelihood of the 

event is very low. Therefore, the environmental risk of an accident is SMALL. 

The use of a DTS for the purposes of this continued storage environmental analysis represents 

a reasonable assumption for how future licensees are likely to repackage spent fuel, should 

repackaging activities become necessary during continued storage. However, the NRC has not 

received an application to construct and operate a DTS and, therefore, has not analyzed the 

environmental impacts of severe accidents at a DTS. As described in Section 2.1.4, the DOE 

prepared, and NRC reviewed, a topical safety analysis report for a conceptual design of a DTS. 

DOE’s topical safety analysis report includes some of the types of information and analyses 

required to license a DTS, some of which is provided in this GEIS to describe the environmental 

impacts of constructing, operating, and replacing a DTS. DOE’s analysis in the topical safety 

analysis report did not include consideration of severe accidents. However, the NRC’s overall 

requirements for licensing spent fuel storage facilities under 10 CFR ParWHQVXUHWKDWWKHULVN

of severe accidents at a DTS would be small. Although the NRC has not analyzed the 

environmental impacts of severe accidents at a DTS, given that the amount of spent fuel being 

handled in a DTS is limited to the contents of a single dry cask, the consequences described 

above for cask drops provide some insight into the consequences of severe accidents at a DTS. 

Because compliance with NRC regulations for spent fuel handling and storage would likely 

make the risk of severe accidents at a DTS small, and the consequences of any severe 

accident at a DTS would likely be comparable to or less than that for the cask drop accident 

described above, the NRC concludes the likely impacts from activities at a DTS would be small. 

Climate Change 

In the probabilistic risk assessments described above, both EPRI and the NRC evaluated high 

winds and floods as initiating events for accidents. The dry cask storage system that was 

evaluated by the NRC was the Holtec HI–STORM 100 system. This vertical cask system is in 

common use (see Appendix G) at nuclear power plants. As discussed in more detail below, the 

NRC believes that NUREG–1864 provides a useful analysis of the types of high winds and 

floods that could be expected to occur as a result of climate change. Therefore, the results of 

WKH15&¶VVWXG\185(*–186415&I) illustrate the effects of climate change for 

the purposes of this GEIS. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-90 September 2014 

NUREG–1864 concluded that winds in excess of 644 km/hr (400 mph) would be required to 

cause storage cask tip-over, and winds in excess of 1,448 km/hr (900 mph) would be required 

to propel a heavy object into a storage cask with enough force to cause significant damage. 

There is no recorded evidence of tornado wind speeds in excess of 480 km/hr (300 mph) 

(NRC I9HU\IHZKXUULFDQHVKDYHDFKLHYHGZLQGVSHHGVRINPKU(190 mph) 

(Bender et al. 2010). Further, although climate models project future increases in the frequency 

of environmental conditions favorable to severe thunderstorms, the scarcity of high-quality data 

associated with the intensity and frequency of tornadoes and thunderstorm winds, combined 

with the fact that these phenomena are too small to be directly represented in climate models, 

makes it difficult to project how the character of severe thunderstorms might change in the 

future (GCRP 2014). Therefore, the NRC assumes that the risk posed by high winds remains 

very low. 

Floods were also considered in NUREG–1864, but deemed not able to affect the plant that was 

the subject of the study. In general, the effects of floods on dry cask storage systems can 

include cask sliding, tip-over, and blockage of ventilation ports by water and silting of air 

passages. Other effects include water scouring below ISFSI foundations, burial under debris, 

and severe temperature gradients resulting from rapid cooling from immersion in water 

(NRC I. However, based on the relatively slow rate of change in flood risk over time, 

the NRC is confident that any regulatory action that may be necessary will be taken in a timely 

manner to ensure the safety of dry cask storage systems. 

If climate change influences on sea-level rise create conditions adverse to safety, the NRC has 

sufficient time to require licensees to implement corrective actions to identify and correct 

conditions adverse to safety. Some of the specific corrective actions that could be taken include 

elevating the existing ISFSI, relocating dry casks to higher ground onsite, or transporting the 

spent fuel to a different site. 

Summary 

The NRC has examined the risk of severe accidents in dry cask storage systems. Based on 

this assessment, which includes consideration of internal and external event initiators and 

climate change, the NRC concludes that the risk of severe accidents in dry cask storage 

systems is small. 

4.18.2.3 Conclusion 

The NRC has examined the risk of severe accidents in spent fuel pools and dry cask storage 

systems in several studies over the years. Based on these assessments, the NRC concludes 

that the risk of severe accidents in spent fuel pools and dry cask storage systems is SMALL. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-91 185(*௅

4.19 Potential Acts of Sabotage or Terrorism 

This section describes the environmental impacts of potential acts of sabotage or terrorism 

involving the continued storage of spent fuel. The NRC regulates the security of radioactive 

material as part of its domestic safeguards program. This program provides for regulatory 

requirements; licensing and NRC oversight of facility access control; fitness for duty; material 

control and accounting; and physical protection of spent fuel storage in onsite spent fuel pools, 

at-reactor and away-from-reactor ISFSIs, and monitored retrievable storage installations. 

This GEIS considers the potential risks of accidents and acts of sabotage or terrorism at spent 

fuel storage facilities. In 1984 and 1990, the NRC provided some discussion of the reasons why 

it believed that the possibility of a major accident or sabotage with offsite radiological impacts at 

DVSHQWIXHOVWRUDJHIDFLOLW\LVH[WUHPHO\UHPRWH,QWKHXSGDWHWRWKH:DVWH&RQILGHQFH

Decision, the Commission gave considerable attention to the issue of terrorism and spent fuel 

PDQDJHPHQW)57KH&RPPLVVLRQFRQFOXGHGWKDW

>W@RGD\VSHQWIXHOLVEHWWHUSURWHFWHGWKDQHYHU7KHUHVXOWVRIVHFXULW\

assessments, existing security regulations, and the additional protective and 

mitigative measures imposed since September 11, 2001, provide high assurance 

that the spent fuel in both spent fuel pools and in dry storage casks will be 

DGHTXDWHO\SURWHFWHG)5

There is dispute among the United States Courts of Appeals as to whether NEPA analyses 

require consideration of terrorist attacks. In San Luis Obispo Mothers for Peace v. NRC, the 

Court of Appeals for the Ninth Circuit held that the NRC needed to consider the environmental 

impacts of terrorism in its NEPA reviews. In contrast, in 2009, the Court of Appeals for the Third 

Circuit upheld the NRC's position that terrorist attacks are too far removed from the natural or 

expected consequences of agency action to require environmental analysis. Nonetheless, 

because some continuing storage will occur within the Ninth Circuit, this GEIS discusses the 

environmental impacts of a successful terrorist attack to comply with San Luis Obispo Mothers 

for Peace v. NRC. The Ninth Circuit left to agency discretion the precise manner in which the 

NRC undertakes a NEPA-terrorism review (NRC 2008c). 

The environmental impacts of a successful terrorist attack, if one occurs, could be significant 

and destabilizing. The impact determinations for these attacks, however, are made with 

consideration of the low probability of successful attack. The environmental impact 

determination with respect to successful terrorist attacks, therefore, is based on risk, which 

the NRC defines as the product of the probability, even if only a qualitative assessment of 

 

 The regulations in 10 CFR that are most applicable to the domestic safeguards program for spent 

nuclear fuel storage EH\RQGWKHOLFHQVHGOLIHIRURSHUDWLRQDUHFRQWDLQHGLQ3DUWV

DQG
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-92 September 2014 

probability is available, and the consequences of a successful attack. This means that a highconsequence, low-probability event could result in a small impact determination if the risk is 

sufficiently low. 

Impacts from terrorist acts for spent fuel pool storage might occur only during the short-term 

timeframe, and the impacts for dry cask storage are substantially the same across the three 

timeframes. Therefore, this section of the GEIS follows a different format from other sections by 

presenting the various accident types only once. The three storage timeframes (short-term, 

long-term, and indefinite, as described in Chapter 1) apply as follows: 

x During short-term storage, the probability and consequences of attacks on both the onsite 

spent fuel pool and at-reactor ISFSI are considered. 

x Beyond short-term storage, spent fuel is assumed to have been moved from the spent fuel 

pool to an at-reactor ISFSI. Therefore, during long-term and indefinite storage timeframes, 

only the probability and consequences of attacks on the at-reactor ISFSI are applicable. 

4.19.1 Attacks on Spent Fuel Pools 

The NRC has determined that the probability of a successful terrorist attack on a spent fuel 

pool, although numerically indeterminable, is very low )57RVXSSRUWWKLV

conclusion, the NRC reviewed the characteristics of spent fuel pools discussed in Chapter 2 and 

assessed how those features would deter terrorist attacks. Spent fuel pool structural features, 

complemented by the deployment of effective and visible physical security protection measures, 

described further below, are deterrents to terrorist attack. In addition, the emergency 

procedures developed for reactor accidents provide a means for mitigating the potential 

FRQVHTXHQFHVRIWHUURULVWDWWDFNV FR 46204). 

Further, after the terrorist attacks of September 11, 2001, the NRC issued a series of Security 

Orders to require licensees to implement additional interim security measures. Through these 

Orders, the NRC supplemented the Design Basis Threat rule for radiological sabotage6 and 

mandated specific licensee enhancement of security force training, access authorization, and 

defensive strategies, plus additional mitigative measures. In addition, through generic 

communications, the NRC specified expectations for enhanced notifications to the NRC for 

certain security events or suspicious activities. 

In response to the Security Orders, facility licensees revised their physical security plans, 

access authorization programs, training and qualification plans, and safeguards contingency 

 

6 7KHGHILQLWLRQIRUGHVLJQEDVLVWKUHDWIRUUDGLRORJLFDOVDERWDJHLVFRQWDLQHGLQ&)5DZKLFK

describes a determined violent external assault, attack by stealth, or deceptive actions, including 

diversionary actions, by an adversary force capable of operating in each of several modes and with 

attributes, assistance, and equipment as defined in the regulation. Under NRC’s Design Basis Threat 

rule, licensees must be able to defend against these threats with high assurance. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-93 185(*௅

plans. These revisions enhanced physical security with increased patrols, augmented security 

forces and capabilities, added additional security posts, added additional physical barriers, and 

required vehicle checks at greater standoff distances. Procedural enhancements resulted in 

greater coordination with law enforcement authorities, augmented security and emergency 

response training, equipment, and communication, and more restrictive site access controls for 

personnel, including expanded, expedited, and more thorough employee background 

investigations (NRC 2008c). 

,QWKH15&DPHQGHGLWVUHJXODWLRQVLQ &)53DUWJRYHUQLQJOLFHQVHHFDSDELOLty to 

defend against design basis threats of radiological sabotage to capture experience and insights 

gained by the NRC in implementing those requirements and to redefine the level of security 

requirements necessary to ensure adequate protection of the public health and safety and 

FRPPRQGHIHQVHDQGVHFXULW\)5,Q2009, the NRC amended its regulations in 

10 &)53DUWVDQGWRFRGLI\WKHDSSURSULDWHUHTXLUHPHQWVIURPWKH6HFXULW\

Orders and update those requirements with new insights gained from implementation of the 

Security Orders, review of site security plans, implementation of the enhanced baseline 

inspection program, and NRC evaluation of force-on-force exercises. This rulemaking, which 

includes cybersecurity requirements, also updated the NRC's security regulatory framework for 

WKHOLFHQVLQJRIQHZQXFOHDUSRZHUSODQWV)5The cybersecurity requirements, 

ZKLFKDUHFRGLILHGDV&)5UHTXLUHOLFHQVHHVWRSURYLGHKLJKDVVXUDQFHWKDWGLJLWDO

computer and communication systems and networks are adequately protected against cyberDWWDFNVXSWRDQGLQFOXGLQJGHVLJQEDVLVWKUHDWVDVGHVFULEHGLQ&)533XUSRVHDQG

Scope.” To ensure that design basis threats described in 10 CFR remain a valid basis for 

the design of physical protection systems, the NRC staff performs extensive analysis of 

intelligence information gathered from classified and open sources and provides the results of 

this analysis, including recommendations for increasing or decreasing the design basis threat 

for NRC-licensed facilities, in an annual written report to the Commission. 

As discussed in more detail in the NRC’s response to a draft U.S. Government Accountability 

Office report on material control and accounting of spent fuel, with regard to theft and diversion 

of spent fuel, the NRC believes that the likelihood that an adversary could steal spent fuel from 

a spent fuel pool is extremely low, given the security and radiation protection measures in place, 

the ease of detectability, and the physically disabling radiation from the spent fuel. Further, the 

NRC also does not consider the threat of a knowledgeable, active insider stealing a spent fuel 

URGRUSRUWLRQWKHUHRIWREHFUHGLEOH15&G

The NRC has determined that these measures and national anti-terrorist measures to prevent, 

for example, aircraft hijackings, coupled with the robust nature of spent fuel pools, make the 

probability of a successful terrorist attack, although numerically indeterminable, very low 

 FR 46204). 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-94 September 2014 

Although a successful act of sabotage or terrorism by an armed attack is low in probability, the 

consequences of such an act could be severe. A discussion of a postulated spent fuel pool fire 

resulting from loss of pool water, which could result from a successful attack, is provided in 

Appendix F. The conditional consequences described in Appendix F include downwind 

collective radiation doses above one million person-rem, up to 191 early fatalities, and economic 

damages exceeding $ billion. However, given the very low probability of a successful attack 

with these consequences, the NRC determined that the risk of successful attack is small. 

4.19.2 Attacks on ISFSIs and DTS 

Before September 11, 2001, the NRC’s regulations that apply to future DTS licensees and 

current and future ISFSI licensees required licensees to comply with the security requirements 

VSHFLILHGLQ&)53DUW3/LFHQVLQJ5HTXLUHPHQWVIRUWKH,QGHSHQGHQW6WRUDJHRI6SHQW

Nuclear Fuel, High-/HYHO5DGLRDFWLYH:DVWHDQG5HDFWRU-Related Greater than Class C 

:DVWH ́DQG&)53DUW33K\VLFDO3URWHFWLRQRI3ODQWVDQG0DWHULDOV ́$IWHUWKHDWWDFNVRI

September 11, 2001, the NRC enhanced security for all facilities licensed to store spent fuel 

through a combination of the existing security regulations and the issuance of Security Orders to 

individual ISFSI licensees. These orders ensured that a consistent, comprehensive protective 

strategy was in place for all ISFSIs. 

As discussed in Chapter 2, two types of ISFSI licenses (general and specific) are available for 

the storage of spent fuel; a future DTS would be licensed under the specific license provisions 

of 10 CFR 3DUWPhysical security requirements for these licensees appear in various 

sections of 10 &)53DUWGHSHQGLQJRQWKHW\SHRIOLFHQVHH7KHUHJXODWLRQVLQ

10 CFR E&RQGLWLRQVRI*HQHUDO/LFHQVH,VVXHGXQGHUUHTXLUHJHQHUDO

ISFSI licensees to establish a physical protection program that protects the spent fuel against 

the design basis threat for radiological sabotage in accordance with applicable security 

UHTXLUHPHQWVLPSRVHGRQQXFOHDUSRZHUUHDFWRUOLFHQVHHVXQGHU&)535HTXLUHPHQWV

for Physical Protection of Licensed Activities in Nuclear Power Reactors Against Radiological 

Sabotage.” For general-OLFHQVH,6)6,VQHLWKHU&)5EQRU CFR 

imposes a dose limit for security events (i.e., acts of radiological sabotage). For specifically 

licensed ISFSIs and DTSs15&UHJXODWLRQVDW&)535HTXLUHPHQWVIRUWKH3K\VLFDO

Protection of Stored Spent Nuclear Fuel and High-/HYHO5DGLRDFWLYH:DVWH ́UHTXLUHOLFHQVHHV

to establish and maintain a physical protection system that provides high assurance that 

licensed activities do not constitute an unreasonable risk to public health and safety. The 

physical protection system must protect against the loss of control of the ISFSI or DTS that 

could be sufficient to cause a radiation exposure exceeding the dose limitation in 

10 CFR 15&J).

 

 As described in Section 2.1.4 of this GEIS, there are currently no DTS licensees, but these 

requirements would apply to persons that seek to build and operate a DTS. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

In general, the potential for theft or diversion of light water reactor spent fuel from the ISFSI with 

the intent of using the contained special nuclear material for nuclear explosives is not 

considered credible because of (1) the inherent protection afforded by the massive reinforcedconcrete storage module and the steel storage canister; (2) the unattractive form of the 

contained special nuclear material, which is not readily separable from the radioactive fission 

products; and (3) the immediate hazard posed by the high radiation levels of the spent fuel to 

persons not provided radiation protection (NRC 1991c, 1992). 

The immediate hazard posed by the high radiation levels of the spent fuel will, however, 

diminish over time, depending on burnup and the level of radiation deemed to provide adequate 

self-protection. Self-protection refers to the incapacitation inflicted upon a recipient from 

inherent radiation emissions in a timeframe that prevents the recipient from completing an 

intended task (Coates et al. 7KLVPHDQVWKDWVSHQWIXHOFRXOGEHFRPHPRUHVXVFHSWLEOH

to possible theft or diversion over long periods of time. This susceptibility depends on the 

burnup; higher burnup spent fuel provides adequate self-protection for longer time periods. 

The Blue Ribbon Commission on America’s Nuclear Future: Report to the Secretary of Energy 

(BRC 2012) concluded: 

As the duration of storage is extended, the amount of penetrating radiation 

emitted by spent fuel will diminish. In the process, the fuel loses a degree of 

3VHOI-protection” against theft or diversion: in other words, unshielded exposure to 

the fuel becomes less immediately debilitating and hence creates less of a 

deterrent to handling by unauthorized persons. This means that over long time 

periods (perhaps a century or more, depending on burnup and the level of 

radiation that is deemed to provide adequate self-protection), the fuel could 

become more susceptible to possible theft or diversion (although other 

safeguards would remain in place). This in turn could change the security 

requirements for older spent fuel. Extending storage to timeframes of more than 

a century could thus require increasingly demanding and expensive security 

protections at storage sites. 

Further, for non-light water reactor spent fuel, the period of self-protection may be lower than 

that of light water reactor spent fuel, depending on the burnup of the spent fuel and the isotopic 

composition of the special nuclear material (i.e., the attractiveness of the material for diversion). 

Thus, additional security requirements may be necessary in the future if spent fuel remains in 

storage for a substantial period of time. Under those circumstances, it is reasonable to assume 

that, if necessary, the NRC will issue orders or enhance its regulatory requirements for ISFSI 

and DTS security, as appropriate, to ensure adequate protection of public health and safety and 

the common defense and security. 

The NRC has determined that the measures described above, coupled with the robust nature of 

dry cask storage systems, make the probability of a successful terrorist attack, although 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-96 September 2014 

numerically indeterminable, very low. Furthermore, the probability of successfully detonating an 

improvised nuclear device (IND) is even more remote because there are significant steps 

required to manufacture an IND from spent fuel, including theft of the spent fuel, removal of the 

spent fuel from the site, and significant chemical and metallurgical processing steps to 

manufacture an IND. 

The conditional consequence of a successful theft and diversion attack that ultimately results in 

detonation of an IND would be catastrophic. The National Academies and U.S. Department of 

Homeland Security have estimated environmental effects caused by detonation of an IND. For 

a 10-kiloton device, the shockwave could kill exposed persons within 0.6 km (0.4 mi); the heat 

effects could kill persons within 1.8 km (1.1 mi); and initial radiation doses would exceed 4 Gy 

(400 rad) up to 1.3 km (0.8 mi) away. Radioactive fallout could result in doses above 4 Gy (400 

rad) out to  km (6 mi). Long-term environmental effects would include contaminated property 

and food supplies, death and illness, loss of jobs, and costs to local, State, and Federal 

govHUQPHQWVWRUHVWRUHSURSHUW\DQGJRRGV1DWLRQDO$FDGHPLHV

:LWKUHVSHFWWRWKHSRWHQWLDOIRUUDGLRORJLFDOVDERWDJHafter the NRC issued the license for the 

Diablo Canyon ISFSI in March 2004, the Ninth Circuit reviewed the licensing action and, as 

discussed, required the NRC to consider terrorist acts in its environmental review associated 

with this licensing action. In response to the Ninth Circuit decision, the NRC supplemented its 

EA and finding of no significant impact for the Diablo Canyon ISFSI to address the likelihood 

DQGWKHSRWHQWLDOFRQVHTXHQFHVRIDWHUURULVWDWWDFNGLUHFWHGDWWKH,6)6,15&g): 

The NRC staff reviewed the analyses performed for generic ISFSI security 

assessments, and compared their assumptions to the relevant features of the 

Diablo Canyon ISFSI. Based on this comparison, the staff determined that the 

assumptions used in these generic security assessments regarding storage cask 

design, source term (amount of radioactive material released), and atmospheric 

dispersion, were representative, and in some cases, conservative, relative to the 

actual conditions at the Diablo Canyon ISFSI. In fact, because of the specific 

characteristics of the spent fuel authorized for storage at the Diablo Canyon 

ISFSI (lower burnup fuel), and the greater degree of dispersion of airborne 

radioactive material likely to occur at the site, any dose to affected residents 

nearest to the Diablo Canyon site will tend to be much lower than the doses 

calculated for the generic assessments. Based on these considerations, the 

dose to the nearest affected resident, from even the most severe plausible threat 

scenarios – the ground assault and aircraft impact scenarios – would likely be 

EHORZ rem. In many scenarios, the hypothetical dose to an individual in the 

DIIHFWHGSRSXODWLRQFRXOGEHVXEVWDQWLDOO\OHVVWKDQUHPRUQRQHDWDOO,Q

some situations, emergency planning actions could provide an additional 

measure of protection to mitigate the consequences, in the unlikely event that a 

successful attack were carried out at the Diablo Canyon ISFSI. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

7KHVSHFLILFGRVHUHVXOWVIURPWKH'LDEOR&DQ\RQ,6)6,($6XSSOHPHQWZHUHGHULYHG

from the generic analysis performed as part of ISFSI security assessments (NRC 2003). The 

site-specific assumption in the EA Supplement was the distance to the nearest resident from the 

'LDEOR&DQ\RQ,6)6,ZKLFKLVDERXWNPPL%\FRPSDULVRQWKLVLVPRUHWKDQWKH

average distance to nearby residences for other specifically licensed ISFSIs, which is about 

1.6 km (1 mi). Doses at closer residences could be larger, but are likely to remain well below 

levels that could cause immediate health effects. The NRC took both the estimated dose and 

the likelihood into consideration in making a finding of no significant impact. Thus, the NRC 

determines that the environmental risk is SMALL. In addition, the environmental risk of impacts 

on property and land resulting from downwind settling of airborne radioactive material would be 

SMALL. 

In February 2011, after a challenge to the Supplemental Environmental Assessment, the Ninth 

Circuit issued a decision affirming its sufficiency (San Luis Obispo Mothers for Peace v. NRC). 

The consequences of successful radiological sabotage at a DTS would be similar to the 

consequences of postulated accidents at a DTS. For example, Section 4.18.1.2 of this GEIS 

describes a design basis event at a DTS involving 21 damaged spent fuel assemblies in an open 

cask that results in a release of radioactive material through an inoperable ventilation system. 

7KHWRWDOGRVHWRDSHUVRQVWDQGLQJPIWDZD\LVHVWLPDWHGWREH1 mSv 

 mrem). 

4.19.3 Conclusion 

The NRC finds that even though the environmental consequences of a successful attack on a 

spent fuel pool during continued storage would be large, the very low probability of a successful 

attack ensures that the environmental risk is SMALL. Similarly, for operational ISFSIs and 

DTSs during continued storage, the NRC finds that the environmental risk is SMALL. 

4.20 Summary 

The impact determinations for at-reactor storage for each resource area for each timeframe are 

summarized in Table 4-2. For most of the resource areas, the impact determinations for all 

three timeframes are SMALL. Continued storage is not expected to adversely affect special 

species and habitats. For accidents (design basis and severe) and terrorism considerations, the 

environmental risks of continued storage are SMALL. 

However, for a few resource areas, impact determinations are greater than SMALL and varied 

for the three timeframes. For the long-term storage and indefinite storage timeframes, during 

which ground-disturbing activities may occur, impacts on historic and cultural resources range 

from SMALL to LARGE. The impacts from management and disposal of nonradioactive waste 

would be SMALL for both the short-term and long-term timeframes but SMALL to MODERATE 

for indefinite storage. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

185(*௅ 4-98 September 2014 

Table 4-2. Summary of Environmental Impacts of Continued At-Reactor Storage 

Resource Area Short-Term Storage Long-Term Storage Indefinite Storage 

Land Use SMALL SMALL SMALL 

Socioeconomics SMALL SMALL SMALL 

Environmental Justice Disproportionately high and adverse impacts are not expected 

Air Quality SMALL SMALL SMALL 

 Air Emissions SMALL SMALL SMALL 

 Thermal Releases SMALL SMALL SMALL 

Climate Change SMALL SMALL SMALL 

Geology and Soils SMALL SMALL SMALL 

6XUIDFH:DWHU

 Quality SMALL SMALL SMALL 

 Consumptive Use SMALL SMALL SMALL 

Groundwater 

 Quality SMALL SMALL SMALL 

 Consumptive Use SMALL SMALL SMALL 

Terrestrial Resources SMALL SMALL SMALL 

Aquatic Ecology SMALL SMALL SMALL 

Special Status Species 

and Habitats 

Impacts on Federally listed threatened and endangered species and 

Essential Fish Habitat would be determined as part of the consultations 

for the ESA and Magnuson-Stevens Fishery Conservation and 

Management Act 

Historic and Cultural 

Resources 

SMALL SMALL to LARGE SMALL to LARGE 

Noise SMALL SMALL SMALL 

Aesthetics SMALL SMALL SMALL 

:DVWH0DQDJHPHQW

 //: SMALL SMALL SMALL 

 0L[HG:DVWH SMALL SMALL SMALL 

 1RQUDGLRDFWLYH:DVWH SMALL SMALL SMALL to 

MODERATE 

Transportation SMALL SMALL SMALL 

 Traffic SMALL SMALL SMALL 

 Health Impacts SMALL SMALL SMALL 

Public and Occupational 

Health 

SMALL SMALL SMALL 

Accidents SMALL SMALL SMALL 

Sabotage or Terrorism SMALL SMALL SMALL 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4-99 185(*௅

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10 CFR Part 20. Code of Federal Regulations, Title 10, Energy3DUW36WDQGDUGVIRU

3URWHFWLRQ$JDLQVW5DGLDWLRQ ́:DVKLQJWRQ'&

&)53DUWCode of Federal Regulations, Title 10, Energy3DUW3$FFHVV

$XWKRUL]DWLRQ ́:DVKLQJWRQ'&

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3URJUDPV ́:DVKLQJWRQ'&

&)53DUWCode of Federal Regulations, Title 10, Energy3DUW3'RPHVWLF/LFHQVLQJRI

3URGXFWLRQDQG8WLOL]DWLRQ)DFLOLWLHV ́:DVKLQJWRQ'&

10 CFR Part Code of Federal Regulations, Title 10, Energy3DUW3(QYLURQPHQWDO

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:DVKLQJWRQ'&

&)53DUWCode of Federal Regulations, Title 10, Energy3DUW3/LFHQVHV

&HUWLILFDWLRQVDQG$SSURYDOVIRU1XFOHDU3RZHU3ODQWV ́:DVKLQJWRQ'&

&)53DUWCode of Federal Regulations, Title 10, Energy3DUW3'RPHVWLF/LFHQVLQJRI

6SHFLDO1XFOHDU0DWHULDO ́:DVKLQJWRQ'&

&)53DUWCode of Federal Regulations, Title 10, Energy3/LFHQVLQJ5HTXLUHPHQWVIRU

the Independent Storage of Spent Nuclear Fuel, High-/HYHO5DGLRDFWLYH:DVWHDQG5HDFWRU5HODWHG*UHDWHU7KDQ&ODVV&:DVWH ́:DVKLQJWRQ'&

&)53DUWCode of Federal Regulations, Title 10, Energy3DUW33K\VLFDO3URWHFWLRQRI

3ODQWVDQG0DWHULDOV ́:DVKLQJWRQ'&

&)53DUWCode of Federal Regulations, Title 10, Energy3DUW30DWHULDO&RQWURODQG

$FFRXQWLQJRI6SHFLDO1XFOHDU0DWHULDO ́:DVKLQJWRQ'&

10 CFR Part 100. Code of Federal Regulations, Title 10, Energy3DUW35HDFWRU6LWH

&ULWHULD ́:DVKLQJWRQ'&
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36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

3DUW33URWHFWLRQRI+LVWRULF3URSHUWLHV ́:DVKLQJWRQ'&

40 CFR Part 93. Code of Federal Regulations, Title 40, Protection of the Environment, Part 93, 

3'HWHUPLQLQJ&RQIRUPLW\RI)HGHUDO$FWLRQVWR6WDWHRU)HGHUDO,PSOHPHQWDWLRQV3ODQV ́

:DVKLQJWRQ'&

&)53DUWCode of Federal Regulations, Title 40, Protection of the Environment, 

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:DVKLQJWRQ'&

&)53DUWCode of Federal Regulations7LWOHWildlife and Fisheries, Part 402, 

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&)5Part 600. Code of Federal Regulations7LWOHWildlife and Fisheries, Part 600, 

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Exelon (([HORQ*HQHUDWLRQ&RPSDQ\//&/D6DOOH&RXQW\6WDWLRQ/HWWHUIURP([HORQ

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to NRC, dated November 14, 2003, regarding 3,GDKR Spent Fuel (ISF) Facility Submittal of 

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Migratory Bird Treaty Act of 1918, as amended86&– et seq.

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15&861XFOHDU5HJXODWRU\&RPPLVVLRQDesign Basis Tornado for Nuclear Power 

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15&861XFOHDU5HJXODWRU\&RPPLVVLRQReactor Safety Study: An Assessment of 

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Radioactive Waste.” NUREG–:DVKLQJWRQ'&$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 1989. Regulatory Analysis for the Resolution of 

Generic Issue 82, “Beyond Design Basis Accidents in Spent Fuel Pools.” NUREG–

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Guidance: Standard Radiological Effluent Controls for Pressurized Water Reactors. Generic 

Letter 89–01, Supplement No. 1, NUREG–:DVKLQJWRQ'& Accession No. 

0/
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NRC (U.S. Nuclear Regulatory Commission). 1991c. Environmental Assessment Related to 

Construction and Operation of the Calvert Cliffs Independent Spent Fuel Storage Installation. 

:DVKLQJWRQ'&$FFHVVLRQ1R0/. 

NRC (U.S. Nuclear Regulatory Commission). 1991d. Environmental Assessment Related to 

Construction and Operation of the Fort St. Vrain Independent Spent Fuel Storage Installation. 

:DVKLQJWRQ'&$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 1992. Environmental Assessment Related to 

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:DVKLQJWRQ'&$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 1996. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants185(*í:DVKLQJWRQ'& Available at 

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NRC (U.S. Nuclear Regulatory Commission). 2000. Radiological Consequence Analyses 

Using Alternative Source Terms. Standard Review Plan. SRP–5HYLVLRQ

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Risk at Decommissioning Nuclear Power Plants. NUREG–:DVKLQJWRQ'&$FFHVVLRQ

No. ML010430066. 

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Private Fuel Storage LLC (Independent Spent Fuel Storage Installation) >Environmental Justice 

Contention@” CLI–02–:DVKLQJWRQ'&$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 2002b. Final Generic Environmental Impact 

Statement for Decommissioning of Nuclear Facilities, Supplement 1 Regarding the 

Decommissioning of Nuclear Power Reactors. NUREG–Supplement 1, Volumes 1 and 2, 

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Construction and Operation of the Diablo Canyon Independent Spent Fuel Storage Installation. 

:DVKLQJWRQ'&$FFHVVLRQ1R 0/
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Proposed Idaho Spent Fuel Facility at the Idaho National Engineering and Environmental 

Laboratory in Butte County, Idaho. NUREG–, :DVKLQJWRQ'&Accession 

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License Renewal of the General Electric Morris Operation Independent Spent Fuel Storage 

Installation in Morris, Illinois:DVKLQJWRQ'&$FFHVVLRQ1R0/

15&861XFOHDU5HJXODWRU\&RPPLVVLRQDEnvironmental Assessment Related to 

the Construction and Operation of the Humboldt Bay Independent Spent Fuel Storage 

Installation:DVKLQJWRQ'&$FFHVVLRQ1R0/

15&861XFOHDU5HJXODWRU\&RPPLVVLRQEEnvironmental Assessment Related to 

the Renewal of the H.B. Robinson Steam Electric Plant, Unit No. 2 Independent Spent Fuel 

Storage Installation License, Special Nuclear Material License No. SNM–2502. 

:DVKLQJWRQ '&$FFHVVLRQ1R0/

15&861XFOHDU5HJXODWRU\&RPPLVVLRQFEnvironmental Assessment Related to 

the Renewal of the License for the Surry Independent Spent Fuel Storage Installation. 

:DVKLQJWRQ'&$FFHVVLRQ1R0/

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1R0/

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Learned Task Force Final Report. :DVKLQJWRQ'& $FFHVVLRQ1R0/

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:DVKLQJWRQ'&$FFHVVLRQ1R0/

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an Early Site Permit (ESP) at the North Anna ESP Site. NUREG–1811, Volume 1, 

:DVKLQJWRQ D.C. Accession No. ML063480261. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel 

September 2014 4- 185(*௅

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Nuclear Fuel.” :DVKLQJWRQ'&$FFHVVLRQ1R0/. 

15&861XFOHDU5HJXODWRU\&RPPLVVLRQDGeneric Environmental Impact Statement 

for License Renewal of Nuclear Plants, Supplement 29, Regarding Pilgrim Nuclear Power 

Station, Final Report. NUREG–Supplement 29, 9ROXPH:DVKLQJWRQ'&$FFHVVLRQ

No. 0/

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Safety Analysis Reports for Nuclear Power Plants: LWR Edition. NUREG–0800, Revision 6, 

:DVKLQJWRQ'& $FFHVVLRQ1R0/

15&861XFOHDU5HJXODWRU\&RPPLVVLRQFDesign-Basis Tornado and Tornado 

Missiles for Nuclear Power Plants5HJXODWRU\*XLGH5HYLVLRQ:DVKLQJWRQ'&

Accession No. 0/

NRC (U.S. Nuclear Regulatory Commission). GSeismic Design Classification. 

Regulatory Guide 1.29, Revision 4, :DVKLQJWRQ'&$FFHVVLRQ1R0/

15&861XFOHDU5HJXODWRU\&RPPLVVLRQHQuality Group Classifications and 

Standards for Water-, Steam-, and Radioactive-Waste-Contaminating Components of Nuclear 

Power Plants. Regulatory Guide 1.26, Revision 4:DVKLQJWRQ'&$FFHVVLRQ

No. 0/

15&861XFOHDU5HJXODWRU\&RPPLVVLRQIA Pilot Probabilistic Risk Assessment of a 

Dry Cask Storage System at a Nuclear Power Plant. NUREG–1864:DVKLQJWRQ'&

$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). J. Supplement to the Environmental 

Assessment and Final Finding of No Significant Impact Related to the Construction and 

Operation of the Diablo Canyon Independent Spent Fuel Storage Installation:DVKLQJWRQ'&

$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 2008a. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants, Supplement 32 Regarding Wolf Creek Generating 

Station. NUREG–Supplement 32, :DVKLQJWRQ'& Available at 

http://www.nrc.gov/reading-rm/doc-FROOHFWLRQVQXUHJVVWDIIVUVXSSOHPHQW. 

NRC (U.S. Nuclear Regulatory Commission). 2008b. Final Environmental Impact Statement for 

an Early Site Permit (ESP) at the Vogtle Electric Generating Plant Site. NUREG–

Volume :DVKLQJWRQ'&$FFHVVLRQ1R0/
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NRC (U.S. Nuclear Regulatory Commission). 2008c. 3Memorandum and Order in the Matter of 

Pacific Gas and Electric Co. (Diablo Canyon Power Plant Independent Spent Fuel Storage 

Installation).” CLI–08–01, :DVKLQJWRQ'&$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 2009a. Environmental Assessment for the 

Amendment of U.S. Nuclear Regulatory Commission License No. SNM–2506 for Prairie Island 

Independent Spent Fuel Storage Installation:DVKLQJWRQ'&$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 2009b. Environmental Assessment for the 

Renewal of U.S. Nuclear Regulatory Commission License No. SNM–2503 for Oconee Nuclear 

Station Independent Spent Fuel Storage Installation:DVKLQJWRQ'&$FFHVVLRQ

No. 0/

NRC (U.S. Nuclear Regulatory Commission). 2010. Memorandum from P. HilDQGWR%:

Sheron, dated September 2, 2010, regarding 3Safety/Risk Assessment Results for Generic 

Issue 199, ‘Implications of Updated Probabilistic Seismic Hazard Estimates in Central and 

Eastern United States on Existing Plants.’ ́:DVKLQJWRQ'&$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 2011a. Final Environmental Impact Statement for 

the Combined License (COL) for Calvert Cliffs Nuclear Power Plant Unit 3. NUREG–1936, 

Volumes DQG:DVKLQJWRQ'&$FFHVVLRQ1RV0/$0/$

NRC (U.S. Nuclear Regulatory Commission). 2011b. Senior Management Review of Overall 

Regulatory Approach to Groundwater Protection. SECY–11–:DVKLQJWRQ'&

$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 2011c. Final Environmental Impact Statement for 

the Combined Licenses (COLs) for Virgil C. Summer Nuclear Station, Units 2 and 3. 

NUREG–9ROXPHVDQG:DVKLQJWRQ'&$FFHVVLRQ1RV0/$

0/$

NRC (U.S. Nuclear Regulatory Commission). 2011d. Final Environmental Impact Statement 

for the Combined Licenses (COLs) for South Texas Project Electric Generating Station Units 3 

and 4. NUREG–:DVKLQJWRQ'&$FFHVVLRQ1R0/$

NRC (U.S. Nuclear Regulatory Commission). 2011e. Fact Sheet on Seismic Issues for Nuclear 

Power Plants. :DVKLQJWRQ'&$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 2011f. Design-Basis Hurricane and Hurricane 

Missiles for Nuclear Power Plants. 5HJXODWRU\*XLGH5HYLVLRQ:DVKLQJWRQ'&

Accession No. ML110940300. 
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NRC (U.S. Nuclear Regulatory Commission). 2012a. Environmental Assessment for the 

Proposed Renewal of U.S. Nuclear Regulatory Commission License No. SNM–2505 for 

Calvert Cliffs Nuclear Power Plant, LLC’s Independent Spent Fuel Storage Installation. 

:DVKLQJWRQ'&$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 2012b. Occupational Radiation Exposure at 

Commercial Nuclear Power Reactors and Other Facilities 2010: Forty-Third Annual Report. 

NUREG–9ROXPH :DVKLQJWRQ'&$YDLODEOHDWhttp://www.nrc.gov/reading-rm/doccollections/nuregs/staff/srY. 

NRC (U.S. Nuclear Regulatory Commission). 2012c. Central and Eastern United States 

Seismic Source Characteristics for Nuclear Facilities. NUREG–:DVKLQJWRQ'&

$FFHVVLRQ1R0/$

NRC (U.S. Nuclear Regulatory Commission). 2012d. Request for Information Pursuant to 

Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 

9.3 of the Near-Term Task Force Review of Insights From the Fukushima Dai-Ichi Accident. 

:DVKLQJWRQ'&$FFHVVLRQ1R0/$

NRC (U.S. Nuclear Regulatory Commission). 2013a. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants. NUREG–5HYLVLRQ:DVKLQJWRQ'&

$FFHVVLRQ1R0/$

NRC (U.S. Nuclear Regulatory Commission). 2013b. Environmental Impact Statement for the 

Combined License (COL) for Enrico Fermi Unit 3 Final Report. NUREG–9ROXPHV 1 and 

2, :DVKLQJWRQ'&$FFHVVLRQ1RV0/$0/$

NRC (U.S. Nuclear Regulatory Commission). 2013c. Attachment 1—Staff Guidance for 

Greenhouse Gas and Climate Change Impacts for New Reactor Environmental Impact 

Statements. COL/ESP-ISG-026, :DVKLQJWRQ'&$FFHVVLRQ1R0/$. 

NRC (U.S. Nuclear Regulatory Commission). 2013d. Final Environmental Impact Statement for 

Combined Licenses for William States Lee III Nuclear Station Units 1 and 2. NUREGí2111, 

9ROXPHVDQG:DVKLQJWRQ'& $FFHVVLRQ1RV0/$0/$

0/$

NRC (U.S. Nuclear Regulatory Commission). 2013e. Generic Issue Management Control 

System Report for Fiscal Year 2013 1st Quarter:DVKLQJWRQ'&$FFHVVLRQ1R

0/$
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Pacific Gas and Electric Company. 2012. Letter from Pacific Gas and Electric Company to 

15&GDWHG'HFHPEHUUHJDUGLQJ3'LDEOR&DQ\on Independent Spent Fuel Storage 

Installation - Decommissioning Funding Plan.” Avila Beach, California. Accession 

No. 0/$

3UDVDG5/+LEOHU$&ROHPDQDQG':DUGDesign-Basis Flood Estimation for Site 

Characterization at Nuclear Power Plants in the United States of America. NUREG/CR–, 

3DFLILF1RUWKZHVW1DWLRQDO/DERUDWRU\5LFKODQG:DVKLQJWRQ. Accession No. 0/$

5HVRXUFH&RQVHUYDWLRQDQG5HFRYHU\$FWRI (RCRA). 42 USC 6901 et seq. 

6DIH'ULQNLQJ:DWHU$FW, as amended. 42 USC 300f et seq.

San Luis Obispo Mothers for Peace v. NRC (Nuclear Regulatory Commission). )G

(9th Cir. 2011). 

Transnuclear, Inc. 2004. Standardized NUHOMS® Horizontal Modular Storage System for 

Irradiated Nuclear Fuel. Final Safety Analysis Report, Volume 3 of 4, Appendix M, Hawthorne, 

1HZ<RUN$FFHVVLRQ1R0/

:DVKLQJWRQ6WDWH'HSDUWPHQWRI7UDQVSRUWDWLRQ2014. Biological Assessment Preparation for 

Transportation Projects – Advanced Training Manual – Version 20142O\PSLD:DVKLQJWRQ

Available at http://www.wsdot.wa.gov/Environment/Biology/BA/BAguidance.htm.
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5.0 Environmental Impacts of Away-FromReactor Storage 

This chapter evaluates the environmental impacts of continued away-from-reactor storage of 

spent nuclear fuel (spent fuel) in an independent spent fuel storage installation (ISFSI) beyond 

the licensed life for operation of a reactor during the timeframes considered in this Generic 

Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel (GEIS. 

No away-from-reactor ISFSIs of the size considered in this chapter have been constructed in 

the United States; however, the U.S. Nuclear Regulatory Commission (NRC) has issued a 

license to Private Fuel Storage, LLC (PFS) to construct and operate the Private Fuel Storage 

Facility (PFSF) on the Reservation of the Skull Valley Band of Goshute Indians in Tooele 

County, Utah (NRC 2006a).1

For the purposes of evaluating the environmental impacts of continued storage of spent fuel at 

an away-from-reactor ISFSI, the NRC evaluates the impacts of a facility of the same size as the 

proposed PFS ISFSI. To perform this evaluation, the NRC makes the following assumptions: 

x The ISFSI would have the same capacity as that analyzed for the PFSF, which was 

designed to store up to 40,000 MTU of spent fuel. This amount of spent fuel is more than 

half of the amount generated to date by commercial reactors in the United States, and 

more than twice as much as the amount in dry storage based on the most recent data 

(NRC 2013a). The amount of fuel storage (40,000 MTU) evaluated for the away-fromreactor ISFSI would represent all of the spent fuel from multiple reactor sites. 

x The ISFSI would be of approximately the same physical size as that analyzed for the PFSF, 

which would have been built on a fenced 330-ha (820-ac) site; the actual storage facilities 

would have been built on a 40-ha (99-ac) portion of the site. The onsite facilities (e.g., 

buildings and storage pads) for the ISFSI would be similar to those for the PFSF. This 

aligns with the preceding assumption. 

 

1 Although a license was issued, the PFSF has not yet been constructed. However, the NRC determined 

based on its review of the application that there is reasonable assurance that if the PFSF is constructed: 

(i) the activities authorized by the license can be conducted without endangering the health and safety of 

the public; and (ii) these activities will be conducted in compliance with the applicable regulations of 

10 &)53DUW15&D See also Appendix B, Section B.3.2.2, of this GEIS. In addition, the U.S. 

Department of Energy has indicated that a storage facility of this type is part of its plan to respond to the 

recommendations of the “Blue Ribbon Commission on America’s Nuclear Future” (DOE 2013). 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-2 September 2014 

x The ISFSI would require a dry transfer system (DTS) similar to that described in 

Section 2.1.4 of this GEIS for the long-term storage and indefinite storage timeframes. The 

DTS is assumed to be built sometime after the ISFSI is built because it would not be needed 

immediately. 

x Construction and operation of the ISFSI would be similar to that analyzed for the PFSF and 

would require workforces similar in size to those described for the PFSF, consistent with the 

first assumption above. 

x No specific location is used by the NRC in the evaluation of an away-from-reactor ISFSI. 

However, the location of the ISFSI would be chosen to meet the siting evaluation factors in 

Title 10 of the Code of Federal Regulations 3DUW6XESDUW(&)53DUW6XESDUW(

For example, a site would be deemed unsuitable if adequate protection cannot be provided 

for design basis external events. The NRC would also consider characteristics such as 

population density, seismicity, and flooding potential as part of its evaluation of a proposed 

ISFSI site. 

x In most instances, placement of facilities on a proposed site could be adjusted to minimize 

or avoid impacts on water, ecological, historic and cultural, and other resources in the area; 

however, the NRC recognizes that this is not always possible. Because an away-fromreactor ISFSI does not depend on a significant water supply and has limited electrical power 

needs, an applicant may have more flexibility in how it chooses to place facilities on a site 

and, therefore, a greater chance of avoiding impacts to resources in the area. 

The NRC believes that these assumptions are reasonable and provide an acceptable basis for 

developing a generic evaluation of away-from-reactor storage of spent fuel. The NRC makes no 

assumptions about when the ISFSI might be built. While the NRC assumes that any proposed 

away-from-reactor ISFSI would likely be similar to the assumed generic facility described above 

from the standpoint of the size, operational characteristics, and location of the facility, the NRC 

would evaluate the site-specific impacts of the construction and operation of any proposed 

facility as part of that facility’s licensing process. This review would not reanalyze the impacts of 

continued storage of the spent fuel, but would incorporate the impact determinations of this 

GEIS, as stated in 10 CFR 51.23(b). In this chapter, the term ISFSI refers to all of the original 

facilities that would be built (i.e., storage pads, casks, and canister transfer building), and the 

DTS is addressed separately because the NRC assumes that it would be added after the ISFSI 

would be placed into operation. 

In addition to the assumptions discussed above, the analysis of the environmental impacts of an 

away-from-reactor ISFSI are based, in general, on the description of the affected environment 

provided and discussed in Sections 3.1 through 3.16 for at-reactor spent fuel storage. However, 

some aspects of the discussions are not applicable, or are not applicable in the same way, for 

an away-from-reactor ISFSI. The NRC analysis will be based on the following differences: 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-3 185(*௅

x Portions of the discussion of at-reactor spent fuel storage address facilities that are in semiurban areas. However, the NRC assumes that an away-from-reactor ISFSI will be built in an 

area of low population density. 

x Portions of the discussion of at-reactor spent fuel storage start from an assumption that 

socioeconomic conditions and infrastructure (e.g., access roads) have been established 

prior to the short-term storage timeframe due to the presence of an existing nuclear power 

plant. For an away-from-reactor ISFSI, the NRC assumes conditions typical in remote areas 

(e.g., limited pre-existing road infrastructure). 

x Portions of the discussion of at-reactor spent fuel storage start from an assumption that 

certain site conditions (e.g., proximity to major waterbodies and associated historic and 

cultural resources) are related to the way nuclear power plants are sited. Those conditions 

likely would not be applicable to an away-from-reactor ISFSI. For an away-from-reactor 

ISFSI, the NRC assumes that the site selection would be adjusted to minimize impacts on 

local resources, including historic and cultural resources and special status species and 

habitats, while acknowledging that in some cases avoiding impacts may not be possible. 

x Portions of the discussion of at-reactor spent fuel storage assume pre-existing programs 

associated with operating reactors (e.g., radiological environmental monitoring program and 

monitoring for decommissioning) that would exist in a somewhat different form for an awayfrom-reactor ISFSI. For an away-from-reactor facility, the NRC bases its evaluation of the 

impacts of public and occupational doses on the limits and radiological monitoring 

requirements in 10 &)53DUWDQG&)53DUWWKDWDUHDSSOLFDEOHWRDQDZD\-fromreactor ISFSI. 

x Portions of the discussion of at-reactor spent fuel storage focus on issues related to reactor 

plant systems (e.g., cooling-water systems, liquid and gaseous radioactive waste, and 

transmission lines), which would not be applicable for an away-from-reactor ISFSI. For an 

away-from-reactor facility, the NRC bases its evaluation of impacts on the systems and 

supporting facilities that are expected at such an installation. 

With these exceptions, the NRC used the descriptions of the affected environment in 

Sections 3.1 through 3.16 in its evaluation of the environmental impacts of an away-from-reactor 

ISFSI. 

Major features of the away-from-reactor ISFSI include the canister transfer building, the DTS, 

the storage casks, and the storage pads. The canister transfer building is used to receive 

transportation packages and to move spent fuel canisters from the transportation packages to 

storage casks for movement to the pads. The building would also be used to move spent fuel 

canisters from the storage casks into transportation packages for the shipment of the spent fuel 

to the repository. The canister transfer building would be used in the early years and toward the 

end of the ISFSI’s operational period, recognizing that the shipment of the fuel from the reactors 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-4 September 2014 

to the ISFSI might occur over a period of 20 or more years. Shipment of the fuel from the ISFSI 

to the repository would occur over a similar timeframe. The DTS is designed to handle spent 

fuel outside the storage canister (i.e., to move the fuel into a new canister if monitoring identifies 

the need to replace the old canister). The DTS is used on an as-needed basis and would likely 

be built sometime after the ISFSI begins operations and would be used over the life of the 

ISFSI. 

The potential impacts from transportation of spent fuel from an away-from-reactor ISFSI to a 

repository are evaluated in Chapter 6 as part of cumulative impacts. Transportation of spent 

fuel to an away-from-reactor storage facility is evaluated in Section 5.16. 

The NRC does not evaluate the impacts of decommissioning of the away-from-reactor ISFSI 

and DTS in this chapter. The impacts of these activities are considered in the cumulative 

impacts analysis in Chapter 6. 

For the short-term storage timeframe (see Section 1.8.2), the NRC evaluates the impacts of 

continued storage of spent fuel for 60 years beyond the licensed life for operations of a 

reference reactor. The NRC assumes that a repository would become available by the end of 

this 60-year timeframe. 

Short-term storage of spent fuel for 60 years beyond licensed life for operations at an awayfrom-reactor ISFSI includes the following: 

x construction and continued operation of the ISFSI, 

x routine maintenance and monitoring of the ISFSI, and 

x cask handling and transfers. 

For the long-term storage timeframe, the NRC evaluates the impacts of continued storage for 

another 100 years after short-term storage. The NRC assumes that a repository would become 

available by the end of this 100-year timeframe and that the oldest fuel would be transferred to 

the repository first. 

Long-term storage activities include the following: 

x continued operation and routine maintenance and monitoring of the away-from-reactor 

ISFSI, 

x construction and operation of a DTS2, and 

 

2 A licensee would have to request authorization from the NRC to build and operate the DTS, either 

during initial licensing of the ISFSI, or as a later, separate action. As part of its review of such a request, 

the NRC would have to consider any associated environmental impacts under 10 CFR Part 51. 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-5 185(*௅

x one-time replacement of the ISFSI (i.e., replacement of casks and canisters, concrete pads, 

and canister transfer building) and the DTS (see Section 1.8.2). 

For the indefinite storage timeframe, the NRC has also evaluated the environmental 

consequences within each resource area for a scenario assuming a repository does not become 

available, thus requiring indefinite onsite storage. Although the NRC believes that this scenario 

is highly unlikely (see Section 1.2 of this GEIS), impact determinations for indefinite storage and 

fuel handling at an away-from-reactor ISFSI have been made for each resource area. The 

activities associated with indefinite storage are the same as those for the long-term storage 

timeframe, except that they would occur repeatedly due to the lack of a repository. As 

discussed in Chapter 1, the ISFSI (i.e., casks and canisters, concrete pads, and canister 

transfer building) and the DTS would be replaced on a 100-year cycle. 

Sections 5.1 through 5.19 evaluate potential impacts on various resource areas, such as land 

use, air quality, and water quality. Within each resource area, the NRC provides an analysis of 

the potential impacts and an impact determination í SMALL, MODERATE, LARGE í for each 

timeframe. For some resource areas, the impact determination language is specific to the 

authorizing regulation, executive order, or guidance. 

5.1 Land Use 

This section describes land-use impacts caused by the continued storage of spent fuel at an 

away-from-reactor ISFSI. 

5.1.1 Short-Term Storage 

The environmental impacts on land use from the construction and operation of an away-fromreactor storage facility are based on a facility similar to the PFSF (NRC 2001), built at a location 

selected based on the assumptions presented above. The ISFSI would be designed to store up 

to 40,000 MTU of spent fuel on a fenced 330-ha (820-ac) site. Storage pads for the canisters 

and some support facilities would be located on a 40-ha (99-ac) restricted access area within 

the site. 

Construction activities associated with the ISFSI would be limited to the immediate area of the 

ISFSI site and would primarily consist of clearing, excavation, and grading of the 40-ha (99-ac) 

restricted access area where the storage pads and major buildings would be located. In 

addition, one or more access roads and a rail spur would likely have to be either built or 

improved. Based on its past experience and judgment, the NRC assumes that (1) disturbed 

areas around the ISFSI site and associated corridors would be graded and reseeded after 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-6 September 2014 

construction is completed, (2) permits3 would require best management practices (BMPs) such 

as construction of flood diversion berms to control erosion and the installation of silt fencing and 

sediments traps to stabilize disturbed soils to reduce land-use impacts, and (3) the 40-ha 

(99-ac) restricted access area would be enclosed with chain-link security fencing. For the 

PFSF, the total amount of land disturbed for construction, including the access road and rail 

line, was 408 ha (1,008 ac) and the rail line represented more than three-quarters of the land 

GLVWXUEHG2IWKHODQGGLVWXUEHGKDDFZDVWREHUHYHJHWDWHGDIWHUFRQVWUXFWLRQDQG

120 ha (295 ac) was expected to remain cleared; the rail line represented more than half of that 

value (NRC 2001). Although these numbers are specific to the PFSF analysis, based on the 

assumptions presented in the introduction to this chapter, they provide a reasonable 

representation of the amount of land disturbance that could be expected at another location 

because the rail line was fairly long at 51 km (32 mi). 

Construction of any proposed ISFSI would change the nature of land use within the site 

boundary and along the access corridors. While this change would be qualitatively substantial 

(e.g., from agricultural to industrial), the land parcel is assumed to be sufficiently remote and 

relatively small (compared, for example, to any surrounding county) so that no quantitatively 

significant impact would occur. By way of comparison, for the proposed Levy Nuclear Plant, the 

NRC concluded that the land-use impacts for the plant (not including transmission lines) “would 

not noticeably alter the existing land uses within the vicinity and region.” The Levy project (not 

including transmission lines) would have affected just over 405 ha (1,000 ac) (NRC 2012). 

Operation of any proposed ISFSI would involve transportation of spent fuel from reactors to the 

ISFSI and receiving, transferring, and storing the spent fuel. Impacts on land use during ISFSI 

operations would create no additional impacts on land use beyond those for the construction of 

the facility. This generic analysis and associated findings are consistent with the findings for the 

PFSF (NRC 2001). 

Based on its review, the NRC concludes that the impacts on land use from the construction and 

operation of an away-from-reactor ISFSI would be SMALL. This is because the land parcel for 

the ISFSI is assumed to be remote and relatively small. 

5.1.2 Long-Term Storage 

As discussed in the introduction to this chapter, the NRC assumes that a DTS is constructed as 

part of an away-from-reactor ISFSI. The NRC also assumes that the DTS will be built inside the 

confines of the ISFSI’s 40-ha (99-ac) restricted area—a reasonable assumption considering the 

small area (0.04 ha [0.1 DF@UHTXLUHGIRUWKH'76EDVHPDWDQGKDDFIRUWKH'76

security zone. The DTS would be used to facilitate transfer of the spent fuel canister from one 

 

3 For example, the licensee of each site would have to obtain a National Pollutant Discharge Elimination 

System permit that would include requirements to minimize the impacts of stormwater runoff. 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5- 185(*௅

cask to another, retrieve and repackage spent fuel, or replace damaged canisters or casks 

identified during visual inspections. Construction and operation of a DTS at an away-fromreactor ISFSI would be based on Section 2.1.4 of this GEIS. 

By comparison, the canister transfer building at the PFSF would have been a fully enclosed 

high-bay building equipped with cask transfer and handling equipment (e.g., overhead and 

gantry cranes) and radiation-shielded transfer cells for transferring the spent fuel canisters from 

transportation packages to the storage casks (NRC 2001). The building would have occupied 

about 0.5 ha (1.2 ac) within the 40-ha (99-ac) restricted access area where the storage pads, 

major buildings, and access roads would have been located (NRC 2001). It is possible such a 

building would be equipped or could be retrofitted with the necessary equipment for retrieval 

and repackaging of spent fuel. However, for the purposes of the analysis in this GEIS, the NRC 

assumes that a separate DTS will be constructed. 

The NRC assumes that construction of a DTS would take 1 to 2 years based on a construction 

schedule similar to that for the canister transfer building at the PFSF, which was estimated to 

take approximately 18 months (NRC 2001). Construction equipment would be used to grade 

and level the DTS site and excavate the facility foundation. Construction of the DTS structures 

would disturb about 0.04 ha (0.1 ac) of land. In addition, the NRC expects that land adjacent to 

a DTS would be disturbed for a construction laydown area. Based on its past experience and 

judgment, the NRC assumes that after the construction of the DTS is completed (i.e., about 1 to 

2 years), the construction laydown area would be reclaimed and revegetated. The DTS would 

be built within an area for which access is already restricted, and it would represent a small 

increase in the amount of land that is disturbed within that restricted area. 

The NRC also assumes that aging management would require the replacement of an awayfrom-reactor ISFSI and DTS (i.e., the concrete storage casks and concrete storage pads, and 

canister transfer building) during the long-term timeframe. Replacement facilities would be 

constructed on land near the existing facilities. The old facilities would be demolished and the 

land reclaimed. Regardless, this land would be inside the 40-ha (99-ac) restricted area and it 

would be unavailable for other uses for as long as the ISFSI exists. 

In conclusion, construction of a DTS would disturb a small portion of the land committed for an 

away-from-reactor ISFSI. Operational impacts would include continuing to restrict access to the 

facility site and use of the site for spent fuel transfer, handling, repackaging, and aging 

management activities. To minimize land-use impacts from replacing storage casks, storage 

pads, the canister transfer building, and the DTS, replacement facilities would likely be 

constructed on land near the existing facilities. Therefore, the NRC concludes that the impact 

on land use from long-term storage of spent fuel at an away-from-reactor ISFSI would be 

SMALL. 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-8 September 2014 

5.1.3 Indefinite Storage 

This section describes the potential environmental impacts on land use if a repository is not 

available to accept spent fuel. For this analysis, the NRC assumes that spent fuel would 

continue to be stored at an away-from-reactor ISFSI indefinitely. 

The environmental impacts on land use from continued operation of dry cask storage of spent 

fuel at an away-from-reactor ISFSI if a repository is not available would be similar to those 

described in Section 5.1.2. All operations and maintenance activities would occur inside the 

40-ha (99-ac) restricted area, which would remain unavailable for other uses for as long as the 

ISFSI exists. These activities would occur repeatedly because the spent fuel would remain at 

the facility indefinitely. 

In conclusion, continued storage of spent fuel in an away-from-reactor ISFSI indefinitely (i.e., if a 

repository is not available) would affect only a small portion of the total land area developed for 

the storage facility and would not change land-use conditions. Therefore, the NRC concludes 

that the environmental impacts on land use from indefinite storage of spent fuel at an awayfrom-reactor ISFSI would be SMALL. 

5.2 Socioeconomics 

This section describes socioeconomic impacts caused by the continued storage of spent fuel at 

an away-from-reactor ISFSI. Several types of impacts could occur, including impacts on 

economy, housing, and public services. 

As discussed in Section 5.0, should the NRC receive an application for a proposed away-fromreactor ISFSI, the NRC would evaluate the site-specific impacts of the construction and 

operation of any proposed facility as part of that facility’s licensing process. This review would 

consider impacts to socioeconomic conditions, including specific concerns attributable to the 

special conditions within a community. 

5.2.1 Short-Term Storage 

Construction activities would be temporary and would occur mainly within the boundaries of the 

ISFSI site. As discussed in the introduction to this chapter, the NRC used the characteristics of 

the PFSF (e.g., land area affected and size of workforce) in its analyses. There would be 

incremental changes to offsite services to support construction activities, such as the 

transportation of construction materials. Most of the construction workforce (255 workers at its 

peak) is expected to come from within the region, and those workers who might relocate to the 

region would represent a small percentage of the surrounding area’s population base. Because 

of the relatively short duration of the construction project, few, if any, of the workers who migrate 

to work at the site would be accompanied by their families. As a result, the impacts on housing 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-9 185(*௅

and public services are expected to be minor. Aside from the direct impacts associated with the 

project, there would also be indirect impacts from jobs created in the area. For example, the 

purchase of goods by workers onsite and in the local community could create additional jobs. 

However, unlike jobs associated directly with the construction of the ISFSI, indirect jobs are 

more likely to be filled by local residents. Given the small number of construction workers, there 

would not be a noticeable increase in the demand for housing and public services. The 

economic impact on the local and regional economy would be minor. 

During ISFSI operation, employees would continue to maintain, monitor, and inspect the facility. 

The NRC estimates that the number of operations workers would be around 43 based on the 

PFSF environmental impact statement (EIS) (NRC 2001). In contrast to construction, for which 

workers may or may not relocate, workers employed for the operation of the storage facility, if 

they were not from the local area, would be expected to move into the area with their families. 

Given the small number of operations workers, there would not be a noticeable increase in the 

demand for housing and public services. The impacts on the local and regional economy would 

be minor. 

Local and State government agencies would receive tax payments from the ISFSI licensee. 

The impact of the payments would depend on a number of factors, including the pre-existing 

economic conditions. If the local jurisdiction(s) already have a substantial tax base, then the 

addition of taxes from the ISFSI would have a minor beneficial impact. But if the pre-existing 

local tax base was small, then the new tax revenue could have a significant beneficial impact. 

For the PFSF, the NRC concluded that there would be a large impact on the Skull Valley Band 

and on Tooele County from the payments made by PFS (NRC 2001). Based on the assumption 

that any away-from-reactor ISFSI would be built in an area with low population density, the NRC 

concludes that the increase in tax revenue could have a significant beneficial impact on the local 

economy, but the beneficial impacts beyond the host jurisdiction would be minor. 

In the PFSF EIS, the NRC concluded that construction and operation of an away-from-reactor 

ISFSI would have a SMALL socioeconomic impact (NRC 2001). Considering the very sparse 

population around the PFS site (30 persons on the Reservation and a total of about 150 

persons in all of Skull Valley), the NRC concludes that the socioeconomic impacts at any site of 

constructing and operating an away-from-reactor ISFSI would be similar to those described in 

the PFSF EIS. Based on the analysis above, construction and operation of an away-fromreactor ISFSI could generate potentially LARGE beneficial economic impacts in some rural 

economies as well as SMALL adverse socioeconomic impacts due to increased demand for 

housing and public services. 

5.2.2 Long-Term Storage 

A DTS constructed as part of an away-from-reactor ISFSI would be used to facilitate the 

replacement of spent fuel canisters as part of aging management practices. The construction of 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-10 September 2014 

the DTS would require a workforce smaller than that required for construction of an away-fromreactor ISFSI. Similar to the construction of the ISFSI, the workers would come from a 

combination of the existing workforce or commute into the area from surrounding communities, 

but workers would be unlikely to move into the area for DTS construction due to the short 

duration of the project. Therefore, the impacts from the construction of the DTS are bounded by 

those associated with the construction of the ISFSI discussed in Section 5.2.1. 

A staged approach to aging management would require the replacement of an away-fromreactor ISFSI (i.e., the concrete storage casks, concrete storage pads, and canister transfer 

building) and replacement of the DTS during the long-term storage timeframe. The workforce 

required for the replacement of these structures and components would be similar to or less 

than the workforce required for the original construction of the ISFSI, depending on how the 

work is spread out over time. Therefore, the socioeconomic impacts of these workers would be 

similar to or less than the impacts of the original construction of the ISFSI. In addition, the 

operational and maintenance activities begun during the short-term timeframe would continue, 

as would the tax payments to local jurisdictions. 

As discussed above, the impacts from long-term operation and maintenance of the ISFSI are 

bounded by those described in Section 5.2.1. Therefore, the NRC concludes the 

socioeconomic impacts on public services and housing from continued storage during the longterm timeframe would be SMALL. Beneficial impacts from property-tax payments could be 

LARGE in some rural economies. 

5.2.3 Indefinite Storage 

This section evaluates the socioeconomic impacts of away-from-reactor storage assuming a 

repository does not become available. The same operations and maintenance activities 

described in Section 5.2.2 occur repeatedly because the spent fuel remains at the facility 

indefinitely. Therefore, the NRC concludes that the socioeconomic impacts on public services 

and housing during the indefinite timeframe would be SMALL. Beneficial impacts from propertytax payments could be LARGE in some rural economies. 

5.3 Environmental Justice 

This section describes the potential human health and environmental effects on minority and 

low-income populations caused by the continued storage of spent fuel at an away-from-reactor 

ISFSI. See Sections 3.3 and 4.3 for discussion of the approach the NRC uses to evaluate 

issues related to environmental justice. The discussion in both sections is also applicable to the 

consideration of environmental justice for an away-from-reactor ISFSI. As explained in Section 

4.3, the NRC strives to identify and consider environmental justice issues in agency licensing 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-11 185(*௅

and regulatory actions primarily by fulfilling its National Environmental Policy Act of 1969, as 

amended (NEPA) responsibilities for these actions. 

In most cases, the NRC environmental justice analyses are limited to evaluating the human 

health effects of the proposed licensing action and the potential for minority and low-income 

populations to be disproportionately affected. As explained in the Commission’s policy 

statement, issues related to environmental justice and demographic conditions (i.e., the 

presence of potentially affected minority and low-income populations) differ from site to site, and 

environmental justice issues and concerns usually cannot be resolved generically. In sitespecific licensing actions, the NRC addresses environmental justice issues and concerns during 

environmental reviews by identifying potentially affected minority and low-income populations. 

Then, the NRC determines whether there would be any potential human health or 

environmental effects and whether these effects may be disproportionately high and adverse. 

Human health and environmental effects are defined in Section 3.3. Consequently, 

environmental justice, as well as other socioeconomic issues, is normally considered in sitespecific environmental reviews (69 FR 52040). However, the NRC has determined that for the 

purposes of this GEIS a generic analysis of the human health and environmental effects of 

continued storage from the construction and operation of an away-from-reactor ISFSI on 

minority and low-income populations is possible. In addition, should the NRC receive an 

application for a proposed away-from-reactor ISFSI, a site-specific NEPA analysis would be 

conducted which would include consideration of environmental justice. 

As previously stated in Chapters 2 and 3, this GEIS and the Rule are not licensing actions and 

do not authorize the continued storage of spent fuel. The environmental analysis in this GEIS 

fulfills a small part of the NRC’s NEPA obligation with respect to the licensing or relicensing of 

an away-from-reactor ISFSI. Further, for site-specific licenses, the NEPA analysis would 

include consideration of environmental justice prior to any NRC licensing action. As with other 

resource areas, this site-specific analysis allows the NRC to make an impact determination for 

each NRC licensing action. For the purposes of this GEIS, a generic determination of the 

human health and environmental effects during continued storage at an away-from-reactor 

ISFSI is possible because the NRC understands how such a facility will be sited. 

5.3.1 Short-Term Storage 

The construction and short-term operation of an away-from-reactor ISFSI could raise 

environmental justice concerns. Should the NRC receive an application for a proposed awayfrom-reactor ISFSI, a site-specific NEPA analysis would be conducted, and this analysis would 

include consideration of environmental justice impacts per the Commission’s policy statement. 

During the environmental review for a proposed site-specific away-from-reactor ISFSI, the NRC 

would collect demographic information about nearby minority and low-income populations and 

any special characteristics (e.g., subsistence fishing) of those populations. The NRC would 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-12 September 2014 

collect this information to evaluate the potential for disproportionately high and adverse human 

health and environmental effects on those populations. During the PFSF review, the NRC 

concluded that “no disproportionately high and adverse impacts will occur to the Skull Valley 

Band or to minority and low-income populations living near the proposed rail routes from the 

proposed action” (NRC 2001). 

For the analysis in this GEIS, it is not possible to define the characteristics of minority or lowincome populations around a potential away-from-reactor ISFSI and associated transportation 

corridors. However, environmental justice would be one of the factors considered in the siting 

and licensing of any ISFSI. Using past licensing experience as an indicator, disproportionately 

high and adverse impacts on minority or low-income populations could be avoided through the 

siting process. If impacts were determined to be disproportionately high and adverse, the 

facility could be relocated or plans modified to mitigate any adverse effects. For example, the 

Louisiana Energy Services facility was originally proposed for a location in Louisiana. However, 

the applicant eventually decided to withdraw its application (LES 1998, NRC 1998) and select a 

different site for its facility. A key outstanding issue for the project was an environmental justice 

concern identified during the licensing review. 

Potential impacts to minority and low-income populations from the construction and operation of 

an away-from-reactor ISFSI would mostly consist of environmental and socioeconomic effects 

(e.g., noise, dust, traffic, employment, and housing impacts). Noise and dust impacts from 

construction would be short-term and primarily limited to onsite activities. Minority and lowincome populations residing along site access roads would be affected by increased commuter 

vehicle traffic during shift changes and truck traffic. However, these effects would be temporary 

during certain hours of the day and would not likely be high and adverse. Increased demand for 

rental housing during construction could disproportionately affect low-income populations. 

However, construction workers could commute to the site, thereby reducing the potential 

demand for rental housing. 

Regarding visual impacts, the NRC expects the canister transfer building to be the largest 

building on the site. For the PFSF, this building would have been approximately 60 m (200 ft) 

ZLGHPIWORQJDQGPIWKLJK15&8VLQJWKH 330-ha (820-ac) site area 

for the PFSF as a guide, the site boundary would be approximately 0.8 km (0.5 mi) from the 

facility. At this distance the NRC concludes that visual impacts on nearby residents would be 

minimal. Depending on the location of minority or low-income populations, these populations 

could experience an adverse impact. As stated in Section 5.14, impacts could range from 

SMALL to MODERATE. However, impacts are not expected to be disproportionately high and 

adverse. 

As discussed in Section 5.12, in most instances, placement of facilities on a proposed site could 

be adjusted to minimize or avoid impacts on historic and cultural resources in the area, but the 

NRC recognizes that this is not always possible. The magnitude of adverse effects on historic 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-13 185(*௅

properties and impacts on historic and cultural resources largely depends on where the facilities 

are sited, what resources are present, the extent of proposed land disturbance, and if the 

licensee has management plans and procedures that are protective of historic and cultural 

resources. The NRC’s site-specific environmental review and compliance with the National 

Historic Preservation Act (NHPA) process could identify historic properties, adverse effects, and 

potentially resolve adverse effects on historic properties and impacts on other historic and 

cultural resources. As discussed in Section 3.3, a disproportionately high and adverse 

environmental impact refers to an impact or risk of an impact on the natural or physical 

environment in a low-income or minority community that appreciably exceeds the environmental 

impact on the larger community. In assessing cultural environmental impacts, impacts that 

uniquely affect minority or low-income populations or American Indian tribes are also 

considered. Thus, the potential impacts on historic and cultural resources could be SMALL to 

LARGE depending on site-specific factors. 

Regarding noise, in Section 5.13 the NRC concludes that impacts near the site could exceed 

U.S. Environmental Protection Agency (EPA)-recommended levels at times during construction 

and operations. If minority or low-income populations are located near the site boundary or 

transportation routes, they could be disproportionately affected; although the NRC concluded in 

Section 5.13 that the overall noise impacts could be SMALL. Therefore, the NRC does not 

expect that these impacts would be disproportionately high and adverse. 

Radiation doses to surrounding populations would be maintained within regulatory limits (as 

provided in 10 CFR Part 20), ensuring minor impacts. In addition, the licensee is required by 

10 &)5GWRLPSOHPHQWDQHQYLURQPHQWDOPRQLWRULQJSURJUDPWRHQVXUHFRPSOLDQFH

with effluent limitations. Based on a review of recent radiological environmental monitoring 

program reports, human health impacts would not be expected in special pathway receptor 

populations living near a nuclear power plant as a result of subsistence consumption of water, 

local food, fish, or wildlife during continued storage of spent fuel. Unlike the operation of nuclear 

reactors, the operation of the ISFSI is not expected to have any routine radiological effluents. 

Therefore, the results for reactors bound the results for the away-from-reactor ISFSI, and the 

NRC concludes that there would not be any disproportionately high and adverse radiological 

human health or environmental impacts on any minority or low-income populations in the area. 

Siting of an away-from-reactor ISFSI would be expected to ensure that environmental justice 

concerns are addressed prior to licensing. As discussed for the other resource areas, overall 

human health and environmental effects from construction and from the continued storage of 

spent fuel during the short-term timeframe would be limited in scope and SMALL for all 

populations, except for air quality, terrestrial resources, aesthetics, historic and cultural 

resources, and socioeconomic and traffic conditions. Short-term storage impacts to each of the 

affected resource areas are discussed elsewhere in this chapter. Based on this information and 

the analysis of human health and environmental impacts discussed for other resource areas in 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-14 September 2014 

this chapter, minority and low-income populations are not expected to experience 

disproportionately high and adverse human health or environmental effects from the 

construction and operation of an away-from-reactor ISFSI during the short-term timeframe. 

5.3.2 Long-Term Storage 

The construction of a DTS would occur within the facility boundaries. NRC authorization to 

construct and operate a DTS and replace the ISFSI and DTS would constitute Federal actions 

under the NEPA and would be addressed through site-specific reviews that would include an 

analysis of the potential human health and environmental effects on minority and low-income 

populations. The environmental review for the DTS would not rely on the analysis in this GEIS, 

because the site-specific NEPA analysis would consider the site-specific impacts on minority 

and low-income populations. 

Impacts from construction of the DTS would include the potential for an increase in labor 

demand similar to that described under the initial construction of the away-from-reactor facility, 

although on a somewhat smaller scale (60 to 80 workers, see Sections 4.2.2 and 4.3.2). The 

activities associated with building an away-from-reactor ISFSI are described in the PFSF EIS 

(NRC 2001). Because building the DTS is a much smaller project and would occur within the 

ISFSI protected area, the description from the PFSF EIS activities bound the activities 

necessary to build the DTS. Therefore, the NRC concludes that the impacts from construction 

of the DTS would be bounded by the impacts from the construction of the away-from-reactor 

ISFSI, as discussed in Section 5.3.1. 

Aging management would include continued monitoring, maintenance, and a staged approach 

to replacement of ISFSI facilities and components (i.e., casks, pads, and canister transfer 

building) and the DTS. Activities associated with aging management are described in 

Sections 4.1.2, 4.15.2, and 5.1.2. These activities would occur over the duration of operation 

and be contained within the restricted area of the ISFSI. In addition, the dose at the site 

boundary would decrease over time because of the decay of the radioactive materials in 

storage. 

As discussed for the other resource areas, overall human health and environmental effects from 

continued storage during the long-term timeframe would be limited in scope and SMALL for all 

populations, except for aesthetics, historic and cultural resources, socioeconomic, and traffic 

conditions. Long-term storage impacts to each of the affected resource areas are discussed 

elsewhere in this chapter. Due to the passive nature of operations, the temporary nature of any 

construction associated with the DTS and replacement of the ISFSI and the DTS, and based on 

the analysis in Section 5.3.1, the NRC concludes that minority and low-income populations are 

not expected to experience disproportionately high and adverse human health and 

environmental effects from continued storage during the long-term timeframe. 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-15 185(*௅

5.3.3 Indefinite Storage 

The human health and environmental effects on minority and low-income populations from 

continued storage during the indefinite timeframe would be the same as the impacts for longterm storage, as described in Section 5.3.2, except for nonradioactive waste generation and 

disposal. Indefinite storage impacts associated with nonradioactive waste are summarized later 

in this chapter. The only difference is that the activities required for maintenance and 

replacement of the ISFSI and the DTS would be repeated indefinitely. Therefore, the NRC 

concludes that minority and low-income populations are not expected to experience 

disproportionately high and adverse human health and environmental effects during the 

indefinite storage timeframe. 

5.4 Air Quality 

This section describes air quality impacts caused by the continued storage of spent fuel at an 

away-from-reactor ISFSI. See Section 3.4.3 for additional information regarding air quality 

standards. 

5.4.1 Short-Term Storage 

For the purposes of its analysis of air quality impacts in this GEIS, the NRC will use the 

information regarding the emissions from construction and operations activities at the PFSF 

(e.g., construction vehicles, land disturbance, fuel receipt, and routine maintenance and 

monitoring), because they would be representative of the activities and air emission levels of a 

similar away-from-reactor ISFSI, regardless of location. In the PFSF EIS (NRC 2001), the NRC 

examined air quality impacts related to construction and operation of an away-from-reactor 

ISFSI with a capacity of 40,000 MTU, as well as the construction of a rail spur to transport spent 

fuel to and from the ISFSI, located in a National Ambient Air Quality Standards attainment area. 

Fugitive dust would have the greatest influence on air quality during construction. As stated in 

the PFSF EIS, the magnitude of the impact depends in part on the proximity to receptors. For 

the construction analysis for the onsite facilities the PFSF EIS concluded that the impacts were 

SMALL. Atmospheric concentrations of particulate matter with an aerodynamic diameter of 

10 microns or less (PM10) were modeled between 1.1 NPPLIURPWKHFHQWHURIWKH

proposed facility (i.e., the distance to the nearest publicly owned land) and 3.5 km (2.2 mi) from 

the center of the proposed facility (i.e., the distance to the nearest residence). Emissions from 

vehicles were also considered. A maximum of ten equipment operators were expected to be 

onsite at any one time, and emissions from construction-related equipment were expected to be 

small. However, due to the large extent of the disturbed area, fugitive dust emitted from 

excavation and earthwork could lead to local increases in particulate matter concentrations. 

In its analysis for the PFSF, the NRC made conservative assumptions including the following: 

x The entLUHVLWHDUHDRIKDDFZRXOGXQGHUJRKHDY\FRQVWUXFWLRQDWWKHVDPHWLPH
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-16 September 2014 

x Construction was assumed to occur continuously during a 9-hour shift (8 a.m. to 5 p.m. 

each day). 

x Background sources of dust from within a 50-km (32-mi) radius of the site were added to the 

construction-related dust. 

x No mitigation was assumed as a result of natural obstructions (e.g., mountains) that exist 

between background sources and the PFSF site. 

Even when the construction was assumed to be as intensive as that assumed for the PFSF, the 

modeled concentrations of particulate matter from PFSF construction activities were below the 

regulatory standards associated with the allowable increases in emission levels for individual 

projects (i.e., Prevention of Significant Deterioration Class II limits under the Clean Air Act). 

For the rail-spur construction analysis, the PFSF EIS concluded that the temporary and 

localized effects of fugitive dust could produce MODERATE impacts in the immediate vicinity 

where the rail spur and Interstate 80 were near each other and SMALL impacts elsewhere. 

Atmospheric concentrations of PM10 were modeled for a total area of 5 ha (12.4 ac) where the 

rail line ran approximately parallel to Interstate 80 and the rail spur was as close as 50 m 

(164 ft) to the highway. Dust levels were noticeable, and dust control mitigation measures 

(e.g., surface wetting) were included to ensure compliance with National Ambient Air Quality 

Standards. 

For an away-from-reactor ISFSI, the NRC assumes that, if necessary, any site-specific permits 

would include appropriate mitigation to ensure that impacts would not be destabilizing to local 

air quality. An applicant would also have to comply with the requirements of the General 

&RQIRUPLW\5XOH6HFWLRQRIWKH&OHDQ$LU$ct) if the area in which the ISFSI is to be built 

has not met the National Ambient Air Quality Standards. Thus, the Clean Air Act permitting 

process provides a regulatory mechanism to ensure that particulate concentrations created by 

ISFSI construction would be held below regulatory standards and mitigated as appropriate to 

protect ambient air quality. 

The construction of an away-from-reactor ISFSI of the size assumed by the NRC in the 

introduction to this chapter of the GEIS would generate emissions similar to those evaluated in 

the PFSF EIS because similar activities would have to be carried out at the generic facility. 

Based on the emission levels associated with continued storage, construction impacts would 

depend on the proximity of the receptor to the emission-generating activities. The NRC expects 

that noticeable impacts resulting from the proximity between emission sources and receptors 

would more likely be associated with rail-spur construction rather than ISFSI facility construction 

because of the distance between the ISFSI construction activities and the site boundary. 

Therefore, the NRC concludes that for an area that is in attainment for the National Ambient Air 

Quality Standards, the construction impacts could range from not noticeable to noticeable but 

not destabilizing. 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5- 185(*௅

The NRC also considered how construction-related emissions might affect areas designated by 

the EPA as “maintenance” or “nonattainment” for criteria pollutants.4 Estimated annual 

emissions of criteria pollutants at the PFSF were much lower than de minimis levels described 

in 40 CFR 93.153, “Applicability.” For example, the applicant for the PFSF estimated that 

emissions of nitrogen oxides, a precursor to ozone, would have been less than 10 T/yr 

(PFS 2001). The de minimis level of emissions in even an extreme nonattainment area for 

ozone is 10 T/yr. 

Based on the emission levels discussed above, the NRC concludes that the air quality impacts 

related to construction of an away-from-reactor ISFSI could range from not noticeable to 

noticeable but not destabilizing in any air quality region. Noticeable but not destabilizing 

impacts, if they occur, would be due to fugitive dust emissions in the areas immediately adjacent 

to the rail-spur construction activities. 

As stated in the PFSF EIS (NRC 2001), during operations the PFSF would not have been a 

“major stationary source” of air emissions as defined in 40 CFR 52.21(b). The PFSF analyses 

considered emissions from sources such as space heaters, emergency generators, and a 

concrete batch plant, as well as vehicle emissions, and stated that if the emissions from these 

sources were combined, the total would not be expected to exceed the significance levels for 

Prevention of Significant Deterioration analysis specified in 40 CFR 51.166(b)(23)(i). The PFSF 

EIS concluded that the operations impacts on air quality would be SMALL. The NRC 

determined that the results of this PFSF EIS would be applicable to any away-from-reactor 

ISFSI with a similar 40,000-MTU capacity because the types of emission-generating activities 

and associated emission levels would be similar. Therefore, the NRC concludes that the air 

quality impacts from the operation of the ISFSI would be minor. 

Transportation of spent fuel from reactor sites to the away-from-reactor ISFSI could also 

contribute to air quality impacts. In the PFSF EIS, the NRC stated that the locomotives using 

the rail line would have emitted pollutants in any one area for a very short period before moving 

on. The NRC concluded that the associated air quality impacts would be small (NRC 2001). 

For the analysis of an away-from-reactor ISFSI in this GEIS, the NRC concludes that the basis 

for the PFSF conclusion would be applicable to any ISFSI because the same amount of fuel 

would have to be transported over similar distances. Therefore, the air quality impacts 

associated with the transportation of spent fuel to the site would be minor. 

 

4 The EPA designates an area as “nonattainment” generally based upon air quality monitoring data or 

modeling studies that show the area violates, or contributes to violations of, the national standard. After a 

nonattainment area’s air quality improves so that it is no longer violating or contributing to violations of the 

standard, and the State or Tribe adopts an EPA-approved plan to maintain the standard, the EPA can 

redesignate the area as attainment. These areas are known as “maintenance” areas. See also 

Section 3.4.3. 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-18 September 2014 

Overall, the NRC concludes that the air quality impacts from the construction and short-term 

operation of an away-from-reactor ISFSI would be SMALL to MODERATE. MODERATE 

impacts, if they occur, would be due to fugitive dust emissions in the areas immediately adjacent 

to the rail-spur construction activities. 

5.4.2 Long-Term Storage 

Activities associated with aging management of spent fuel in dry casks (e.g., cask repair, bare 

fuel handling as part of repackaging operations, and replacement of the ISFSI and the DTS) are 

expected to be of relatively short duration and limited extent. These activities are likely to 

involve only a portion of the ISFSI and would likely involve, in any year, only a fraction of the air 

emissions that were associated with initial construction of the ISFSI. Maintenance of the rail 

spur would also occur during long-term storage. As a result, there may be temporary increases 

in levels of fugitive dust from construction and refurbishment activities. But the impacts on air 

quality would be less than those of initial construction because the work would be performed in 

stages over an extended period of time, as needed. 

The NRC assumes that a DTS would have to be constructed and replaced during the long-term 

storage timeframe. However, as discussed in Section 5.1, the DTS is a relatively small facility 

and the air quality impacts associated with its construction would be a fraction of the impacts 

associated with the original construction of the ISFSI. Exhaust from vehicles for commuting 

workers and material transportation would add to levels of hydrocarbons, carbon monoxide, and 

nitrogen oxides. However, these emissions would be less than those during the construction 

period and are not expected to noticeably affect air quality in the region. 

Overall, the NRC concludes that the impacts on air quality would be SMALL for all location 

classifications (i.e., attainment, nonattainment, and maintenance). 

5.4.3 Indefinite Storage 

This section evaluates the air quality impacts of away-from-reactor storage, assuming a 

repository does not become available. The same activities described in Section 5.4.2 would 

occur repeatedly because the spent fuel would remain at the facility indefinitely. Therefore, the 

NRC concludes that the impacts on air quality associated with continuing spent fuel storage for 

an indefinite period would be SMALL for all location classifications (i.e., attainment, 

nonattainment, and maintenance). 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-19 185(*௅

5.5 Climate Change 

In this section, the NRC evaluates the effect of continued storage at an away-from-reactor ISFSI 

on climate change. The NRC’s evaluation of the effects of climate change on the intensity and 

frequency of natural phenomena hazards that may cause spent fuel storage accidents is 

provided in Sections 4.18. 

5.5.1 Short-Term Storage 

The issue of climate change was not specifically addressed in the PFSF EIS. Therefore, for the 

purposes of this GEIS, the NRC assumes that the greenhouse gas emission levels released 

from the construction and operation of a 1,000-MW(e) reference reactor would bound those 

associated with a 40,000-MTU ISFSI (NRC 2013b). Construction and operation of light water 

reactors involves, among other things, substantial earthwork and soil dewatering, concrete 

batch plant operations, making and emplacing many thousands of metric tons of concrete, 

ironworks, lifting and rigging construction materials and equipment, material transportation, 

equipment maintenance, demolition, and workforce transportation. Because these activities are 

of a far greater scale than that for an away-from-reactor ISFSI, the greenhouse gas emission 

levels from the construction and operation of a 1,000-MW(e) reference reactor bound the 

emissions from the construction and operation of an away-from-reactor ISFSI. 

In its “Interim Staff Guidance on Environmental Issues Associated with New Reactors, 

Attachment 1: Staff Guidance for Greenhouse Gas and Climate Change Impacts for New 

Reactor Environmental Impact Statements” (NRC 2013b), the NRC categorized emission levels 

E\SURMHFWSKDVHV7KH15&DVVXPHGD-year construction period, which would generate a 

total of 82,000 MT of carbon dioxide (CO2) equivalent (approximately 12,000 MT/yr). The 

analysis assumed an average workforce of 1,000 workers, which is roughly 4 times the number 

of workers assumed to build the ISFSI. Although the new reactor analysis did not include 

transport of supplies and waste materials, which would also generate greenhouse gases during 

construction, the number of vehicles transporting workers to a new reactor construction site 

vastly exceeds the number of vehicles transporting supplies and materials. Therefore, the 

4:1 ratio between workers at a new reactor construction site and an ISFSI construction site still 

provides a very conservative, bounding calculation of 12,000 MT/yr in greenhouse gas 

emissions, even including the emissions from the transport of supplies and waste materials for 

the ISFSI. For the PFSF, Phase 1 of the construction, which was to encompass the bulk of 

construction, was scheduled for 18 months. Using a conservative estimate of 2 years, 

construction of the ISFSI would lead to greenhouse gas emissions of about 24,000 MT. 

For a reactor during the operations period, the NRC estimated a workforce of 550 and total 

CO2 emissions (including emissions from support equipment) of  MT over 40 years. 

This equates to approximately 8,000 MT/yr (NRC 2013b). Similar to the construction estimate, 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-20 September 2014 

the new reactor analysis did not include transport of supplies and waste materials that would 

also generate greenhouse gases during operations. However, the workforce assumed for the 

reactor is about 10 times the workforce that would be needed for the ISFSI and there is more 

support equipment (e.g., emergency diesel generators) at the reactor as well. Therefore, for the 

purposes of estimating the impacts for the ISFSI, the 8,000 MT/yr produced by an operating 

reference reactor is a conservatively high number. 

Transportation of spent fuel from the reactor sites to the away-from-reactor ISFSI would also 

involve emissions of CO2.

5 A similar issue was considered in the U.S. Department of Energy 

(DOE) EIS for Yucca Mountain (DOE 2002) and DOE’s 2008 Final Supplemental EIS for 

Yucca Mountain (DOE 207KHVH(,6VFRQVLGHUHGWKHWUDQVSRUWDWLRQRI078RI

spent fuel from reactor sites over a 50-year operational period, as opposed to the 40,000 MTU 

assumed by the NRC for the away-from-reactor ISFSI over a 20-year operational period. In its 

2008 Final Supplemental EIS, DOE determined that the movement of the fuel would add less 

than 0.0006 percent to overall national CO2 emissions in 2005. The NRC reviewed the analysis 

performed by DOE and determined that it was generally consistent with NRC and Council on 

Environmental Quality regulations and NRC guidance for completeness and adequacy 

(NRC 2008a). Because the annual amount of spent fuel going to an away-from-reactor ISFSI 

(2,000 MTU/yr based on shipping 40,000 MTU in 20 years) is a factor of 1.4 greater than the 

annual amount considered in the Yucca Mountain EIS (1,400 MTU/yr based on shipping 

 MTU in 50 years) and emissions are proportionate to the amount of fuel shipped, the 

emissions from the transportation of spent fuel from reactors to the away-from-reactor ISFSI 

would be less than double the low proportion (less than 0.0006 percent) of national 

CO2 emissions calculated in the Yucca Mountain Final Supplemental EIS. Because this 

transportation adds only slightly to existing traffic, and because emissions would be dispersed 

over a wide area between the reactor sites and the ISFSI, the NRC concludes that the 

greenhouse gas emissions impacts from the transportation of that spent fuel would be minor. 

The total emissions associated with constructing (2 years at 12,000 MT/yr) and operating the 

facility over the short-term timeframe of 60 years (60 years at 8,000 MT/yr) would be 

504,000 MT; the average emissions rate would be about 8,200 MT/yr. The annual emission 

values for the various phases represent a small percentage of the total U.S. annual emission 

UDWHRIELOOLRQ07&22 equivalent in 2011 (EPA 2013a). To put the annual emissions in 

context, 8,200 MT CO2 equivalent would be approximately equal to the annual emissions from 

1,640 passenger vehicles (EPA 2013b). During the construction period, when emissions are 

higher than the average, the 12,000 MT CO2 equivalent would be approximately equal to the 

annual CO2 equivalent emissions from 2,400 passenger vehicles. 

 

5 As indicated in the introduction to this chapter, the potential impacts from transportation of spent fuel 

from an away-from-reactor ISFSI to a repository are not evaluated in this section. 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-21 185(*௅

The NRC concludes that the relative contribution of an away-from-reactor ISFSI to greenhouse 

gas emission levels would be SMALL. 

5.5.2 Long-Term Storage 

Activities associated with aging management of spent fuel in dry casks (e.g., cask repair, 

construction of the DTS, bare fuel handling as part of repackaging operations, and ISFSI and 

DTS replacement) are expected to be of relatively short duration and limited extent. These 

activities are likely to involve only a portion of the ISFSI, and would likely involve, in any year, 

only a fraction of the greenhouse gas emissions associated with initial construction of the 

storage facilities (see Sections 5.1.2 and 5.4.2). Therefore, the NRC concludes that the relative 

contribution of spent fuel transfer, handling, and aging management activities to greenhouse 

gas emission levels during the long-term timeframe would be SMALL, for the same reasons 

stated in Section 5.5.1. 

5.5.3 Indefinite Storage 

This section describes the environmental impacts on climate change if spent fuel must be stored 

indefinitely. Ongoing transfer, handling, and aging management activities would continue 

indefinitely, the ISFSI and DTS would be replaced, and the spent fuel would be repackaged 

every 100 years. The main difference when compared to the impacts described in 

Sections 5.5.1 and 5.5.2 is that without a repository these activities would occur on an ongoing 

basis over a longer period of time. However, the annual emission levels for the various phases 

would remain the same. 

The NRC concludes that the relative contribution of an away-from-reactor ISFSI to annual 

greenhouse gas emission levels during the indefinite timeframe would be SMALL, the same as 

the emissions discussed in Section 5.5.2. 

5.6 Geology and Soils 

This section describes geology and soils impacts caused by the continued storage of spent fuel 

at an away-from-reactor ISFSI. 

5.6.1 Short-Term Storage 

Construction impacts associated with away-from-reactor storage include earth clearing and 

foundation laying for the ISFSI, both of which may contribute to soil erosion. As discussed in 

the introduction to this chapter, these activities would be similar to those described in the PFSF 

EIS, regardless of the location of the ISFSI. As described in the PFSF EIS, the environmental 

impacts on soils would have included the loss of soils as a result of physical alterations to the 

existing soil profile. These alterations would have led to a reduced availability to support plant 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-22 September 2014 

and animal life and could have led to changes in erosion patterns and characteristics that affect 

how water infiltrates into the soil (NRC 2001). However, in the PFSF EIS, the NRC concluded 

that these losses are a small percentage of the similar available soils in the valley. The NRC 

also noted that soils used in project construction are recoverable upon facility decommissioning, 

and that no excess soils would be generated that require shipment or disposal offsite. Similarly, 

economic geologic resources (such as minerals, oil, and gas, if any) that would be unavailable 

for exploitation during facility construction and operation are widely available elsewhere in the 

region. 

As discussed in Section 5.1, the amount of land committed to the away-from-reactor ISFSI is 

relatively small compared, for example, to the land available in a typical county. The methods 

necessary to control soil erosion are well understood and local permits typically require the 

implementation of erosion controls. Because of the relatively small size of the facility, 

restrictions on access to geologic resources under the ISFSI site would also be minimal. For 

these reasons, the NRC concludes that the impacts on soils and geologic resources from the 

building and short-term operation of an away-from-reactor ISFSI would be SMALL. 

5.6.2 Long-Term Storage 

The NRC expects that the construction of a DTS (see Chapter 2 for further details) will have 

PLQLPDOLPSDFWVRQJHRORJ\DQGVRLOVGXHWRWKHVPDOOVL]HRIWKHIDFLOLW\DERXWKD>DF@IRU

the DTS security zone). The types of impacts on soils would be similar to those anticipated for 

any power plant facility construction. Due to the relatively small size of the DTS, the impacts 

would be limited to the immediate area. Also, any laydown areas associated with construction 

would be reclaimed once the construction phase was complete. 

It is assumed that ISFSI pads and supporting facilities (e.g., canister transfer building) would 

require replacement during the long-term storage timeframe and would occur on land near 

existing facilities. It is not anticipated that the overall land disturbed would increase because the 

old facility location would be demolished and the land would likely be reclaimed. Even if the 

land is not reclaimed, it has no further impact on soils and geologic resources because all of the 

activities would occur inside the 40-ha (99-ac) restricted area. The operations phase of any 

ISFSI is not anticipated to have any additional impacts on soils above those associated with 

construction. 

In general, while the geological characteristics of the site and vicinity are essential to the safe 

design and operation of the ISFSI, continued storage of spent fuel does not have a significant 

environmental impact on geological resources (such as, damage to unstable slopes, adjacent 

utilities, or nearby structures). 

The construction, operation, and replacement of a DTS would have minimal impacts on soils on 

the small fraction of the land committed for the facility. There are no anticipated impacts on the 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-23 185(*௅

geology of an area as the result of either the construction or operation of a DTS. Therefore, the 

NRC concludes that the environmental impact on geology and soils due to transfer, handling, 

and aging management of fuel during the long-term storage timeframe would be SMALL. 

5.6.3 Indefinite Storage 

In this section, the impacts on geology and soils are evaluated for away-from-reactor storage 

assuming a repository does not become available. The same operations and maintenance 

activities described in Section 5.6.2 would occur repeatedly because the spent fuel would 

remain at the facility indefinitely. 

An away-from-reactor storage facility would have no additional impact if a repository is not 

available; therefore, the NRC concludes that the impacts on geology and soils from indefinite 

storage would be SMALL. 

5.7 Surface-Water Quality and Use 

This section describes surface-water quality and use impacts caused by the continued storage 

of spent fuel at an away-from-reactor ISFSI. 

5.7.1 Short-Term Storage 

Construction of an away-from-reactor ISFSI would require modification of the surface drainage 

to accommodate increased locally generated stormwater resulting from land cleared of 

vegetation and the increased area of impervious cover resulting from paved roads, buildings, 

and thick concrete pads on which spent fuel casks would be placed (NRC 2001). The types of 

activities carried out at the ISFSI that could affect surface water would be similar to those 

activities described for the PFSF based on the assumptions presented in the introduction to this 

chapter. 

For the PFSF site, the NRC noted that BMPs would have been used to address stormwater 

flows, soil erosion, and siltation throughout the construction period. The NRC determined that, 

during construction, implementation of BMPs would have resulted in impacts on surface-water 

quality that would have been SMALL. The NRC also determined that, in the unlikely event that 

severe flooding occurred during the construction period (when the ground-disturbing activities 

would have made the soil more mobile), impacts on the surface-water hydrological system 

would have been SMALL to MODERATE. 

The methods necessary to control impacts on surface-water quality during the construction of 

the ISFSI are well understood and local permits typically require the implementation of these 

controls. Stormwater control measures, which would be required to comply with National 

Pollutant Discharge Elimination System (NPDES) permitting, would minimize the flow of 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-24 September 2014 

disturbed soils or other contaminants into surface waterbodies. The licensee could also 

implement BMPs to minimize erosion and sedimentation. The NRC concludes that under 

normal circumstances, the impacts on surface-water quality would be minor. Depending on the 

characteristics of the specific location, unforeseen storm events could cause periods during 

which surface water could be noticeably affected by runoff, erosion, and sediment loads. 

However, these events would be of short duration, after which water quality would return to 

normal. 

During construction, the PFSF would have used from about 102 m3/d (19 gpm) to more than 

520 m3/d (96 gpm) of water (NRC 2001). The water requirements for an away-from-reactor 

ISFSI would be similar because of its similar size. These water requirements could be met by a 

combination of groundwater, surface water, or water delivered to the site (by truck or from a 

local municipal water system). The amount of water required is relatively small. For example, a 

large power plant with cooling towers might consume approximately 54,500 m3/d (10,000 gpm) 

during operations. During the operational period, the away-from-reactor ISFSI would be in a 

passive state and water use would be much lower than during the construction period. The 

PFSF would have used about 6.8 m3/d (1.3 gpm) during operations. Activities would be limited 

to cask emplacement and site maintenance with very little water use. Transportation of the 

spent fuel to the ISFSI would not have any impacts on surface-water use or quality. For these 

reasons, the potential impacts on the surface-water flow system, water availability, and water 

quality during ISFSI operation are generally expected to be minor. 

For construction and operation of the away-from-reactor ISFSI, the NRC concludes that the 

overall impacts on surface-water use and quality would be SMALL. Although there is a 

possibility of noticeable impacts during unusual storm events during construction, such impacts 

would be short-lived before the surface waterbody would return to normal conditions. 

Therefore, even taking into consideration the impact of such unusual storm events, the overall 

impact would be SMALL. 

5.7.2 Long-Term Storage 

The construction and operation of a DTS (see Chapter 2 for further details) is anticipated to 

have minimal impacts on surface-water resources due to the small size of the facility (about 

 ha [2 ac] for the DTS security zone) compared to the ISFSI restricted area (40 ha [99 ac]). 

The construction and operation of a DTS involves very little consumptive use of water, and this 

use would be intermittent. Given the relatively smaller size of the DTS compared to a 

40,000-MTU away-from-reactor ISFSI, much less water would be required to build the DTS than 

would be used to construct the ISFSI. Therefore, the consumptive water use for construction 

and operation of the DTS would be minor. 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-25 185(*௅

With regard to storage facility replacement activities, the consumptive water use would be no 

greater than that identified for initial construction of the facilities, which would have only a minor 

impact on water availability. 

The NRC assumes that the ISFSI and DTS would require replacement during the long-term 

storage timeframe and that replacement structures would be constructed on land near existing 

facilities. It is not anticipated that the overall land disturbed would increase because the old 

facility location would be demolished and the land would likely be reclaimed. This alternating 

location pattern minimizes the total land disturbed, which would limit the flow of disturbed soils 

or other contaminants into surface waterbodies. Based on the preceding analysis, expected 

impacts on surface-ZDWHUUHVRXUFHVZRXOGEHVLPLODUWRWKRVHLQ6HFWLRQ60$//

5.7.3 Indefinite Storage 

If no repository becomes available, away-from-reactor dry cask storage of spent fuel would 

continue indefinitely. As a result, the potential impacts on surface-water resources would be 

VLPLODUWRWKRVHGHVFULEHGLQ6HFWLRQEHFDXVHWKHVDPHRSHUDWLRQDODFWLYLWLHVZRXOGEH

happening at the storage site. Every 100 years, surface water would be needed for demolishing 

and replacing concrete pads and other possibly degraded facilities. This additional consumptive 

use would be temporary. Therefore, the NRC concludes that the potential impacts on surfacewater use and quality if a repository is not available would be SMALL. 

5.8 Groundwater Quality and Use 

This section describes groundwater-quality and -use impacts caused by the continued storage 

of spent fuel at an away-from-reactor ISFSI. 

5.8.1 Short-Term Storage 

Construction of an away-from-reactor ISFSI would require only shallow excavations for the 

concrete pad foundation and all structures for ISFSI facilities would be at or near the ground 

surface. 

The water-use requirements for the away-from-reactor ISFSI would be similar to those for the 

PFSF because of its similar size. This water could be obtained from groundwater sources. For 

the PFSF site, the NRC noted that water use during construction would have varied from about 

102 m3/d (19 gpm) to more than 520 m3GJSP15&DVGLVFXVVHGLQ6HFWLRQ.1. 

For an away-from-reactor ISFSI, these water requirements could be met by a combination of 

groundwater, surface water, or water delivered to the site (by truck or from a local municipal 

water system). The amount of water required is relatively small. For example, a large power 

plant with cooling towers might consume approximately 54,500 m3/d (10,000 gpm) during 

operations. In the PFSF EIS (NRC 2001), the NRC determined that environmental impacts from 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-26 September 2014 

consumptive use of groundwater during construction of the proposed facility would have been 

SMALL. Because of the relatively small amount of consumptive water use and the ability to 

obtain water from multiple sources, the NRC concludes that the impacts of consumptive use of 

groundwater for an away-from-reactor ISFSI would be minor. 

Potential impacts on groundwater quality would be expected to originate through seepage from 

ground-surface features, such as contaminants in runoff from the concrete pad surfaces and 

overlying surface waterbodies. The potential impacts on groundwater quality from an awayfrom-reactor ISFSI would depend on local conditions. The methods to control impacts on 

groundwater quality are well understood and local permits typically require the implementation 

of these controls. Under these permits, licensees would be required to implement BMPs to 

mitigate any potential impacts on groundwater from fuels and other ground-surface 

contaminants. For this reason, the NRC concludes that the impacts on groundwater quality 

would be minor. By way of comparison, the impacts on groundwater quality from the PFSF 

construction were determined by the NRC to be SMALL, given the depth to groundwater (about 

38 m [125 ft]) and mitigation afforded by the PFS BMP plan. Groundwater-quality impacts 

during PFSF operation were also deemed to be SMALL. This finding included consideration of 

operation of a surface-water detention basin, two planned septic systems with leach fields, and 

storage of onsite vehicle fuel. 

Transportation of the spent fuel to the ISFSI would not have any impacts on groundwater use or 

quality. 

Based on the considerations discussed above, the NRC concludes that the impacts on 

groundwater use and quality from construction and short-term operation of the away-fromreactor ISFSI would be SMALL. 

5.8.2 Long-Term Storage 

To accomplish spent fuel repackaging into new canisters, the NRC assumes that a DTS would 

be required, as described in Chapter 2. The environmental impacts on groundwater from 

constructing a DTS would be smaller than those considered for construction of the away-fromreactor ISFSI (Section 5.8.1) because of the small area of land affected. Likewise, the impacts 

of replacing the ISFSI and the DTS over time would be no more than the impacts of the initial 

construction of the facility because they involve similar activities and would likely occur over a 

longer period of time. As a result, the NRC concludes that the impacts on groundwater use and 

quality of long-term storage of spent fuel would be SMALL. 

5.8.3 Indefinite Storage 

If a repository does not become available, then activities described in Section 5.8.2 would 

continue indefinitely, including replacement of the ISFSI and DTS every 100 years. The 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5- 185(*௅

potential environmental impacts on groundwater would be similar to those discussed in Section 

5.8.2. Therefore, the NRC concludes that the potential environmental impacts on groundwater 

use and quality due to indefinite storage of spent fuel at an away-from-reactor ISFSI would be 

SMALL. 

5.9 Terrestrial Resources 

This section describes terrestrial resource impacts caused by the continued storage of spent 

fuel at an away-from-reactor ISFSI. 

5.9.1 Short-Term Storage 

Construction of an away-from-reactor ISFSI that would affect terrestrial ecology involve land 

clearing, grading, and building facilities, including access roads and a rail spur. During 

construction of an away-from-reactor dry cask storage facility, vegetation would be most 

affected by the direct removal of trees, plants, shrubs, and grasses and by replacing some of 

the cleared land with structures and ancillary facilities, including access roads. These removal 

activities could result, to varying degrees, in reduction of available wildlife habitat and food; 

modification of existing vegetative communities; and potential establishment or spread of 

invasive plant species. Parts of the disturbed areas would be replanted with some mixture of 

native and non-native plant species. Terrestrial wildlife would be most affected by habitat loss 

or alteration, displacement of wildlife, and incremental habitat fragmentation, all of which can 

lead to direct and indirect mortalities. However, in general, most wildlife would disperse from 

the project area when construction activities begin nearby and may recolonize in adjacent, 

undisturbed areas. In addition, wildlife could be disturbed by noise from construction equipment 

and vehicle traffic. Collisions with vehicles could be responsible for direct mortality of both large 

and small animals. 

The NRC evaluated site-specific construction impacts on terrestrial ecological resources from 

an away-from-reactor dry storage facility as part of the PFSF EIS (NRC 2001). Based on the 

assumptions presented in the introduction to this chapter, land-disturbing activities for an awayfrom-reactor ISFSI would be of a similar magnitude. For the PFSF, the NRC evaluated the 

FOHDULQJRIKDDFIRUWKHPDLQIDFLOLW\DQGDFFHVVURDGRIZKLFKKDDFZHUHWR

EHUHYHJHWDWHGDIWHUFRQVWUXFWLRQDQGKDDFZHUHWRUHPDLQFOHDUHGIRUWKHOLIHRIWKH

project. The PFSF also required the addition of a 51-km (32-mi) rail line that involved the 

FOHDULQJRIKDDFRIZKLFKKDDFZHUHWREHUHYHJHWDWHGDIWHUFRQVWUXFWLRQ

and 63 ha (155 ac) were to remain cleared for the life of the project (NRC 2001). The proposed 

PFSF, located in an arid, shrub-saltbush vegetation community, was expected to store as many 

as 4,000 canisters in individual storage casks to store a maximum of 40,000 MTU of spent fuel. 

The PFSF had drainages in the area that were ephemeral. However, no wetlands were on or 

near the proposed PFSF, and there would have been no direct impacts on wetlands from 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-28 September 2014 

construction (NRC 2001). It is likely that an away-from-reactor storage facility would also be 

located in an area away from sensitive perennial and wetland habitats to satisfy laws such as 

the Endangered Species Act (ESA) and the Clean Water Act (for wetlands). However, in some 

locations sensitive terrestrial features may be unavoidably affected. 

The NRC concluded that the direct impact on vegetation from clearing vegetation and disrupting 

the ground surface from the proposed PFSF would have been SMALL because no unique 

habitats occur in the proposed project area (NRC 2001). The NRC further concluded that 

vegetation removal impacts that reduce habitat, alter prey-predator relationships, and force 

animals to leave the area would have been SMALL. The NRC also concluded that indirect 

impacts from the proposed PFSF, including surface-water runoff from impermeable surfaces, 

restricting large animal movement, construction noise, introduction on non-native plant species, 

groundwater withdrawal effects on vegetation, and ground and vegetation disturbances from 

trucks and associated fugitive dust, would also have been SMALL (NRC 2001). 

For an away-from-reactor ISFSI at a different location, the impacts on terrestrial resources could 

be different from those at the PFSF. However, certain factors tend to limit the impacts, including 

the following: 

x The land area permanently disturbed is relatively small. 

x Any impacts on wetlands must be addressed under the Clean Water Act and, if wetlands are 

present, the applicant must demonstrate that the proposed action is the least 

environmentally damaging practicable alternative. 

Even considering these factors, it is possible that the construction of the project could have 

some noticeable, but not destabilizing, impacts on terrestrial resources, depending on what 

resources are affected, as demonstrated by other environmental reviews the NRC has 

performed (e.g., reviews for new reactors). Given the passive nature of ISFSI operations, 

impacts on terrestrial resources from such operations (e.g., reduced available habitat, reduced 

mobility of terrestrial animals, and increased noise, light, and traffic) would be much less than 

the impacts of construction and would be minimal. Transportation of the spent fuel to the ISFSI 

would have little or no impacts on terrestrial resources. Therefore, the NRC concludes that, 

depending on the characteristics of the particular site, the impacts on terrestrial resources could 

range from SMALL to MODERATE, based primarily on the potential impacts of construction 

activities. 

5.9.2 Long-Term Storage 

As described previously in Section 5.1.2, the NRC assumes that a DTS would be constructed as 

part of an away-from-reactor ISFSI. This facility would be used to facilitate repackaging of 

spent fuel or replacement of damaged canisters or casks identified during visual inspections or 

aging management activities. Construction of a DTS is anticipated to last about 2 years (see 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-29 185(*௅

Section 5.1.2), and only a small portion of the land committed for an away-from-reactor ISFSI is 

required to construct and operate a DTS. 

The NRC assumes that because only a small portion of the land committed for an away-fromreactor ISFSI is required to construct and operate a DTS, the impacts from construction and 

operation of a DTS on terrestrial resources would be significantly less than those from 

construction and operation of an away-from-reactor ISFSI. The DTS could be sited on 

previously disturbed ground, probably away from sensitive terrestrial features, due to the 

relatively small land area affected for a DTS security zone (about 2 ac). 

Operational impacts would include reduced available habitat and mobility of terrestrial animals 

and increased noise, light, and traffic. Maintenance activities would include inspections and 

testing of the spent fuel and cask transfer and handling equipment and process and effluent 

radiation monitoring, which do not increase erosion, fugitive dust, traffic, noise, light, or release 

of contaminants or require any change to land use. As the ISFSI and the DTS are replaced 

during the long-term storage timeframe, it is anticipated that there would be no new or additional 

activities from those described above. The potential impacts would be less than the impacts the 

NRC evaluated in Section 5.9.1 because replacement activities would occur within the 

operational area near existing facilities. For these reasons, the NRC concludes that the impact 

on terrestrial resources due to transfer, handling, and aging management of spent fuel at an 

away-from-reactor ISFSI during the long-term storage timeframe would be SMALL. 

5.9.3 Indefinite Storage 

Impacts on terrestrial resources from continued operation of an away-from-reactor ISFSI if a 

repository is not available would be similar to those described in Section 5.9.2. The same 

operations and maintenance activities described in Section 5.9.2 would occur repeatedly 

because the spent fuel would remain at the facility indefinitely. 

Based on the NRC’s evaluation of the impacts from operations of an away-from-reactor ISFSI in 

Section 5.9.2, the NRC concludes that the environmental impacts on terrestrial resources from 

dry cask storage of spent fuel at an away-from-reactor ISFSI indefinitely would be SMALL. 

5.10 Aquatic Ecology 

This section describes aquatic ecology impacts caused by the continued storage of spent fuel at 

an away-from-reactor ISFSI. 

5.10.1 Short-Term Storage 

Construction and operation of an away-from-reactor ISFSI would require limited water supplies 

VHH6HFWLRQVDQG/LTXLGHIIOXHQWVLIany, would be limited to stormwater and treated 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-30 September 2014 

wastewater. The dry cask storage facility could likely be sited away from sensitive aquatic 

features to comply with the ESA and other environmental laws. Ground-disturbing activities 

could increase runoff and surface erosion into aquatic habitats. In most cases, aquatic 

disturbances would result in relatively short-term impacts and the aquatic environs would 

recover naturally. In addition, stormwater control measures, which would be required to comply 

with NPDES permitting, would minimize the flow of disturbed soils or other contaminates into 

aquatic features. The plant operator could also implement BMPs to minimize erosion and 

sedimentation. 

For the PFSF, given the minimal impacts on aquatic biota and minimal aquatic features near the 

site, the NRC concluded that construction and operational activities at the PFSF would have 

had negligible direct and indirect impacts on aquatic biota (NRC 2001). This conclusion 

resulted from the facility’s limited water use and the passive nature of facility operations. For an 

away-from-reactor ISFSI at a different location, the impacts on aquatic resources could be 

different from those at the PFSF. However, certain factors would tend to limit the impacts, 

including the following: 

x The land area permanently disturbed is relatively small. 

x Water use for the construction and operation of the site is limited. 

x Any impacts from discharges to waterbodies must be addressed under the Clean Water Act 

and an associated NPDES permit must be obtained for such discharges, including 

stormwater runoff. 

Considering all of these factors, the NRC concludes that the impacts on aquatic resources 

would be SMALL. 

5.10.2 Long-Term Storage 

Building a DTS and activities related to the transfer and handling of spent fuel and aging 

management at away-from-reactor ISFSIs could result in ground-disturbing activities that would 

have similar impacts to those analyzed in Section 5.10.1. For example, ground-disturbing 

activities could increase runoff and surface erosion into aquatic habitats. The ISFSI and the 

DTS would be replaced during the long-term storage timeframe. The NRC anticipates that 

aquatic impacts from these activities would be within the bounds of those described in 

Section 5.10.1. The potential impacts may be less than the impacts the NRC evaluated in 

Section 5.10.1 because replacement activities would occur within the facility’s operational area 

near existing facilities over an extended period of time. In most cases, aquatic disturbances, if 

any, would result in relatively short-term impacts and the aquatic environs would recover 

naturally. Required mitigation related to NPDES or other permits would also reduce impacts. 

Therefore, the NRC concludes that impacts on aquatic resources from long-term storage at 

away-from-reactor ISFSIs would be SMALL. 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-31 185(*௅

5.10.3 Indefinite Storage 

Impacts on aquatic resources from maintenance and operation of an away-from-reactor ISFSI if 

no repository becomes available would be similar to those described in Section 5.10.2. The 

same operations and maintenance activities described in Section 5.10.2 would occur repeatedly 

because the spent fuel would remain at the facility indefinitely. As described in Section 5.10.2, 

these activities could result in minimal, short-term impacts on aquatic resources. Therefore, the 

NRC concludes that impacts on aquatic resources for indefinite storage of spent fuel at an 

away-from-reactor ISFSI would be SMALL. 

5.11 Special Status Species and Habitats 

This section describes special status species and habitat impacts caused by the continued 

storage of spent fuel at an away-from-reactor ISFSI. 

5.11.1 Short-Term Storage 

Impacts from the construction and operation of dry cask storage facilities on special status 

species and habitats would be similar to those described above for terrestrial and aquatic 

resources, which would range from minimal to noticeable; any noticeable impacts would result 

from the construction of the ISFSI. The NRC assumes that the dry cask storage facility could be 

sited to avoid adversely affecting special status species and habitat because of the facility’s 

relatively small construction footprint and limited use of water. However, if an away-fromreactor ISFSI was located in area that could affect Federally listed species or designated critical 

KDELWDWFRQVXOWDWLRQXQGHU6HFWLRQRIWKH(6$ZRXOGbe required. 

Prior to initial licensing of the facility, the NRC would coordinate with the U.S. Fish and Wildlife 

Service (FWS) or the National Marine Fisheries Service (NMFS) to determine the presence of 

any Federally listed species or designated critical habitat at or near the site. If Federally listed 

species or designated critical habitat could be affected by the facility, the NRC would be 

UHTXLUHGWRLQLWLDWH(6$6HFWLRQFRQVXOWDWLRQThis consultation may be either formal or 

informal, depending on the specific adverse effect. In the case of an adverse effect for which 

the NRC would issue a biological assessment that initiates formal consultation, the FWS or 

NMFS would issue a biological opinion in accordance with the provisions of formal consultation 

at 50 CFR 402.14. The FWS or NMFS could issue, with a biological opinion, an incidental take 

statement that exempts a certain incidental take of Federally listed species and reasonable and 

prudent measures necessary or appropriate to minimize impacts to Federally listed species and 

designated critical habitats. Following the conclusion of an initial consultation, 50 CFR 402.16 

directs Federal agencies to reinitiate consultation where discretionary Federal involvement or 

control over the action has been retained or is authorized by law and where (1) the amount or 

extent of taking specified in the incidental take statement is exceeded, (2) new information 

reveals effects to Federally listed species or designated critical habitats that were not previously 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-32 September 2014 

considered, (3) the action is modified in a manner that causes effects not previously considered, 

or (4) new species are listed or new critical habitat is designated that may be affected by the 

action. 

Thus, the ESA consultation process would identify potential impacts on Federally listed species 

and potentially require monitoring and mitigation to minimize impacts on Federally listed 

species. In addition, the official lists of Federally listed species and designated critical habitats 

are updated by the FWS or NMFS. Species may be added to the list or delisted. If new species 

are listed under the ESA, the NRC would assess any potential impacts on those species at the 

away-from-reactor ISFSI at the time of listing. Therefore, if a new species is listed after the 

ISFSI receives its license, and if the criteria in 50 CFR Part 402 are met for initiation or 

reinitiation RI6HFWLRQFRQVXOWDWLRQthe NRC would initiate or reinitiate (6$6HFWLRQ

consultation with the FWS or NMFS if the newly listed species may be affected by the ISFSI. 

Additional details and guidance regarding the consultation process are provided in 50 CFR 

Part 402 and in the Endangered Species Consultation Handbook (FWS/NMFS 1998), 

respectively. 

In addition, NRC and licensee coordination with other Federal and State natural resource 

agencies would further encourage licensees to take appropriate steps to avoid or mitigate 

impacts on special status species, habitats of conservation concern, and other protected 

species and habitats, such as those protected under the Fish and Wildlife Coordination Act, 

Coastal Zone Management Act, Marine Mammal Protection Act, the Migratory Bird Treaty Act, 

and the Bald and Golden Eagle Protection Act, as applicable. NRC and licensee coordination 

with other Federal and State natural resource agencies would likely result in avoidance or 

mitigation measures that would minimize impacts on protected species and habitats. Impacts 

on essential fish habitat (EFH) from short-term storage are not expected because away-fromreactor ISFSIs are built on land and ground-disturbing impacts would have minimal impacts on 

aquatic habitats, as described in Section 5.10.1. 

The impacts on Federally listed species and designated critical habitat would be determined as 

SDUWRI(6$6HFWLRQFRQVXOWDWLRQ,QFRPSO\LQJZLWKWKH(6$WKH15&ZRXOGHYDOXDWHWKH

impacts of ISFSI construction, operations, and decommissioning in a site-specific review before 

the ISFSI is initially constructed and afterwards if an activity meets the criteria in 50 CFR Part 

402 for initiation or reinitiation RI6HFWLRQconsultation. The FWS ESA guidance provides four 

categories by which the NRC would characterize the effects of ISFSI construction, operation, 

and decommissioning: (1) no effect, (2) may affect but is not likely to adversely affect, (3) may 

affect and is likely to adversely affect, or (4) is likely to jeopardize the continued existence of the 

listed species or destroy or adversely modify the designated critical habitat of Federally listed 

species populations. In the unlikely situation that construction or operation of an ISFSI could 

adversely affect EFH, and if the criteria are met in 50 CFR Part 600 for initiation of consultation 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-33 185(*௅

under the Magnuson–Stevens Fishery Conservation and Management Act, the NRC would be 

required to initiate EFH consultation with NMFS. 

Given flexibility in site selection and the limited size of an ISFSI, the ISFSI can likely be sited to 

minimize adverse effects on special status species and habitats. Accordingly, the NRC 

concludes that the construction and operation of the ISFSI could have minimal to noticeable 

impacts on State-listed species, marine mammals, migratory birds, and bald and golden eagles. 

5.11.2 Long-Term Storage 

As described above, the NRC would evaluate the impacts on Federally listed species and 

designated critical habitat from construction and operation of the ISFSI in a site-specific review 

as required under the ESA. This evaluation would include the potential impacts from transfer, 

handling, and aging management activities, including ISFSI and DTS replacement. If 

transferring, handling, or aging management resulted in a take of a Federally listed species, and 

if the criteria in 50 CFR Part 402 are met for initiation or reinitiation of ESA 6HFWLRQ

consultation, the NRC would initiate or reinitiate consultation with the FWS or NMFS. 

During long-term storage, the NRC assumes that the licensee would have to build a DTS. The 

NRC authorization to construct and operate a DTS would constitute a Federal action under 

NEPA and would be addressed pursuant to 10 CFR Part 51. Prior to authorization, the NRC 

would coordinate with FWS or NMFS to determine the presence of any Federally listed species 

or designated critical habitat at or near the site. If Federally listed species or designated critical 

habitat occur near the site and could be affected by the facility, the NRC would be required to 

LQLWLDWH(6$6HFWLRQFRQVXOWDWLRQDVGHVFULEHGLQ6HFWLRQBecause the ISFSI and the 

DTS would be replaced during the long-term storage timeframe, the NRC anticipates that the 

impacts on special status species and habitats would be within the bounds of those described 

above. The potential impacts would most likely be less than the impacts the NRC evaluated in 

Section 5.11.1 because replacement activities would occur within the operational area near 

existing facilities over an extended period of time. 

In addition, NRC and licensee coordination with other Federal and State natural resource 

agencies would further encourage ISFSI licensees to take appropriate steps to avoid or mitigate 

impacts to State-listed species, habitats of concern, and other protected species and habitats. 

NRC and licensee coordination with other Federal and State natural resource agencies would 

likely result in avoidance or mitigation measures that would minimize impacts on protected 

species and habitats, such as those protected under the Fish and Wildlife Coordination Act, 

Coastal Zone Management Act, Marine Mammal Protection Act, the Migratory Bird Treaty Act, 

and the Bald and Golden Eagle Protection Act, as applicable. 

As described above, in complying with the ESA, the NRC would assess the impacts to Federally 

listed species and designated critical habitat from an away-from-reactor ISFSI and DTS in a 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-34 September 2014 

site-specific review before the facility is initially constructed and afterwards if an activity meets 

the criteria in 50 CFR Part 402 for initiation or reinitiation RI6HFWLRQFRQVXOWDWLRQ7KH15&

would characterize the effects of construction and operations in terms of its ESA findings of 

(1) no effect, (2) may affect but is not likely to adversely affect, (3) may affect and is likely to 

adversely affect, or (4) likely to jeopardize the listed species, or adversely modify the designated 

critical habitat of Federally listed species populations. In the unlikely situation that activities 

during the long-term storage period could adversely affect EFH, and if the criteria are met in 

50 CFR Part 600 for initiation of consultation under the Magnuson–Stevens Fishery 

Conservation and Management Act, the NRC would be required to initiate EFH consultation with 

NMFS. 

Given flexibility in site selection and the limited size of an ISFSI and DTS, these facilities can 

likely be sited to minimize adverse effects on special status species and habitats. Accordingly, 

the NRC concludes that operating and replacing components of the ISFSI and DTS could have 

minimal impacts on State-listed species, marine mammals, migratory birds, and bald and golden 

eagles. 

5.11.3 Indefinite Storage 

Impacts on special status species and habitats from continued operation of an away-fromreactor ISFSIs if a repository never becomes available would be similar to those described in 

Section 5.11.2. The same operations and maintenance activities described in Section 5.11.2 

would occur repeatedly because the spent fuel would remain at the facility indefinitely. 

As described above, in complying with the ESA, the NRC would evaluate the impacts from an 

away-from-reactor ISFSI and DTS in a site-specific review before the facility is initially 

constructed and afterwards if an activity meets the criteria in 50 CFR Part 402 for initiation or 

reinitiation RI6HFWLRQFRQVXOWDWLRQThe NRC would report the effects of construction and 

operations in terms of its ESA findings of (1) no effect, (2) may affect but is not likely to 

adversely affect, (3) may affect and is likely to adversely affect, or (4) likely to jeopardize the 

listed species, or adversely modify the designated critical habitat of Federally listed species 

populations. In the unlikely situation that activities during indefinite storage period could 

adversely affect EFH, and if the criteria are met in 50 CFR Part 600 for initiation of consultation 

under the Magnuson–Stevens Fishery Conservation and Management Act, the NRC would be 

required to initiate EFH consultation with NMFS. 

Given flexibility in site selection and the limited size of an ISFSI and DTS, the ISFSI and DTS 

can likely be sited to minimize adverse effects on special status species and habitats. 

Accordingly, the NRC concludes that operating and replacing components of the ISFSI and DTS 

could have minimal impacts on State-listed species, marine mammals, migratory birds, and bald 

and golden eagles. 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-35 185(*௅

5.12 Historic and Cultural Resources 

This section describes historic and cultural resource impacts caused by the continued storage of 

spent fuel at an away-from-reactor ISFSI. 

The NRC is considering impacts on historic and cultural resources in this GEIS through 

implementation of its NEPA requirements in 10 CFR Part 51. This rulemaking is not a licensing 

action; it does not authorize the construction or operation of an away-from-reactor ISFSI, and it 

does not authorize storage of spent fuel. Because this GEIS does not identify specific sites for 

NRC licensing actions, an NHPA Section 106 review has not been performed. However, the 

NRC complies with NHPA Section 106 and the implementing provisions in 36 CFR Part 800 in 

site-specific licensing actions. As discussed in Section 3.11, identification of historic properties, 

adverse effects, and potential resolution of adverse effects would be conducted through 

consultation and application of the National Register of Historic Places criteria in 36 CFR 60.4. 

This information would also be evaluated to determine the significance of potential impacts on 

historic and cultural resources in the NRC’s environmental review documents. 

For site-specific licensing actions (new reactor licensing, reactor license renewal, and sitespecific at-reactor and away-from-reactor ISFSIs), the NRC complies with Section 106 

requirements to consider the effects of its undertaking on historic properties. If any historic 

properties are present, their significance would be determined through application of the 

National Register of Historic Places criteria. If adverse effects to historic properties are 

identified, appropriate mitigation can be developed through consultation with the State Historic 

Preservation Officer, or appropriate Tribal Historic Preservation Officer, tribal representatives, 

and other interested parties. A site-specific license could be issued at the conclusion of the 

NRC’s safety review and environmental review and compliance with NHPA Section 106 

requirements. 

As discussed in more detail below, the NRC recognizes that there is uncertainty associated with 

the degree of prior disturbance and the resources, if any, are present in areas where future 

ground-disturbing activities could occur. The NRC cannot eliminate the possibility that historic 

and cultural resources would be affected by construction activities because the initial ISFSI 

could be located within a less-disturbed area with historic and cultural resources in close 

proximity. Further, resources may be present after initial construction of the away-from-reactor 

ISFSI that would not have been considered significant at the time the initial or replacement 

facilities were constructed, but could become significant in the future. 

5.12.1 Short-Term Storage 

NRC authorization to construct and operate an away-from-reactor ISFSI would constitute a 

Federal action under NEPA and would be an undertaking under the NHPA. In accordance with 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-36 September 2014 

36 CFR Part 800, the NRC would conduct an NHPA Section 106 review to determine whether 

historic properties are present in the area of potential effect, and if so, whether construction and 

operation of the ISFSI would result in any adverse effects on such properties. Prior to 

submitting an application to construct and operate the ISFSI, the ISFSI applicant would conduct 

a survey of any areas of proposed development to identify and record historic and cultural 

resources. Impacts on historic and cultural resources would vary depending on the location of 

the ISFSI and what resources are present. Resolution of adverse effects to historic properties, 

if any, should be concluded prior to the closure of the Section 106 process. After construction is 

completed, disturbed areas not occupied by ISFSI structures and supporting infrastructure (e.g., 

access roads, parking areas, and laydown areas) would be reclaimed and revegetated. 

The environmental impacts on historic and cultural resources from the construction and 

operation of an away-from-reactor storage facility are informed by the evaluation as described in 

the PFSF EIS (NRC 2001). The proposed PFSF would have been located on the Reservation 

of the Skull Valley Band of Goshute Indians, which HQFRPSDVVHVKDDFLQ

Tooele County, Utah. Storage pads for the canisters and some support facilities would have 

been located on a 99-ac (40-ha) restricted access area within the PFSF site (NRC 2001). 

Additional land would have been disturbed for the access road and the new rail line. The NRC 

assumes that the amount of land disturbance for an away-from-reactor ISFSI would be similar to 

the land disturbance for the PFSF, as discussed in the introduction to this chapter and 

Section 5.1. 

Extensive work was performed at the PFSF to identify historic and cultural resources on or near 

the facilities and to evaluate the potential impacts of the project on those resources (NRC 2001). 

As a result, the NRC concluded that the construction of the rail line would have adversely 

affected portions of eight historic properties evaluated as eligible for inclusion in the National 

Register of Historic Places. The NRC included in the PFS license a condition that required the 

implementation of seven specific requirements for the treatment of historic properties. 

Operation of the proposed PFSF was not expected to impact historic and cultural resources 

because no additional ground disturbance would occur (NRC 2001). 

For an away-from-reactor ISFSI, the impacts on historic and cultural resources would be 

different from those at the PFSF, given the difference in sites. However, several factors could 

avoid, minimize, or mitigate impacts. These include the following: 

x Any impacts on historic and cultural resources would be addressed during a site-specific 

NEPA review. Any adverse effects to historic properties must be addressed under the 

NHPA in consultation with any affected State or Tribal Historic Preservation Officers, and 

other interested parties. 

x The land area disturbed is relatively small and any one of a number of alternative sites can 

be selected. 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5- 185(*௅

x In most, but not all instances, placement of facilities on a proposed site could be adjusted to 

minimize or avoid impacts on historic and cultural resources in the area, but the NRC 

recognizes that this is not always possible. Because an away-from-reactor ISFSI does not 

depend on a significant water supply and has limited electrical power needs, an applicant 

may have more flexibility in how it chooses to place facilities on a site and therefore have a 

greater chance of avoiding historic and cultural resources in the area. 

x Potential adverse effects to historic properties and impacts to other historic and cultural 

resources could be minimized through development of agreements, license conditions, and 

implementation of the licensees’ historic and cultural resource management plans and 

procedures to protect known historic and cultural resources and address inadvertent 

discoveries during construction. 

However, it may not be possible to avoid adverse effects on historic properties under NHPA or 

impacts on historic and cultural resources under NEPA. The magnitude of adverse effects on 

historic properties and impacts on historic and cultural resources largely depends on where 

facilities are sited, what resources are present, the extent of proposed land disturbance, 

whether the area has been previously surveyed to identify historic and cultural resources, and if 

the licensee has management plans and procedures that are protective of historic and cultural 

resources. Even a small amount of ground disturbance (e.g., clearing and grading) could affect 

a small but significant resource. In most instances, placement of storage facilities on the site 

can be adjusted to minimize or avoid impacts on any historic and cultural resources in the area. 

However, the NRC recognizes that this is not always possible. The NRC’s site-specific 

environmental review and compliance with the NHPA process could identify historic properties, 

identify adverse effects, and potentially resolve adverse effects on historic properties and 

impacts on other historic and cultural resources. Under the NHPA, mitigation does not eliminate 

a finding of adverse effect on historic properties. Therefore, the NRC concludes that the 

potential impacts on historic and cultural resources could range from SMALL to LARGE, 

depending on site-specific factors. 

Impacts from continued operations and routine maintenance during short-term timeframe would 

be small because no ground-disturbing activities are expected. Therefore, impacts associated 

with continued operations and maintenance of the ISFSI on historic and cultural resources 

during the short-term timeframe would be SMALL. 

5.12.2 Long-Term Storage 

The NRC assumes that systems, structures, and components of an away-from-reactor ISFSI 

would be replaced during the long-term storage timeframe. In addition to routine maintenance, 

the NRC also assumes that a DTS is constructed, operated, and replaced as part of an awayfrom-reactor ISFSI during the long-term storage timeframe. As discussed in Section 5.1.2 of 

this GEIS, a DTS would be used to retrieve and repackage spent fuel for aging management 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-38 September 2014 

activities or to replace damaged canisters or casks identified during visual inspections. 

Construction and operation of a DTS at an away-from-reactor ISFSI is described in Section 

2.1.4 of this GEIS. 

Impacts from continued operations and routine maintenance during long-term storage would be 

similar to those described for the short-term storage timeframe. The impacts would be small 

because there would be no ground-disturbing activities as a result of the continued operations 

and routine maintenance at the ISFSI. 

NRC authorization to construct and operate a DTS and replace the ISFSI and DTS would 

constitute Federal actions under NEPA and would be undertakings under the NHPA and would 

require a site-specific environmental review and compliance with NHPA requirements before 

making a decision on the licensing action. In accordance with 36 CFR Part 800, a Section 106 

review would be conducted for each undertaking to determine whether historic properties are 

present in the area of potential effect, and if so, whether these actions would result in any 

adverse effects upon these properties. Impacts on historic and cultural resources can vary 

depending on the location of the original DTS and the replacement ISFSI and DTS and what 

resources are present. For site-specific licensing actions (new reactor licensing, reactor license 

renewal, site-specific at-reactor and away-from-reactor ISFSIs, and DTS), applicants are 

required to provide historic and cultural resource information in their environmental reports. To 

prepare these assessments, applicants conduct cultural resource surveys. This information 

assists NRC in its review of the potential impacts on historic and cultural resources. Section 

106 of the NHPA requires the NRC to conduct a site-specific assessment to determine whether 

historic properties are present in the area of potential effect, and if so, whether construction and 

operation of a DTS would result in any adverse effect upon these properties. Resolution of 

adverse effects, if any, should be concluded prior to the closure of the Section 106 process. 

The NRC assumes that the replacement ISFSI and initial and replacement DTS will be 

constructed on land near the existing facilities. Ground-disturbing activities occurred during 

initial ISFSI construction, and much of the land within and immediately surrounding the ISFSI 

would be disturbed. If the replacement ISFSI and initial and replacement DTS are sited within 

previously disturbed areas, then impacts would likely be small because initial construction of the 

ISFSI could have reduced the potential for historic and cultural resources to be present. 

However, if these facilities were sited in less-developed or disturbed portions of the ISFSI site, 

then there could be impacts to historic and cultural resources. 

Given the land area available around the ISFSI restricted area, the licensee should be able to 

locate the replacement facilities away from historic and cultural resources. However, the NRC 

recognizes that it may not be possible for a licensee to avoid adverse effects to historic 

properties under NHPA or impacts on historic and cultural resources under NEPA. The NRC 

believes that it is reasonable to assume that the replacement ISFSI and the initial and 

replacement DTS would be constructed near the existing ISFSI because the licensee would 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-39 185(*௅

already have characterized and selected the initial ISFSI site to meet NRC siting, safety, and 

security requirements. The NRC believes that it is reasonable to assume that licensees would 

generally avoid siting and operating an ISFSI away from the existing licensed area or outside 

previously characterized areas. The magnitude of adverse effects on historic properties and 

impacts to historic and cultural resources during the long-term timeframe largely depends on 

where the facilities are sited, what resources are present, the extent of proposed land 

disturbance, whether the area has been previously surveyed to identify historic and cultural 

resources, and whether the licensee has management plans and procedures that are protective 

of historic and cultural resources. Even a small amount of ground disturbance (e.g., clearing 

and grading) could affect a small but significant resource. In most, but not all, instances, 

placement of storage facilities on the site can be adjusted to minimize or avoid impacts on any 

historic and cultural resources in the area. Before these ground-disturbing activities occur, the 

site-specific environmental review and compliance with the NHPA process would identify 

historic properties and historic and cultural resources that could be impacted. Under the NHPA, 

mitigation does not eliminate a finding of adverse effect on historic properties; but impacts would 

be assessed at the time of the future proposed licensing action. 

Based on the considerations above, the potential impacts on historic and cultural resources 

during the long-term storage timeframe would range from SMALL to LARGE. This range takes 

into consideration routine maintenance and monitoring (i.e., no ground-disturbing activities), the 

absence or avoidance of historic and cultural resources, and potential ground-disturbing 

activities that could affect historic and cultural resources. The analysis also considers 

uncertainties inherent in analyzing this resource area over long timeframes. These 

uncertainties include any future discovery of previously unknown historic and cultural resources; 

resources that gain significance within the vicinity and the viewshed (e.g., nomination of a 

historic district) due to improvements in knowledge, technology, and excavation techniques and 

changes associated with predicting resources that future generations will consider significant. 

Potential adverse effects on historic properties or impacts on historic and cultural resources 

could be minimized through development of agreements, license conditions, and 

implementation of the licensees’ historic and cultural resource management plans and 

procedures to protect known historic and cultural resources and address inadvertent discoveries 

during construction of the replacement ISFSI and initial and replacement DTS. If construction of 

a DTS and replacement of the ISFSI and DTS occurs in an area with no historic or cultural 

resource present or construction occurs in previously a disturbed area that allows avoidance of 

historic and cultural resources then impacts would be SMALL. By contrast, a MODERATE or 

LARGE impact could result if historic and cultural resources are present at a site and, because 

they cannot be avoided, are impacted by ground-disturbing activities during the long-term 

timeframe. Accordingly, the NRC has concluded that the impacts on historic and cultural 

resources for the long-term timeframe would be SMALL to LARGE. 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-40 September 2014 

5.12.3 Indefinite Storage 

The environmental impacts of indefinite spent fuel storage would be similar to those described 

in Section 5.12.2. The same operations and maintenance activities described in Section 5.12.2 

would occur repeatedly because the spent fuel would remain at the facility indefinitely. During 

this timeframe, maintenance and monitoring would continue and the at-reactor ISFSI and DTS 

would be replaced every 100 years. The site-specific environmental review and compliance 

with the NHPA process would identify historic properties, adverse effects, and potentially 

resolve adverse effects on historic properties and impacts on other historic and cultural 

resources. As discussed in Section 5.12.2, the NRC assumes that the replacement of the ISFSI 

and DTS would be constructed on land near the existing facilities. As stated in Section 1.8, the 

NRC assumes that the land where the original facilities were constructed will be available for 

replacement facility construction; however, the NRC cannot eliminate the possibility that historic 

and cultural resources would be affected by construction activities during the indefinite 

timeframe because the NRC recognizes that there is uncertainty associated with the degree of 

prior disturbances and what resources, if any, are present in areas where future grounddisturbing activities (e.g., initial and replacement DTS and replacement ISFSI) could occur. 

Further, significant resources may be present that were not considered significant at the time 

the initial or replacement facilities were constructed. Impacts regarding the replacement of the 

ISFSI and DTS would be similar to those described for the long-term storage timeframe. 

Based upon the considerations above, the potential impacts to historic and cultural resources 

during the indefinite storage timeframe would range from SMALL to LARGE. This range takes 

into consideration routine maintenance and monitoring (i.e., no ground-disturbing activities), the 

absence or avoidance of historic and cultural resources, and potential ground-disturbing 

activities that could impact historic and cultural resources. The analysis also considers 

uncertainties inherent in analyzing this resource area over long timeframes. These 

uncertainties include any future discovery of previously unknown historic and cultural resources; 

resources that gain significance within the vicinity and the viewshed (e.g., nomination of a 

historic district) due to improvements in knowledge, technology, and excavation techniques and 

changes associated with predicting resources that future generations will consider significant. 

Potential adverse effects on historic properties or impacts on historic and cultural resources 

could be minimized through development of agreements, license conditions, and 

implementation of the licensees’ historic and cultural resource management plans and 

procedures to protect known historic and cultural resources and address inadvertent discoveries 

during construction of the replacement ISFSI and replacement DTS. If construction of a DTS 

and replacement of the ISFSI and DTS occurs in an area with no historic or cultural resource 

present or construction occurs in previously a disturbed area that allows avoidance of historic 

and cultural resources then impacts would be SMALL. By contrast, a MODERATE or LARGE 

impact could result if historic and cultural resources are present at a site and, because they 

cannot be avoided, are impacted by ground-disturbing activities during the indefinite timeframe. 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-41 185(*௅

Accordingly, the NRC has concluded that the impacts on historic and cultural resources for the 

indefinite timeframe would be SMALL to LARGE. 

5.13 Noise 

This section describes noise impacts caused by the continued storage of spent fuel at an awayfrom-reactor ISFSI. 

5.13.1 Short-Term Storage 

The assessment of the environmental impacts of noise from the construction and operation of 

an away-from-reactor ISFSI is informed by those described in the PFSF EIS (NRC 2001). 

Background noise levels within the vicinity of the PFSF (Skull Valley) are low, as would be 

H[SHFWHGIRUDQ\UHPRWHORFDWLRQ7KH(3$KDVSURYLGHGJXLGHOLQHVRXQGOHYHOVEHORZ

which the general public would be protected from activity interference and annoyance; 55 dBA 

applies to outdoor locations “in which quiet is a basis for use” and 45 dBA applies to indoor 

residential areas (NRC 2001). 

Construction of the ISFSI facility occurs during a small portion of the short-term timeframe. The 

schedule for the proposed PFSF called for the first stage of construction, which included the 

major buildings and one-fourth of the total number of proposed storage pads, to last 18 months 

(NRC 2001). Noise impacts would result from construction equipment used to grade and level 

the site, excavate the facility foundation, handle building materials, build the ISFSI facilities 

(e.g., buildings, storage pads, access road, new rail siding, and new rail spur), and from 

additional construction traffic. Construction equipment associated with these activities can 

generate noise levels up to 95 dBA (NRC 2001). This noise level applies at a reference 

distance of 15 m (50 ft) from the source. Noise levels decrease by about 6 dBA for each 

doubling of distance from the source. At distances greater than about 1.9 km (1.2 mi), expected 

maximum noise levels would be less than the 55 dBA recommended by the EPA for protection 

against outdoor activity interference and annoyance (NRC 2001). For the PFSF, constructionrelated noise levels were expected to be less than 48 dBA in the ambient air at the nearest 

residences (at a distance of roughly 3 km [2 mi]). Therefore, noise from construction activity 

was not expected to be annoying for residents located in the nearest houses (NRC 2001). 

However, for an away-from-reactor ISFSI at a different location, the nearest resident could be 

closer and noise levels during construction could exceed the EPA recommendation. Whether 

associated noise impacts could or would be mitigated could only be determined during a sitespecific review. 

Construction would also result in increased vehicle traffic (e.g., commuting workforce, 

construction vehicles, and material transport) and an associated increase in noise. For the 

PFSF this would have increased noise levels by 5 dBA (NRC 2001). The impacts of the 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-42 September 2014 

increase in noise around the ISFSI will depend considerably on the nature of the area through 

which the traffic is passing. Because the NRC expects that the ISFSI will be built in a remote 

location with little pre-existing traffic, the noise from the additional traffic is likely to be noticeable 

and could exceed the EPA recommendation. However, the duration of the most intense portion 

of the construction period would be limited (roughly 18 months for the PFSF). 

Operation of the ISFSI would involve transporting, receiving, handling, and storing spent fuel, as 

well as routine maintenance and monitoring of the ISFSI. Cask transportation, receiving, and 

handling would be the primary noise sources during operations; the loudest onsite noise source 

would most likely be the onsite locomotive diesel switch engine. The train whistle from this 

locomotive could be audible at nearby residences. Momentary noise from routine operation 

could exceed 100 dBA. However, this locomotive would only operate a few hours per week 

(NRC 2001). Because the locomotive would be expected to operate only a few hours per week, 

indoor and outdoor noise impacts are expected to be minimal. 

Noise impacts could also be associated with the transportation of spent fuel to the site. In the 

PFSF EIS (NRC 2001), the NRC estimated that an average of 150 loaded transportation 

packages would be received at the facility each year, carried by 1 or 2 trains per week, and a 

similar frequency is assumed for the ISFSI. While the train’s whistle would be loud, trains would 

be passing only infrequently. Therefore, the NRC concludes that the noise impacts resulting 

from transportation of spent fuel to the ISFSI would be minor. 

In conclusion, the NRC determined that the construction and operation noise impacts for the 

away-from-reactor ISFSI could exceed the EPA-recommended levels during some portions of 

construction and occasionally during operations. However, because of the limited duration of 

the construction period and the intermittent nature of the noise, the NRC concludes that the 

overall impacts associated with noise for the construction and short-term operation of the awayfrom-reactor ISFSI would be SMALL. 

5.13.2 Long-Term Storage 

The NRC assumes that a DTS is constructed as the duration and quantity of spent fuel in dry 

cask storage at an onsite storage facility increases. This facility would be used to retrieve and 

repackage spent fuel for aging management activities or to replace damaged canisters or casks 

identified during visual inspections. Section 2.1.4 provides a detailed description of the DTS. 

Construction of a DTS would take approximately 1 to 2 years to complete. Noise levels 

generated during construction would be similar to those associated with initial construction of 

the ISFSI. Noise levels during construction could exceed the EPA recommendation at the 

nearest residence. Whether associated noise impacts could or would be mitigated could only 

be determined during a site-specific review. There would also be some additional traffic 

associated with the construction of the DTS but less than the traffic that would have occurred 

during initial construction. 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-43 185(*௅

Noise generated during operation of the ISFSI (e.g., cask handling, movements to and from 

pads, and routine maintenance and monitoring of the ISFSI) would be the same as during 

operations for the short-term timeframe, which were minimal. 

Aging management would require the replacement of the ISFSI (e.g., casks, storage pads, and 

canister transfer building) and the DTS during the long-term storage timeframe. Storage facility 

and DTS replacement uses construction equipment that can generate noise levels similar to the 

original construction of the ISFSI. These noise levels could exceed the EPA recommendation 

during replacement activities. Whether associated noise impacts could or would be mitigated 

could only be determined during a site-specific review. 

In conclusion, construction of the DTS, although temporary and representing a small portion of 

the overall timeframe for the spent fuel storage, does generate noise levels that could exceed 

EPA-recommended noise levels, as would activities to replace storage pads and other 

structures. However, these activities are temporary and noticeable noise levels would be limited 

to the nearest receptors. Generally for continued spent fuel storage, the operation noise levels, 

noise duration, and distance between the noise sources and receptors do not produce impacts 

noticeable to the surrounding community. Therefore, the NRC concludes that the overall noise 

impacts during the long-term storage timeframe at an away-from-reactor ISFSI would be 

SMALL. 

5.13.3 Indefinite Storage 

The environmental impacts of indefinite spent fuel storage would be similar to those described 

in Section 5.13.2. The same operations and maintenance activities described in Section 5.13.2 

would occur repeatedly because the spent fuel would remain at the facility indefinitely. Based 

on this information, the NRC concludes that the overall noise impacts during indefinite storage 

at an away-from-reactor ISFSI would be SMALL. 

5.14 Aesthetics 

This section describes aesthetic resource impacts caused by the continued storage of spent fuel 

at an away-from-reactor ISFSI. 

5.14.1 Short-Term Storage 

Development of an away-from-reactor ISFSI would use a larger land area than any at-reactor

ISFSI. The ISFSI would likely be sited and constructed in an area remote from population 

centers and areas sensitive to aesthetic concerns. On the other hand, the ISFSI could be sited 

and constructed in an area with no existing industrial facilities or similar land disturbance. 

Therefore, a site-specific analysis of the aesthetic impacts will be required for any proposed 

facility. The ISFSI could affect local scenic and visual quality to the extent its facility structures 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-44 September 2014 

and operations (e.g., buildings, dry storage pads and canisters, the rail line, and trains) are 

visible across any scenic waterbodies or from higher topographic elevations. Facility lighting 

could also affect the scenic quality of the area. If constructed in an area with no existing 

industrial development, there could also be viewshed impacts to the cultural landscape if historic 

properties are present within the area. Potential mitigation measures include use of shielded 

lights to minimize light diffusion at night, planting native vegetation or constructing earthen 

berms to screen the facility, and using paint colors that blend facility structures with the 

surrounding landscape, as discussed in the PFSF EIS (NRC 2001). 

Further, the NRC considered the aesthetic impacts of spent fuel storage at a consolidated site 

as part of the PFSF EIS. This evaluation represents the result for an ISFSI built in an area with 

no previous industrial development. For the PFSF, the NRC found that the visual character of 

the area surrounding the site would have been negatively affected by development and 

operation of an industrial facility in an otherwise largely undeveloped rural landscape. The NRC 

determined that the scenic appeal of the site would have been noticeably changed when viewed 

from various locations. Because of these anticipated changes to the affected viewshed, the 

NRC found the aesthetic impacts from the construction and operation of the PFSF to be SMALL 

to MODERATE (NRC 2001). 

For an away-from-reactor ISFSI at a different location, the impacts on aesthetic resources would 

be similar to those for the PFSF if it is built in a location with no previous industrial development. 

But the impacts could be SMALL if the ISFSI is built in a previously disturbed location (i.e., a 

brownfield site). Overall, the NRC concludes that the impacts on aesthetic resources would be 

SMALL to MODERATE. 

5.14.2 Long-Term Storage 

Aesthetic impacts from transferring and handling spent fuel and aging management activities at 

an away-from-reactor ISFSI are anticipated to be similar to the impacts described for the 

construction and short-term operation of the ISFSI described in Section 5.14.1. More 

specifically, periodic construction and demolition of facilities (including a DTS), although 

temporary, could cause an increase in aesthetic impacts compared to normal operation of the 

facility. However, because the replacement of the facilities would be placed near existing 

facilities and the activities and structures involved in the replacement are not expected to 

provide a significant change to what would exist prior to replacement, there would be no 

noticeable change to the impacts on aesthetic resources. 

Because the periodic construction, demolition, and operation activities required for aging 

management would not significantly alter the pre-existing impacts of an away-from-reactor 

ISFSI, the NRC concludes that the environmental impacts on aesthetic resources due to longterm storage would be SMALL to MODERATE. 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-45 185(*௅

5.14.3 Indefinite Storage 

If a repository is not available and away-from-reactor ISFSIs are developed, the activities that 

would be conducted at an away-from-reactor ISFSI would be the same as those described in 

Section 5.14.2. The same operations and maintenance activities described in Section 5.14.2 

would occur repeatedly because the spent fuel would remain at the facility indefinitely. Based 

on this information, the NRC concludes that the aesthetic impacts during long-term storage at 

an away-from-reactor ISFSI would be SMALL to MODERATE. 

5.15 Waste Management 

This section describes impacts from low-level radioactive waste (LLW), mixed waste, and 

nonradioactive waste management and disposal resulting from the continued storage of spent 

fuel at an away-from-reactor ISFSI. See Section 3.14 for a description of the different types of 

waste and typical disposal methods for the wastes. See Section 4.15 for a description of the 

types and impacts of waste generated from the operation, maintenance, and replacement of an 

at-reactor ISFSI; they are the same types of waste produced by the operation, maintenance, 

and replacement of an away-from-reactor ISFSI. However, the away-from-reactor ISFSI is a 

much larger facility than an at-reactor ISFSI and therefore would generate a higher volume of 

waste. 

5.15.1 Short-Term Storage 

Assessment of the environmental impacts from the handling and disposal of LLW, mixed waste, 

and nonradioactive waste from an away-from-reactor ISFSI is informed by those described in 

the PFSF EIS (NRC 2001). The PFSF was designed with a capacity of 40,000 MTU and the 

NRC has assumed a facility of similar size and characteristics for the away-from-reactor ISFSI. 

Because a similar facility is assumed, the quantities of the various wastes generated at the 

ISFSI would also be similar to those identified for the PFSF. For purposes of estimating waste 

volumes, the canister transfer building would only handle canistered spent fuel. Therefore, the 

NRC assumes the amount of LLW produced during operation of a canister transfer building is 

no more than is produced at a DTS (i.e., 0.06m3 [2 ft3] per canister), which handles bare spent 

fuel. 

The construction of the PFSF would have included construction of major buildings (e.g., 

administration and laboratory) and 500 concrete storage pads. Construction activities would 

have generated excavation and construction debris, vegetation debris, and backfill (NRC 2001). 

For an away-from-reactor ISFSI, the construction debris would typically be disposed of at a local 

landfill. The excavation and backfill material could likely be reused for other purposes (e.g., 

building an earthen berm or to level low-lying areas). For the PFSF, the amount of soil 

excavated was estimated to be 153,500 m3 (200,800 yd3). All of this material was expected to 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-46 September 2014 

remain onsite for other uses. This is consistent with NRC experience with other applications 

(e.g., new reactors), for which excavation materials are used or disposed of on the site. 

Operation of an away-from-reactor ISFSI, like the PFSF, would involve limited waste-generating 

activities. The types of wastes generated would be similar to those for an onsite ISFSI, as 

described in Section 4.15.1, but on a larger scale. Small quantities of LLW would be generated 

during routine operation, including maintenance and environmental monitoring. This waste 

would be managed according to 10 CFR Part 20. Because (1) LLW would continue to be 

managed according to Federal regulations and (2) the disposal capacity for LLW is expected to 

be available when needed (see Section 1.8.3), the NRC determines the impacts from LLW 

management and disposal would be minor during short-term storage. 

Operation and maintenance of the ISFSI would be expected to generate minimal to no mixed 

waste. Like other industrial facilities, small quantities of nonradioactive waste would be 

generated from routine operations and maintenance, including municipal waste and hazardous 

wastes, such as paint waste, pesticides, and cleaning supplies (NRC 2001). Sanitary wastes 

would be handled in accordance with regulatory requirements and disposed of at an 

appropriately permitted disposal facility. The wastes would be managed and disposed of 

according to regulatory requirements. 

The NRC considered the impacts of solid and sanitary wastes due to spent fuel storage at a 

consolidated site as part of the PFSF EIS. This evaluation found that impacts from managing 

solid and sanitary wastes during construction and operation of the PFSF would have been 

SMALL (NRC 2001). Because of the small quantities of waste involved, the NRC concludes 

that the impacts of managing and disposing of LLW, mixed waste, and nonradioactive waste 

generated at an away-from-reactor ISFSI would be SMALL. 

5.15.2 Long-Term Storage 

Routine maintenance would continue to occur in the same manner as described in 

Section 5.15.1, generating minimal amounts of waste. Waste management and disposal 

activities related to the construction and operation of a DTS, and the replacement of canisters, 

storage casks, pads, the canister transfer building, DTS facilities, and other ISFSI structures, 

are discussed below. The repackaging of spent fuel, construction and operation of a DTS, and 

ISFSI and DTS replacement are not expected to generate mixed waste. However, if mixed 

waste is generated, it would be a small fraction of that generated by an operating nuclear power 

plant and it would be managed according to regulatory requirements. As well, any hazardous 

wastes generated during this timeframe would be a fraction of that generated at an operating 

power plant and would be managed according to regulatory requirements. 

As described in Sections 4.15.2.1 and 4.15.2.3, the construction of a DTS would not be 

expected to generate LLW but would generate nonradioactive wastes similar to, but on a much 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5- 185(*௅

smaller scale than, the original construction of the ISFSI. The NRC expects that the material 

that is excavated for the DTS would be disposed of onsite. 

For this analysis, because the activities associated with the replacement of the casks and ISFSI 

facilities are similar to decommissioning activities, the LLW impacts from the replacement of 

canisters, casks, and concrete pads are based on the decommissioning impacts considered in 

the PFSF EIS and other sources. As stated in Section 4.15.2.1, individual used canisters would 

be managed and disposed of as LLW and would have a compacted nominal volume of 1.3 m3

\G3) (Transnuclear Inc. 2004). An estimated additional 0.06 m3 (2 ft3) would be generated 

during unloading and loading of each canister. Therefore, repackaging and replacing 4,000 

canisters at an away-from-reactor ISFSI would generate approximately 5,400 m3 ( yd3) of 

LLW. Once a canister has been removed from a cask, the licensee would survey the cask for 

residual radioactivity. If levels are below NRC limits, the casks can be disposed of as 

nonradioactive solid waste. If levels are above NRC limits, the cask material would be disposed 

of as LLW. Donnell (1998) estimated that the decommissioning of one cask at the PFSF would 

generate 0.34 m3 (0.45 yd3) of compacted LLW. Using this volume, the dismantling of 4,000 

storage casks as part of ISFSI replacement would generate 1,360 m3 \G3) of compacted 

LLW over an extended period of time. In addition, in its license application, PFS assumed at 

least 10 percent of the total storage pad surface area would need to be decontaminated. The 

decontamination of the 500 concrete storage pads at the PFSF would have generated an 

additional 8.5 m3 (11 yd3) of LLW (NRC 2001). If the storage pads are removed in their entirety, 

approximately 85,500 m3 (112,000 yd3) of material would need to be disposed of, either as LLW 

or nonradioactive waste (NRC 2001). As stated in Section 4.15.2.1, replacing the DTS would 

generate about 4 to 8 m3 (5 to 10 yd3) of LLW (DOE 1996). For purposes of estimating the 

volume of LLW generated by decontaminating the canister transfer building, which is not 

designed to handle bare spent fuel and would remain largely uncontaminated, the NRC 

assumes the amount of LLW is no more than is produced at a DTS (4 to 8 m3 [5 to 10 yd3]), 

which would handle bare spent fuel and could be contaminated. 

Using the LLW volumes described above, the total volume of LLW generated during the longterm timeframe from replacement of canisters and decontamination of casks, ISFSI pads, DTS, 

and canister transfer building is about 6,800 m3 (8,900 yd3), which is comparable to the LLW 

volumes estimated for decommissioning a pressurized-water reactor (NRC 1996). 

The NRC also estimated the volume of non-radioactive waste from the activities described 

above. In addition to the volume of LLW described above, the replacement of 4,000 casks 

would generate 162,000 m3 (212,000 yd3) of nonradioactive waste. The removal of those 

portions of the ISFSI pad which are decontaminated would generate about 85,500 m3

(112,000 yd3) (NRC 2001). The volume of non-radioactive waste from removal of the 

decontaminated DTS is estimated from the DTS TSAR to be 863 m3 (1,130 yd3) (DOE 1996). 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-48 September 2014 

*LYHQWKDWWKHFDQLVWHUWUDQVIHUEXLOGLQJLVDERXWWLPHVODUJHUWKDQWKH'76the NRC 

estimates the volume of solid waste generated from removal of the canister transfer building 

would be about 60,000 m3 \G3). 

In summary, the total nonradioactive waste volume for replacement of storage casks, ISFSI 

pads, DTS, and canister transfer building is about 308,000 m3 (403,000 yd3), which is equivalent 

WRDERXW07WRQVRIFRQFUHWH7KLVDPRXQWRIQRQUDGLRDFWLYHZDVWH is a very 

small fraction of the 226 million MT (250.4 million tons) of municipal solid waste disposed of in 

2011 (EPA 2013c), which would result in small impacts on total municipal solid waste capacity. 

Although the exact amount of LLW and nonradioactive waste depends on the level of 

contamination, the quantity of waste generated from the replacement of the canisters, storage 

casks, concrete storage pads, DTS, and canister transfer building is still expected to be a 

comparable to the LLW generated during reactor decommissioning, which was previously 

determined to have a SMALL impact in the Generic Environmental Impact Statement for 

License Renewal of Nuclear Plants (NRC 2013a). Because (1) LLW would continue to be 

managed according to Federal regulations and (2) the disposal capacity for LLW is expected to 

be available when needed (see Section 1.8.3), the NRC determines the impacts from LLW 

management and disposal would be minor during the long-term timeframe. In addition, as 

described above, the amount of radioactive waste results in small impacts on municipal solid 

waste capacity. Therefore, the NRC determines that the potential environmental impacts from 

LLW, mixed waste, and nonradioactive waste for long-term storage at an away-from-reactor 

ISFSI would be SMALL for each waste stream. 

5.15.3 Indefinite Storage 

This section describes the potential environmental impacts from the management and disposal 

of LLW, mixed waste, and nonradioactive waste if a repository is not available to accept spent 

fuel. For this analysis, the NRC assumes that spent fuel would continue to be stored at an 

away-from-reactor ISFSI indefinitely. The waste-generating activities during this timeframe 

include the same activities discussed in Section 5.15.2 but with the activities occurring 

repeatedly. Those impacts were determined to be SMALL based on previous analyses that 

assumed a repository would be available. 

The activities associated with the management and disposal of LLW and mixed waste from 

indefinite away-from-reactor storage of spent fuel would be similar to those described for the 

long-term timeframe. As stated in Section 1.8.3, it is expected that sufficient LLW disposal 

capacity will be made available when needed. Similar to the long-term timeframe, the NRC 

concludes the management and disposal of LLW and mixed waste could result in SMALL 

environmental impacts during indefinite storage of spent fuel. However, in this timeframe, 

because nonradioactive waste would continue to be generated indefinitely, even with continued 

implementation of and adherence to regulatory requirements, there could be noticeable impacts 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-49 185(*௅

on the local and regional landfill capacity for nonradioactive nonhazardous wastes. Therefore, 

the NRC determines that the environmental impacts from the indefinite management and 

disposal of nonradioactive waste would be SMALL to MODERATE. 

5.16 Transportation 

This section describes transportation impacts caused by the continued storage of spent fuel at 

an away-from-reactor ISFSI. Noise impacts from transportation activities are evaluated in 

Section 5.13 and air emissions are evaluated in Section 5.4. The transportation activities to 

move spent fuel to an away-from-reactor ISFSI are included in this section. In considering 

impacts related to the transportation of spent fuel from reactors to the away-from-reactor ISFSI, 

the NRC considers both the information in Table S–46 (10 CFR 51.52) and the analysis of spent 

fuel transportation provided in the PFSF EIS (NRC 2001). Activities and impacts associated 

with moving spent fuel from the away-from-reactor ISFSI to a repository are addressed as 

cumulative impacts in Chapter 6. 

5.16.1 Short-Term Storage 

This analysis considers the impacts of transportation activities associated with construction and 

short-term operation of an away-from-reactor ISFSI on the affected environment beyond the site 

boundary. The environmental impacts evaluated include impacts on regional traffic from worker 

commuting, supply shipments, shipment of spent fuel to the ISFSI, and nonradiological and 

radiological waste shipments. Impacts on traffic from workers commuting to and from the awayfrom-reactor storage site depend on the size of the workforce, the capacity of the local road 

network, traffic patterns, and the availability of alternate commuting routes to and from the 

facility. 

Construction transportation activities involve workers commuting to and from the site and 

shipping construction equipment, supplies, and waste materials. In the prior analysis of impacts 

from constructing the PFSF, the NRC concluded the initial construction phase (e.g., major 

buildings, approximately 25 percent of the proposed storage pads, the access road, a new rail 

siding, and new rail line) would have the largest transportation impacts during construction 

based on a total workforce of 255, split almost evenly between work on the site and work on the 

rail line (NRC 2001). The NRC considers the amount of transportation (additional number of 

vehicles on the road) from the PFSF EIS to be representative of the transportation for the awayfrom-reactor ISFSI because the facilities are the same size. For the first phase of construction 

 

6 Table S–4 was prepared based on the assumption that spent fuel would be shipped from the reactor 

site to a reprocessing facility. However, because the analysis is addressing impacts that occur during 

transportation of the spent fuel, the type of facility to which it is being sent is not important. Therefore, the 

information provided by Table S–4 can be considered by the NRC in evaluating the impacts of the 

transportation of spent fuel from reactor sites to an away-from-reactor ISFSI. 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-50 September 2014 

for the PFSF, lasting about 18 months, the NRC concluded that the impacts on local 

transportation would have been SMALL to MODERATE. That analysis also found the 

transportation impacts of completing remaining facility construction would diminish along with a 

concurrent decline in the need for equipment, materials, and construction workers. The prior 

analysis concluded traffic impacts and increased wear and maintenance requirements would be 

highest (moderate impact) on local roads with low average daily traffic and less pronounced 

(small) for major transportation routes that have higher capacities. Specifically, peak 

construction traffic involving supply shipments and commuting workers was estimated at 

450 vehicle trips per day (NRC 2001). This traffic was being added to local roads with annual 

average daily traffic counts between 325 and 565 vehicles per day (an increase in traffic ranging 

IURPWRSHUFHQW7KLVFKDQJHLQORFDOWUDIILFSUHYLRXVO\HYDOXDWHGIRUWKH3)6)FKDQJHG

the level of service resulting in a conclusion of moderate impacts on traffic. Transportation of 

cask materials to construct 200 casks per year (an additional 6 truck trips per day) was also 

previously evaluated for the PFSF as not significantly adding to the daily traffic or projected 

impacts. 

The impacts on traffic from construction of an away-from-reactor ISFSI at a different location are 

likely to be similar. The amount of additional traffic is not very large but because the ISFSI will 

likely be built in a remote location with limited existing roads, the impacts on local traffic may still 

be noticeable but not destabilizing. If the location of the ISFSI has an extensive existing road 

network, then the impacts may not be noticeable. 

Construction of a rail line and siding to the PFSF would have required the movement of large 

quantities of excavated soils, ballast, and sub-ballast as well as the transportation of workers to 

construction areas and the same would be true for the away-from-reactor ISFSI, for which a 

similar rail line is assumed. The previous NRC impact analysis indicated that most materials 

and workers would be expected to travel to the site of the proposed rail siding by the interstate 

highways. Construction of the proposed rail line and siding would have required approximately 

245,000 m3 (320,000 yd3) of ballast and sub-ballast (composed of crushed gravel or rock) 

obtained from existing commercial gravel pits in the area. Assuming a per-truck capacity of 

approximately 15.3 m3 (20 yd3) for movement of the ballast and sub-ballast, a total of 

approximately 32,000 two-way truck trips would have been required to transport the ballast and 

sub-ballast or 134 truck trips per day or approximately 13 vehicles per hour. The rail line 

construction workforce was estimated to be 125 workers contributing 250 vehicle trips per day 

for a total of 384 vehicle trips per day for rail line construction. This level of traffic was 

4.5 percent of the interstate traffic; therefore, the NRC concluded impacts on transportation by 

construction of the rail line would have been small although temporarily adverse to feeder road 

traffic (i.e., noticeable but not destabilizing). 

The impacts on traffic of building a rail line to an away-from-reactor ISFSI at a different location 

are likely to be similar. The amount of additional traffic is not very large, but because the ISFSI 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-51 185(*௅

will likely be built in a remote location with limited existing roads, the impacts on local traffic may 

still be noticeable but not destabilizing. If the location of the ISFSI has an extensive existing 

road network, then the impacts may not be noticeable. 

Operation of an away-from-reactor ISFSI would result in small impacts on the local 

transportation system due to daily commuting of workers and shipment of fabricated steel liners 

for the storage casks and spent fuel transportation packages. The NRC previously estimated 

for the PFSF that an operations workforce of 43 workers would commute each day using 

individual private vehicles or light trucks. These workers would account for an increase of 86 

vehicle trips per day on local roads during operations. The previous NRC analysis of impacts of 

the PFSF concluded this decrease in the volume of traffic generated by the storage facility 

relative to construction activities would not result in any degradation of the level of service on 

local roads (NRC 2001). Because of the small number of trips involved, the NRC concludes 

that the traffic impacts for an away-from-reactor ISFSI at a different location would also not be 

noticeable. 

During the operation of the away-from-reactor ISFSI, spent fuel would be shipped from power 

plants to the facility. These shipments would be required to comply with applicable NRC and 

U.S. Department of Transportation (DOT) regulations for the transportation of radioactive 

materials in &)53DUWVDQGDQG&)5Parts —180, 390—DV

appropriate to the mode of transport. The radiological impacts on the public and workers of 

spent fuel shipments from a reactor have been previously evaluated by the NRC and found to 

be SMALL in several evaluations. A generic impact determination in 10 CFR 51.52, Table S–4, 

DQGWKHVXSSRUWLQJDQDO\VLV$(&FRQFOXGHGWKDWWKHHQYLURQPHQWDOLPSDFWVRI

transportation of fuel and waste to and from a light water reactor under normal operations of 

transport and accidents in transport would be small. 

The results of subsequent analyses of transportation impacts in Final Environmental Statement 

on Transportation of Radioactive Material by Air and Other Modes 15&DQG

Reexamination of Spent Fuel Shipment Risk Estimates (Sprung et al. 2000) confirmed that 

spent fuel transportation impacts are small. Additional site-specific analyses of transportation 

impacts for power plants that did not meet the conditions of 10 CFR 51.52 also concluded that 

the transportation radiological impacts would be small (NRC 2006c, 2008b, 2011aíd, 2013c). 

The NRC recently calculated spent fuel transportation risks for individual shipments under 

incident-free and accident conditions in Spent Fuel Transportation Risk Assessment Final 

Report (NRC 2014) based on current models, data, and assumptions. The analysis modeled 

transportation package response to accident conditions, such as impact force and fire, and 

calculated risks considering a range of truck and rail accidents of different severities, including 

those involving no release or loss of shielding, loss of shielding only, or loss of shielding and 

release. That analysis reconfirmed that the radiological impacts from spent fuel transportation 

conducted in compliance with NRC regulations are low. The NRC concluded that the 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-52 September 2014 

regulations for transportation of radioactive material are adequate to protect the public against 

unreasonable risk of exposure to radiation from spent fuel packages in transport (NRC 2014). 

Considering that an away-from-reactor ISFSI would also receive shipments of spent fuel from 

more than one power plant, the radiological and nonradiological impacts from a comparable 

transportation scenario were previously evaluated for the PFSF (NRC 2001). That analysis 

calculated incident-free and accident risks from the shipment of 4,000 spent fuel packages, 

transported over a representative route from Maine to Utah over a 20-year period, and 

concluded the radiological impacts would have been SMALL. The resulting cumulative dose to 

the maximally exposed individual at the end of the 20-year period was 0.022 mSv (2.2 mrem). 

The maximally exposed individual is an individual that is assumed for the purpose of bounding 

to be exposed to the radiation from all shipments. By comparison, NRC regulations at 

10 CFR 20.1301 limit the annual radiation dose to any member of the public resulting from any 

licensed activity to 1 mSv (100 mrem). The PFSF incident-free and accident risk results were 

bounded by or comparable to results in 10 CFR 51.52, Table S–4, or the Final Environmental 

Statement on Transportation of Radioactive Material by Air and Other Modes 15&

Based on the PFSF analysis, the NRC concludes in the present analysis that the additional 

accumulated impacts from transportation of the entire inventory of spent fuel from multiple 

reactors to an away-from-reactor ISFSI would also be minor. 

The operation of the away-from-reactor ISFSI would generate a small amount of LLW (e.g., 

used personal protection equipment) that would result in infrequent waste shipments to a 

licensed disposal facility. The small and infrequent number of shipments and compliance with 

NRC and the DOT packaging and transportation regulations would also limit potential worker 

and public radiological and nonradiological impacts from these waste shipments. Based on this 

analysis, the NRC concludes the impacts on traffic and to public and worker radiological and 

nonradiological safety from LLW shipments resulting from spent fuel storage activities beyond 

the licensed life of reactor operation would be small. 

Based on the factors discussed above, the NRC concludes the impacts on traffic and public and 

worker radiological and nonradiological safety from construction and operation activities for an 

away-from-reactor ISFSI during short-term storage would be SMALL to MODERATE. The 

potential for a MODERATE impact is related to traffic and would depend on the characteristics 

at a particular site. 

5.16.2 Long-Term Storage 

During the long-term storage timeframe, the NRC assumes aging management activities would 

begin to identify stored spent fuel canisters requiring replacement. To evaluate the potential 

 

 By way of comparison, the average annual dose to individuals from natural background radiation (e.g., 

solar radiation and radon) is 3.11 mSv/yr (311 mrem/yr) (NCRP 2009). 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-53 185(*௅

impacts, the NRC assumes a spent fuel DTS would be constructed to execute the replacement 

of canisters and casks. This facility would provide the capability to repackage spent fuel to 

replace damaged canisters or casks identified during regular inspections or aging management 

activities. The longer duration of storage is assumed to require eventual replacement of the 

away-from-reactor ISFSI and DTS facilities during the long-term storage timeframe. These 

replacement activities would generate additional waste material shipments. 

The construction of a DTS would likely involve a smaller temporary workforce than the original 

construction workforce. A previously reviewed proposal to construct a spent fuel transfer facility 

at the Idaho National Engineering Laboratory (NRC 2004) estimated a construction workforce of 

250 workers that would be employed for 2 years. Because the proposed Idaho transfer facility 

was designed to transfer a larger variety wastes than would be handled at an away-from-reactor 

storage facility, the NRC assumes the Idaho facility bounds the impacts of constructing a DTS at 

an away-from-reactor ISFSI. The resulting daily two-way traffic trips from this workforce 

(500 trips) would be comparable to the construction workforce traffic evaluated in Section 5.16.1 

for initial storage facility construction and therefore traffic impacts would range from not 

noticeable to noticeable but not destabilizing. Operation of the dry spent fuel transfer facility 

would involve fewer workers than the construction workforce (60 workers were previously 

projected for operation of the Idaho transfer facility [NRC 2004]), and therefore the commuting 

traffic impacts during the operational period would be minor. 

The operation of the DTS would involve shipment of materials including new canisters and 

would generate a small amount of LLW (e.g., used canisters and used personal protection 

equipment) that would result in infrequent waste shipments to a licensed disposal facility. The 

small and infrequent number of shipments and compliance with NRC and DOT packaging and 

transportation regulations would also limit potential worker and public radiological and 

nonradiological impacts from these waste shipments. Based on this analysis, the NRC 

concludes the impacts on traffic and to public and worker radiological and nonradiological safety 

from LLW shipments resulting from spent fuel storage activities during the long-term storage 

timeframe would be minimal. 

The replacement of the storage facility, DTS, and an increase in repackaging would generate 

additional nonradiological and LLW that would need to be shipped offsite for disposal. As 

described in Section 5.15.2, the estimated quantity of waste from replacement activities would 

be about 315,000 m3 (412,000 yd3) of nonhazardous waste or LLW. Assuming this waste is 

shipped in roll-off containers with a capacity of 15 m3 (20 yd3), the total number of truck 

shipments estimated is 20,600. If replacement were phased over a 5-year period and shipping 

occurred 5 days per week, 16 shipments per day would be needed. The activities would not 

significantly increase the magnitude of traffic generated by storage operations occurring each 

year, and operational transportation impacts would continue to be minor. 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-54 September 2014 

Based on the preceding analysis, the overall transportation impacts of continued operations of 

the away-from-reactor ISFSI during the long-term storage timeframe would be SMALL to 

MODERATE. The potential for a MODERATE impact is related to traffic and would depend on 

the characteristics at a particular site. 

5.16.3 Indefinite Storage 

Assuming no repository becomes available, spent fuel would be stored indefinitely in the awayfrom-reactor ISFSI. Annual transportation activities and associated environmental impacts 

would be similar to that analyzed for storage facility operations and DTS construction and 

operations evaluated in Section 5.16.2. The same operations and maintenance activities 

described in Section 5.16.2 would occur repeatedly because the spent fuel would remain at the 

facility indefinitely. Based on this information, the NRC concludes that the transportation 

impacts during indefinite storage at an away-from-reactor ISFSI would be SMALL to 

MODERATE. The potential for a MODERATE impact is related to traffic and would depend 

on the characteristics at a particular site. 

5.17 Public and Occupational Health 

This section describes public and occupational health impacts caused by the continued storage 

of spent fuel at an away-from-reactor ISFSI. For the purposes of assessing radiological 

impacts, impacts are considered to be SMALL if releases and doses do not exceed dose limits 

prescribed by NRC regulations. This definition of SMALL applies to occupational doses as well 

as to doses to individual members of the public. 

Transportation-related public and occupational health impacts are addressed in Section 5.16. 

5.17.1 Short-Term Storage 

In the PFSF EIS (NRC 2001), the NRC examined human health impacts related to construction 

and operation of an away-from-reactor ISFSI. The analysis addressed in detail the human 

health impacts resulting from construction, operation, and potential accidents at the proposed 

PFSF site. This included nonradiological impacts from construction and operation of the 

proposed PFSF, as well as analysis of the radiological impacts from the spent fuel stored at the 

facility, including potential radiological accidents and their consequences. The type and 

frequency of nonradiological injuries and the types of pollutant emissions at an away-fromreactor ISFSI would be similar to those for the PFSF because of the similarities between the 

facilities. The types of radiological releases from the two facilities would also be similar for the 

same reason. 

The nonradiological health impacts from the construction of a facility of this size include the 

normal hazards associated with construction, such as pollutants (e.g., dust), and fatal and 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-55 185(*௅

nonfatal occupational injuries, such as falls or overexertion. The detailed analysis in the PFSF 

EIS used extensive data from the Bureau of Labor Statistics and the Occupational Safety and 

Health Administration, as well as discussion of the requirements of the Occupational Safety and 

Health Administration’s General Industry Standards (29 CFR Part 1910) and Construction 

Industry Standards (29 CFR Part 1926) to conclude that the nonradiological health impacts 

would have been SMALL. The results were typical for an industrial facility of this size and would 

also apply to a similarly sized away-from-reactor ISFSI at any location. Impacts of 

nonradiological accidents during operations would be even less because of the smaller 

workforce and because activities carried out during operations will generally be lower risk 

activities (e.g., monitoring). Therefore, the NRC concludes that human health impacts from 

construction and operation of the ISFSI would be minor. 

Radiological impacts at an away-from-reactor ISFSI would not occur until operation commenced 

and spent fuel storage casks were brought on site. The detailed analyses in the PFSF EIS used 

the review and evaluation of the PFSF Safety Analysis Report to assess the radiological 

impacts on the general public (i.e., potential dose to a hypothetical maximally exposed individual 

located at the boundary of the proposed facility as well as known nearby residents) and 

estimated dose to occupational personnel. 

The analyses presented in the PFSF EIS (NRC 2001) provide evidence that public and 

occupational doses would have been maintained significantly below the dose limits established 

E\&)53DUWDQG&)53DUW7KH15&DVVXPHVWKDWDQDZD\-from-reactor ISFSI at 

any site has the same spent fuel capacity and a similar physical size; therefore, doses to 

workers and to the public would be similar to those calculated for the PFSF. The NRC 

concludes that public and occupational health impacts would be SMALL. 

5.17.2 Long-Term Storage 

As discussed in the previous section, in the PFSF EIS (NRC 2001) the NRC examined human 

health impacts related to construction and operation of an away-from-reactor ISFSI. The 

analysis addressed in detail the public and occupational human health impacts resulting from 

construction, operation, and potential accidents at the proposed PFSF site. The occupational 

tasks were grouped into four categories consisting of (1) handling (i.e., receiving, transferring, 

and moving) of the spent fuel canisters and casks; (2) security, inspection, and maintenance 

activities; (3) administration and management; and (4) facility construction. The analyses for 

categories 1, 2, and 3 provide a similar analysis for the transferring, handling, and aging 

management activities that would be required for long-term storage of spent fuel being 

addressed by this GEIS. The analyses presented in the PFSF EIS (NRC 2001) provide 

evidence that public and occupational doses would be maintained significantly below the dose 

limits established by 10 CF53DUWDQG&)53DUW,QDGGLWLRQWKHVHUHJXODWLRQVZRXOG

also require a licensed away-from-reactor ISFSI to maintain an ALARA (as low as is reasonably 

achievable) program, which would likely reduce the doses described in the PFSF EIS (NRC 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-56 September 2014 

2001). The NRC assumes that an away-from-reactor ISFSI at any site has the same spent fuel 

capacity and a similar physical size; therefore, doses to workers and to the public would be 

similar to those calculated for the PFSF. The NRC concludes that public and occupational 

health impacts from operations during the long-term storage timeframe would be minor. 

During the long-term storage timeframe, the NRC expects that the licensee would have to build 

a DTS for repackaging of spent fuel canisters. The operation of the DTS would involve 

increased doses to workers and a very small increase in dose levels at the site boundary 

(estimated at roughly 0.8 km [0.5 mi] based on the size of the site). However, the licensee 

would still be required to comply with the dose liPLWVHVWDEOLVKHGE\&)53DUWDQG&)5

Part 20. In addition, the NRC assumes that the casks, pads, canister transfer building, and DTS 

would require replacement during the long-term storage timeframe. The health impacts related 

to these activities would be similar to those for the original construction of the facility. 

Based on the information above, the NRC concludes that the public and occupational health 

impacts of ISFSI operations and construction and demolition activities during the long-term 

timeframe of storage would be SMALL. 

5.17.3 Indefinite Storage 

The public and occupational impacts of continuing to store spent fuel without a repository would 

be similar to those desFULEHGLQ6HFWLRQ7KHW\SHVRIDFWLYLWLHVRSHUDWLRQPDLQWHQDQFH

and replacement) and associated human health impacts would remain the same. The main 

difference is that these activities would be repeated over a longer period of time. Based on this 

information, the NRC concludes that the impacts on human health during long-term storage at 

an away-from-reactor ISFSI would be SMALL. 

5.18 Environmental Impacts of Postulated Accidents 

In this section, the NRC considers the environmental impacts of postulated accidents involving 

continued storage of spent fuel at an away-from-reactor ISFSI. The fuel will be stored in dry 

storage casks licensed by the NRC. As discussed in Chapter 1, the NRC assumes that a DTS 

would be constructed to facilitate canister and cask replacement for long-term and indefinite 

storage. The consequences of accidents for a dry cask storage facility are summarized in 

Sections 4.18.1.2 and 4.18.2.2. The types and consequences of accidents for the away-fromreactor ISFSI are represented by the Chapter 4 results because of the similarities between the 

at-reactor ISFSIs and any away-from-reactor ISFSI (i.e., because the types of casks used to 

store the fuel and the process for licensing those casks are the same). 

This section of the GEIS follows a different format than the rest of the document. Because the 

impacts from accidents are substantially the same across the three timeframes—short-term, 

long-term, and indefinite—the GEIS presents the various accident types only once. 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5- 185(*௅

NRC UHJXODWLRQVDW&)53DUW3/LFHQVLQJ5HTXLUHPHQWVIRUWKH,QGHSHQGHQW6WRUDJHRI

Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater than Class C 

Waste,” require that structures, systems, and components important to safety shall be designed 

to withstand the effects of natural phenomena (such as, earthquakes, tornadoes, hurricanes) 

and human-induced events without loss of capability to perform their safety functions. NRC 

VLWLQJUHJXODWLRQVDW&)53DUW6XESDUW(36LWLQJ Evaluation Factors,” also require 

applicants to consider, among other things, physical characteristics of sites that are necessary 

for safety analysis or that may have an impact on plant design (e.g., the design earthquake). 

These characteristics are to be identified and characterized so that they may be taken into 

consideration when determining the acceptability of the site and design criteria of the facility. 

In the PFSF EIS, the NRC examined environmental impacts from accidents at the proposed 

PFSF. This included two events (i.e., extreme winds and 100 percent air duct blockage) that 

could cause higher-than-normal radiation exposures to workers. In that analysis, the NRC 

postulated that the high-wind event resulted in wind-borne missiles that damaged the concrete 

overpack, which resulted in reduced shielding. The reduced shielding would cause slightly 

higher occupational doses and only negligible increases in radiation doses to a member of the 

public at the boundary of the owner-controlled area. The NRC considered the occupational 

doses that would be received upon transfer of the undamaged canister to a replacement cask. 

The NRC estimated that the dose from transfer operations would result in a collective 

RFFXSDWLRQDOGRVHRISHUVRQ-P6YSHUson-mrem). In the second event involving 

blocked vents, the NRC estimated that the dose to a worker that removes the blockage from the 

vents would be 0.586 mSv (58.6 mrem) to the hands and forearms, and 0.386 mSv (38.6 mrem) 

to the chest, which is below regulatory limits for workers (NRC 2001). Because of the 

similarities between the PFSF and any away-from-reactor ISFSI (i.e., because the types of 

casks used to store the fuel and the process for licensing those casks are the same), the 

results would be similar to those for the PFSF. Therefore, the impacts of these accidents would 

be minor. 

In addition to the credible events described above, for the PFSF the NRC also considered an 

accident, not considered credible, in which a canister leaks. The NRC estimated that the 

resulting total effective dose equivalent resulting from a 30-day leak to an individual at the 

owner-FRQWUROOHGDUHDERXQGDU\ZDVP6YPUHP5DGLDWLRQGRVHVDIWHUWKHILUVW

30 days that result from radioactive material deposited on WKHJURXQGZHUHP6Y\U

 mrem/yr) (NRC 2001). These values are below dose limits in 10 CFR Part 20 and 

10 CFR $VDUHVXOW, the NRC determined that these impacts would have been SMALL 

(NRC 2001). Because of the similarities between the facilities, the results would be similar for 

any away-from-reactor ISFSI and the impacts would be minor.

While the results described from the PFSF EIS are specific to that facility, the PFSF and awayfrom-reactor ISFSI are similar and subject to the same regulations for casks and operations. 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-58 September 2014 

The NRC therefore concludes that these results are representative of the impacts for an awayfrom-reactor ISFSI at a different location. Therefore, the NRC concludes that the impacts of 

postulated accidents would be SMALL during the three storage timeframes. 

5.19 Potential Acts of Sabotage or Terrorism 

Section 4.19 provides background regarding the NRC approach to addressing acts of terrorism 

in relation to dry cask storage. That information is also applicable to an away-from-reactor 

ISFSI. As with the accident impacts analysis in Section 5.18, the impacts from terrorist acts are 

substantially the same across the three timeframes—short-term, long-term, and indefinite—and 

are therefore discussed only once. 

The same safeguardVUHJXODWLRQV&)53DUW6XESDUW+DSSO\WRERWKDQDW-reactor ISFSI 

under a site-specific license and an away-from-reactor ISFSI. Safeguard requirements at atreactor specifically licensed ISFSIs are described in Section 4.19.2 of this GEIS. In that section, 

the NRC concluded that both the probability and consequences of a successful attack on an atreactor ISFSI are low and, therefore, the environmental risk is SMALL. Therefore, the NRC 

concludes that the results from Section 4.19.2 would also be applicable to an away-from-reactor 

ISFSI, and the associated impacts would be SMALL during the three storage timeframes. 

5.20 Summary 

The impact levels determined by the NRC in the previous sections for away-from-reactor dry 

cask storage of spent fuel are summarized in Table 5-1. For most impact areas, the impact 

levels are denoted as SMALL, MODERATE, and LARGE as a measure of their expected 

adverse environmental impacts. In other impact areas, the impact levels are denoted according 

to the types of findings required under applicable regulatory or statutory schemes (e.g., 

“disproportionately high and adverse” for environmental justice impacts). 

For a number of the resource areas, the impact determinations for all three timeframes are 

SMALL. For air quality and terrestrial ecology, there is the potential for a MODERATE impact 

during the construction of the ISFSI. For environmental justice, special status species and 

habitats, and historic and cultural resources, the results are highly site-specific. While it is 

possible the ISFSI could be built and operated with no noticeable impacts on these resources, a 

definitive conclusion cannot be drawn in this GEIS. For socioeconomics (taxes), aesthetics, and 

traffic, there are impacts that could be greater than SMALL that will continue throughout the 

existence of the ISFSI. The tax impacts are beneficial in nature. Finally, there is the potential 

for a MODERATE impact from the disposal of nonradioactive waste in the indefinite timeframe if 

that waste exceeds the capacity of nearby landfills. 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-59 185(*௅

Table 5-1. Summary of Environmental Impacts of Continued Away-from-Reactor Storage 

Resource Area Short-Term Storage Long-Term Storage Indefinite Storage 

Land Use SMALL SMALL SMALL 

Socioeconomics SMALL (adverse) to 

LARGE (beneficial) 

SMALL (adverse) to 

LARGE (beneficial) 

SMALL (adverse) to 

LARGE (beneficial) 

Environmental Justice Disproportionately high and adverse impacts are not expected 

Air Quality SMALL to MODERATE SMALL SMALL 

Climate Change SMALL SMALL SMALL 

Geology and Soils SMALL SMALL SMALL 

Surface-Water 

Quality SMALL SMALL SMALL 

Consumptive Use SMALL SMALL SMALL 

Groundwater 

Quality SMALL SMALL SMALL 

Consumptive Use SMALL SMALL SMALL 

Terrestrial Resources SMALL to MODERATE SMALL SMALL 

Aquatic Ecology SMALL SMALL SMALL 

Special Status Species 

and Habitats 

Impacts for Federally listed threatened and endangered species and EFH 

would be determined as part of the consultations for the ESA and the 

Magnuson–Stevens Fishery Conservation and Management Act 

Historic and Cultural 

Resources 

SMALL to LARGE SMALL to LARGE SMALL to LARGE 

Noise SMALL SMALL SMALL 

Aesthetics SMALL to MODERATE SMALL to MODERATE SMALL to MODERATE 

Waste Management 

LLW SMALL SMALL SMALL 

Mixed Waste SMALL SMALL SMALL 

Nonradioactive Waste SMALL SMALL SMALL to MODERATE 

Transportation 

Traffic SMALL to 

MODERATE 

SMALL to MODERATE SMALL to MODERATE 

Health SMALL SMALL SMALL 

Public and Occupational 

Health 

SMALL SMALL SMALL 

Accidents SMALL SMALL SMALL 

Sabotage or Terrorism SMALL SMALL SMALL 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-60 September 2014 

5.21 References 

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

Protection Against Radiation.” Washington, D.C. 

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

Washington, D.C. 

&)53DUWCode of Federal Regulations, Title 10, Energy, 3DUW33DFNDJing and 

Transportation of Radioactive Material.” Washington, D.C.

&)53DUWCode of Federal Regulations, Title 10, Energy, 3DUW3/LFHQVLQJ

Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive 

Waste, and Reactor-Related Greater Than Class C Waste.” Washington, D.C. 

&)53DUWCode of Federal Regulations, Title 10, Energy, 3DUW3, “Physical Protection of 

Plants and Materials.” Washington, D.C. 

29 CFR Part 1910. Code of Federal Regulations, Title 29, Labor, Part 1910, “Occupational 

Safety and Health Standards.” Washington, D.C. 

29 CFR Part 1926. Code of Federal Regulations, Title 29, Labor, Part 1926, “Safety and Health 

Regulations for Construction.” Washington, D.C. 

36 CFR Part 60. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

Part 60, “National Register of Historic Places.” Washington, D.C. 

36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

Part 800, “Protection of Historic Properties.” Washington, D.C. 

40 CFR Part 51. Code of Federal Regulations, Title 40, Protection of the Environment, Part 51, 

“Requirements for Preparation, Adoptions, and Submittal of Implementation Plans.” 

Washington, D.C. 

40 CFR Part 52. Code of Federal Regulations, Title 40, Protection of the Environment, Part 52, 

“Approval and Promulgation of Implementation Plans.” Washington, D.C. 

40 CFR Part 93. Code of Federal Regulations, Title 40, Protection of the Environment, Part 93, 

“Determining Conformity of Federal Actions to State or Federal Implementation Plans.” 

Washington, D.C. 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-61 185(*௅

&)53DUWCode of Federal Regulations, Title 49, Transportation, 3DUW3Hazardous 

Materials Program Procedures.” Washington, D.C. 

&)53DUWV–180. Code of Federal Regulations, Title 49, Transportation3DUWVí180, 

“Hazardous Materials Regulations.” Washington, D.C. 

49 CFR Parts 390–Code of Federal Regulations, Title 49, Transportation, Parts 390–

“Federal Motor Carrier Safety Regulations.” Washington, D.C. 

50 CFR Part 402. Code of Federal Regulations, Title 50, Wildlife and Fisheries. “Interagency 

Cooperation—(QGDQJHUHG6SHFLHV$FWRIDV$PHQGHG ́Washington, D.C. 

50 CFR Part 600. Code of Federal Regulations, Title 50, Wildlife and Fisheries. “MagnusonStevens Act Provisions.” Washington, D.C. 

69 FR 52040. August 24, 2004. “Policy Statement on the Treatment of Environmental Justice 

Matters in NRC Regulatory and Licensing Actions.” Federal Register, U.S. Nuclear Regulatory 

Commission, Washington, D.C. 

$(&86$WRPLF(QHUJ\&RPPLVVLRQ. Environmental Survey of Transportation of 

Radioactive Materials to and From Nuclear Power Plants. WASH–1238, Washington, D.C. 

Available at http://www.osti.gov/energycitations/product.biblio.jsp?osti_id=4569134.

Bald and Golden Eagle Protection Act of 1940, as amended. 16 USC 668-668d et seq. 

Clean Air Act, as amended86&et seq.

Clean Water Act (See Federal Water Pollution Control Act RI). 

Coastal Zone Management Act of , as amended. 16 USC 1451 et seq. 

DOE (U.S. Department of Energy). 2002. Final Environmental Impact Statement for a Geologic 

Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive Waste at Yucca 

Mountain, Nye County, Nevada. DOE/EIS–0250, Office of Civilian Radioactive Waste 

Management, Washington, D.C. Accession No. 0/$. 

DOE (U.S. Department of Energy). 2008. Final Supplemental Environmental Impact Statement 

for a Geologic Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive 

Waste at Yucca Mountain, Nye County, Nevada. DOE/EIS–0250F–S1, Washington, D.C. 

$FFHVVLRQ1R0/
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-62 September 2014 

DOE (U.S. Department of Energy). 2013. Strategy for the Management and Disposal of Used 

Nuclear Fuel and High-Level Radioactive Waste. Washington, D.C. Accession 

No. ML13011A138. 

Donnell, J. 1998. Response to RAI LA 1-6 Private Fuel Storage Facility Docket No. 72-22/TAC 

No. L22462 Private Fuel Storage LLC. Private Fuel Storage LLC, La Crosse, Wisconsin. 

Accession No. ML010260218. 

Endangered Species Act (ESA), as amended. 16 USC 1531 et seq. 

(3$86(QYLURQPHQWDO3URWHFWLRQ$JHQF\Information on Levels of Environmental 

Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety, 

EPA550/9––5HVHDUFK7ULDQJOH3DUN1RUWK&DUROLQD$FFHVVLRQ1R0/

EPA (U.S. Environmental Protection Agency). 2013a. "Clean Energy: Calculations and 

References." Washington, D.C. $FFHVVLRQ1R0/$

EPA (U.S. Environmental Protection Agency). 2013b. Inventory of U.S. Greenhouse Gas 

Emissions and Sinks: 1990–2011. EPA 430-R-13-001, Washington, D.C. Accession No. 

0/$

EPA (U.S. Environmental Protection Agency). 2013c. Municipal Solid Waste in the United 

States: 2011 Facts and Figures. EPA 530-R-13-001, Washington, D.C. Available at 

KWWSZZZHSDJRYRVZQRQKD]PXQLFLSDOSXEV06:FKDUDFWHUL]DWLRQBIQOBBBUSWSGI.

)HGHUDO:DWHU3ROOXWLRQ&RQWURO$FWRIDVDPHQGHGDOVRUHIHUUHGWRDVWKH&OHDQ:DWHU

Act). 33 USC 1251 et seq.

Fish and Wildlife Coordination Act of 1934, as amended. 16 USC 661-H et seq.

Foster Wheeler (Foster Wheeler Environmental Corporation). 2003. Letter from D.I. Rogers, Jr. 

to NRC, dated November 14, 2003, regarding “Idaho Spent Fuel (ISF) Facility Submittal of 

Amendment WR/LFHQVH$SSOLFDWLRQ'RFNHW1R7$&1R. L23389.” Morris Plains, New 

Jersey. Accession No. ML033240044. 

FWS/NMFS (Fish and Wildlife Service/National Marine Fisheries Service). 1998. Endangered 

Species Act Consultation Handbook: Procedures for Conducting Consultation and Conference 

Activities Under Section 7 of the Endangered Species Act. Washington, D.C. Accession No. 

ML12325A215. 

LES (Louisiana Energy Services, LLC). 1998. Letter from R.J. Jensen to S.A. Jackson, dated 

April 22, 1998, 3,QWKH0DWWHURI/RXLVLDQD(QHUJ\6HUYLFHV'RFNHW1R––ML.” ADAMS 

Legacy Library Accession No. 9804240190. 
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-63 185(*௅

Magnuson-Stevens Fishery Conservation and Management Act RI, as amended. 16 USC 

1801 et seq. 

Marine Mammal Protection Act of , as amended. 16 USC 1361 et seq. 

Migratory Bird Treaty Act of 1918, as amended86&- et seq. 

National Environmental Policy Act of 1969 (NEPA), as amended. USC 4321 et seq. 

National Historic Preservation Act (NHPA), as amended86&et seq. 

NCRP (National Council on Radiation Protection and Measurements). 2009. Ionizing Radiation 

Exposure of the Population of the United States. Report 160, Bethesda, Maryland. 

15&861XFOHDU5HJXODWRU\&RPPLVVLRQFinal Environmental Statement on 

Transportation of Radioactive Material by Air and Other Modes. NUREG–:DVKLQJWRQ

D.C. Accession No. ML12192A283. 

NRC (U.S. Nuclear Regulatory Commission). 1998. In the Matter of Louisiana Energy 

Services, L.P. (Claiborne Enrichment Center). CLI–98–15&:DVKLQJWRQ'&

Accession No. ML020560604. 

NRC (U.S. Nuclear Regulatory Commission). 2001. Final Environmental Impact Statement for 

the Construction and Operation of an Independent Spent Fuel Storage Installation on the 

Reservation of the Skull Valley Band of Goshute Indians and the Related Transportation Facility 

in Tooele County, Utah. NUREG–9ROXPH Washington, D.C. Accession 

No. 0/. 

NRC (U.S. Nuclear Regulatory Commission). 2002. Final Generic Environmental Impact 

Statement for Decommissioning of Nuclear Facilities, Supplement 1 Regarding the 

Decommissioning of Nuclear Power Reactors. NUREG-0586, Volumes 1 and 2, Washington, 

'&$FFHVVLRQ1RV0/0/

NRC (U.S. Nuclear Regulatory Commission). 2004. Environmental Impact Statement for the 

Proposed Idaho Spent Fuel Facility at the Idaho National Engineering and Environmental 

Laboratory in Butte County, Idaho. NUREG–:DVKLQJWRQ'&$FFHVVLRQ

No. ML040490135. 

NRC (U.S. Nuclear Regulatory Commission). 2006a. Letter from W.H. Ruland to J.D. Parkyn 

dated February 21, 2006, regarding “Issuance of Materials License No. SNM–2513 for the 

Private Fuel Storage Facility (TAC No. L23821).” Washington, D.C. Accession 

No. ML060450412. 
Environmental Impacts of Away-From-Reactor Storage 

185(*௅ 5-64 September 2014 

NRC (U.S. Nuclear Regulatory Commission). 2006b. Consolidated Decommissioning 

Guidance: Decommissioning Process for Materials Licensees. NUREG–5HYLVLRQ

Washington, D.C. Accession No. ML063000243. 

NRC (U.S. Nuclear Regulatory Commission). 2006c. Final Environmental Impact Statement for 

an Early Site Permit (ESP) at the North Anna ESP Site. NUREG–1811, Volume 1, 

Washington, D.C. Accession No. ML063480261. 

NRC (U.S. Nuclear Regulatory Commission). 2008a. U.S. Nuclear Regulatory Commission 

Staff’s Adoption Determination Report for the U.S. Department of Energy’s Environmental 

Impact Statements for the Proposed Geologic Repository at Yucca Mountain. Washington, D.C. 

Accession No. ML082420342. 

NRC (U.S. Nuclear Regulatory Commission). 2008b. Final Environmental Impact Statement 

for an Early Site Permit (ESP) at the Vogtle Electric Generating Plant Site. NUREG–

Volume 1, Washington, D.C. Accession No. ML082240145. 

NRC (U.S. Nuclear Regulatory Commission). 2011a. Final Environmental Impact Statement for 

the Combined License (COL) for Calvert Cliffs Nuclear Power Plant Unit 3. NUREG–1936, 

Volumes DQG:DVKLQJWRQ'&$FFHVVLRQ1RV0/$0/$

NRC (U.S. Nuclear Regulatory Commission). 2011b. Final Environmental Impact Statement 

for the Combined Licenses (COLs) for South Texas Project Electric Generating Station Units 3 

and 4. NUREG–:DVKLQJWRQ'&$FFHVVLRQ1R0/$

NRC (U.S. Nuclear Regulatory Commission). 2011c. Final Environmental Impact Statement for 

the Combined Licenses (COLs) for Virgil C. Summer Nuclear Station, Units 2 and 3. 

NUREG–1939, Volumes 1 and 2, Washington, D.C. Accession Nos. ML11098A044, 

0/$

NRC (U.S. Nuclear Regulatory Commission). 2011d. Final Environmental Impact Statement for 

Combined Licenses (COLs) for Comanche Peak Nuclear Power Plant Units 3 and 4. 

NUREG–1943, Volumes 1 and 2, Washington, D.C. Accession Nos. ML11131A001, 

ML11131A002. 

NRC (U.S. Nuclear Regulatory Commission). 2012. Environmental Impact Statement for 

Combined Licenses (COLs) for Levy Nuclear Plant Units 1 and 2—Final Report. NUREG–1941, 

Volume 1, Washington, D.C. Accession No. ML12100A063. 

NRC (U.S. Nuclear Regulatory Commission). 2013a. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants. NUREG–5HYLVLRQ:DVKLQJWRQ'&

$FFHVVLRQ1R0/$
Environmental Impacts of Away-From-Reactor Storage 

September 2014 5-65 185(*௅

NRC (U.S. Nuclear Regulatory Commission). 2013b. Attachment 1—Staff Guidance for 

Greenhouse Gas and Climate Change Impacts for New Reactor Environmental Impact 

Statements. COL/ESP-ISG-026, Washington, D.C. Accession No. ML12326A811. 

NRC (U.S. Nuclear Regulatory Commission). 2013c. Final Environmental Statement for the 

Combined License (COL) for Enrico Fermi Unit 3. NUREG–2105, Volumes 1 and 2, 

Washington, D.C. Accession Nos0/$, 0/$. 

NRC (U.S. Nuclear Regulatory Commission). 2014. Spent Fuel Transportation Risk 

Assessment: Final Report. NUREG–2125, Washington D.C. Accession No. ML14031A323. 

PFS (Private Fuel Storage, LLC.). 2001. Environmental Report, Private Fuel Storage Facility, 

Skull Valley Indian Reservation, Tooele County, Utah (Revision 14). La Crosse, Wisconsin. 

PFS (Private Fuel Storage, LLC.). 2012. Letter from R.M. Palmberg to NRC dated 

December 20, 2012, regarding “Termination of NRC License No. SNM–25 13 for Private Fuel 

Storage LLC.” La Crosse, Wisconsin. Accession No. ML12356A063. 

Sprung, J.L., D.J. Ammerman, N.L. Breivik, R.J. Dukart, F.L. Kanipe, J.A. Koski, G.S. Mills, 

K.S. Neuhauser, H.D. Radloff, R.F. Weiner, and H.R. Yoshimura. 2000. Reexamination of 

Spent Fuel Shipment Risk Estimates. NUREG/CR–6DQGLD1DWLRQDO/DERUDWRU\

Albuquerque, New Mexico. Accession No. ML003698324.
 
September 2014 6-1 185(*௅

6.0 Cumulative Impacts 

The Council on Environmental Quality’s (CEQ’s) regulations implementing the National 

Environmental Policy Act of 1969, as amended (NEPA), define a cumulative impact as “... the 

impact on the environment that results from the incremental impact of [an] action when added to 

other past, present, and reasonably foreseeable future actions, regardless of what agency 

(Federal or non-Federal) or person undertakes such other actions” (Title 40 of the Code of 

Federal Regulations >40 &)5@&XPXODWLYHLPSacts can result from individually 

PLQRUEXWFROOHFWLYHO\VLJQLILFDQWDFWLRQVWDNLQJSODFHRYHUDSHULRGRIWLPH,WLVSRVVLEOHWKDW

an impact that may be SMALL by itself could result in a MODERATE or LARGE cumulative 

impact when considered in combination with the impacts of other actions on the affected 

UHVRXUFH)RUH[DPSOHLIDUHVRXUFHLVUHJLRQDOO\GHFOLQLQJRULPSHULOHGHYHQD60$//

individual impact could be substantial if it contributes to or accelerates the overall resource 

GHFOLQH

6.1 Methodology for Assessing Cumulative Impacts 

The cumulative impacts assessment in this Generic Environmental Impact Statement for 

Continued Storage of Spent Nuclear Fuel (*(,6) H[DPLQHVWKHLQFUHPHQWDOLPSDFWRIFRQWLQXHG

storage on each resource area in combination with other past, present, and reasonably 

IRUHVHHDEOHDFWLRQV7KHJHQHUDODSSURDFKIRUDVVHVVLQJFXPXODWLYHLPSDFWVLVEDVHGRQ

principles and guidance described in the CEQ’s Considering Cumulative Effects under the 

National Environmental Policy Act (CE4,QDGGLWLRQWKH861XFOHDU5HJXODWRU\

&RPPLVVLRQ15&UHYLHZHGWKHUHOHYDQWSRUWLRQVRIWKH86(QYLURQPHQWDO3URWHFWLRQ

Agency’s (EPA’s) Consideration of Cumulative Impacts in EPA Review of NEPA Documents

(EPA 1999) and The NEPA Task Force Report to the Council on Environmental Quality on 

Modernizing NEPA Implementation &(4%DVHGRQWKHUHYLHZRIWKHVHGRFXPHQWVDQG

15&¶VUHJXODWLRQVLPSOHPHQWLQJ1(3$LQ&)53DUWWKH15&GHYHORSHGWKHIROORZLQJ

methodology for assessing cumulative impacts in this *(,6: 

 During the scoping and consultation phases of the environmental review, the NRC identified 

potential cumulative impact issues associated with the continued storage of spent nuclear 

IXHOVSHQWIXHO7KH15&LQFOXGHGRWKHUDFWLRQVDQGLVVXHVODWHUDVWKH\ZHUHLGHQWLILHG

 The individual resources, ecosystems, and human communities identified in the affected 

environment sections of Chapter 3 become the resource parameters analyzed in this 

DQDO\VLV6LPLODUO\GLUHFWDQGLQGLUHFWLPSDFWVLGHQWLILHGLQ&KDSWHUVDQGIRUPWKHEDVLV

IRUWKHDQDO\VLVLQWKLVFKDSWHU

 The spatial boundaries for the cumulative impact assessment are unique to each resource 

area and defined in resource-VSHFLILFDQDO\VHVLQ6HFWLRQ(DFKJHRJUDSKLFDUHDRI
&XPXODWLYH,PSDFWV

185(*௅ 6-2 September 2014 

DQDO\VLVLQFOXGHVWKHDUHDVXUURXQGLQJDFRQWLQXHGVWRUDJHVLWHDQGH[WHQGVWRZKHUHWKH

resource would be affected by continued storage and could have overlapping impacts with 

RWKHUSDVWSUHVHQWDQGUHDVRQDEO\IRUHVHHDEOHIXWXUHDFWLRQV

 7KHWHPSRUDOERXQGDU\LHWKHWLPHIUDPHIRUWKLVDQDO\VLVLVGHILQHGLQ6HFWLRQ7KH

WLPHIUDPHRIWKHFXPXODWLYHLPSDFWVDQDO\VLVH[WHQGVIURPthe past history of impacts on 

each resource through decommissioning of the spent fuel pool, at-reactor independent 

VSHQWIXHOVWRUDJHLQVWDOODWLRQ,6)6,DQGDZD\-from-UHDFWRU,6)6,UHIHUUHGWRDVVWRUDJH

IDFLOLWLHV7KHWHPSRUDOERXQGDU\LVWKHVDPH for all resource-specific analyses below 

6HFWLRQ

 The NRC evaluated cumulative impacts by considering the incremental impacts from 

continued storage in combination with other past, present, and reasonably foreseeable 

IXWXUHDFWLRQV7KHGHVFULSWLRQ of the affected environment in Chapter 3 for at-reactor 

VWRUDJHIDFLOLWLHVDQG&KDSWHUIRUDZD\-from-UHDFWRU,6)6,VVHUYHVDVWKHbaseline for the 

FXPXODWLYHLPSDFWVDQDO\VLVLQFOXGLQJWKHHIIHFWVRISDVWDFWLRQV7KHincremental impacts

related to continued storage are described and characterized in Chapter 4 for at-reactor 

VWRUDJHIDFLOLWLHVDQG&KDSWHUIRUDZD\-from-UHDFWRUVWRUDJHIDFLOLWLHV7KH15&LGHQWLILHG

past, present, and reasonably foreseeable future actions7KHVHDFWLRQVLQFOXGHSURMects 

and activities that could impact resources, ecosystems, or human communities within the 

GHILQHGVSDWLDODQGWHPSRUDOERXQGV6HFWLRQGHVFULEHVWKHJHQHUDOQDWLRQDOUHJLRQDO

and local trends and activities (general trends) that occur near at-reactor and away-fromUHDFWRUVWRUDJHIDFLOLWLHVVXFKDVXUEDQL]DWLRQRUHQHUJ\SURGXFWLRQ7KHVHJHQHUDOWUHQGV

are the current and likely future trends in general types of activities that occur near storage 

facilities6HFWLRQGHVFULEHVRWKHU15&-regulated or spent fuel-related activities that 

may occur during the period of continued storage, such as decommissioning of the nuclear 

SRZHUSODQW

 Cumulative impacts fRUHDFKUHVRXUFHDUHDDUHDVVHVVHGLQ6HFWLRQ2YHUODSSLQJRU

cumulative impacts could occur if the action or general trend affects the same resource, 

ecosystem, or human community as those affected by the continued storage of spent fuel 

within the deILQHGWHPSRUDODQGVSDWLDOERXQGV%HFDXVHRIWKHYDULRXVUHVRXUFH

SDUDPHWHUVHJDQHFRV\VWHPYHUVXVDKXPDQFRPPXQLW\DQGWKHGLIIHUHQWVSDWLDO

ERXQGDULHVHJDULYHUYHUVXVDFRXQW\IRUHDFKUHVRXUFHDUHDVRPHDFWLYLWLHVRUJHQHUDO

trends affeFWDVXEVHWRIWKHUHVRXUFHDUHDVGLVFXVVHGEHORZ7KHOHYHORIGHWDLOGHVFULELQJ

WKHYDULRXVFXPXODWLYHLPSDFWVLVFRPPHQVXUDWHZLWKWKHLPSDFWVLJQLILFDQFH

 Conclusions for resource and systems analyses in these sections use the same three-level 

classification scheme—SMALL, MODERATE, or LARGE—that was used for the at-reactor 

and away-from-UHDFWRUVWRUDJHIDFLOLW\DQDO\VHVDVGHILQHGLQ&KDSWHU)RUUHVRXUFH

areas in which the cumulative impact could range based on the site-specific conditions, the 

below analyses describe the general conditions for which a SMALL, MODERATE, or 
&XPXODWLYH,PSDFWV

September 2014 6-3 185(*௅

/$5*(LPSDFWZRXOGRFFXU$FRQFOXVLRQLVSURYLGHGIRUDW-reactor and away-from-reactor 

sites and for all three timeframes (short-term, long-term, and indefinite storage) discussed in 

Chapters DQG

 7KHDQDO\VLVLQWKLVFKDSWHUDVLQWKHUHVWRIWKLV*(,6SURYLGHVDJHQHULFDQDO\VLVWKDWZLOO

ultimately be used to support NRC’s decision regarding a request to license or relicense a 

reactor or site-VSHFLILF,6)6,$VLWH-specific review is required before the NRC provides a 

OLFHQVHIRUDQ\UHDFWRURU,6)6, for which an application for a specific license has been 

submitted7KHUHIRUHWKHDQDO\VLVLQWKLVFKDSWHUZRXOGEHFRQVLGHUHGDORQJZLWKWKHVLWHspecific analysis for a VSHFLILFOLFHQVH

6.2 Spatial and Temporal Bounds of the Cumulative Impacts 

Assessment 

The spatial boundaries for the cumulative impact assessment are resource-specific and 

identified within each resource-VSHFLILFDQDO\VLVEHORZLQ6HFWLRQ7KH15&VHWWhe spatial 

boundaries to encompass the geographic area of the affected resources and the distances at 

ZKLFKLPSDFWVDVVRFLDWHGZLWKSDVWSUHVHQWDQGUHDVRQDEO\IRUHVHHDEOHDFWLRQVPD\RFFXU

,QDGGLWLRQWRLPSDFWVDFFXPXODWLQJRYHUDJHRJUDSKLFDUHDLPSacts can also accumulate or 

GHYHORSRYHUWLPH7KHUHIRUHWKHFXPXODWLYHLPSDFWVDVVHVVPHQWORRNVDFURVVDVSHFLILF

WLPHOLQHWKDWLQFOXGHVWKHSDVWSUHVHQWDQGUHDVRQDEO\IRUHVHHDEOHIXWXUH&(4

The temporal boundary for this analysis includes activities that could occur through 

decommissioning of at-reactor or away-from-UHDFWRUVWRUDJHIDFLOLWLHV

7KHVSDWLDODQGWHPSRUDOERXQGDULHVGHVFULEHWKHPD[LPXPGLVWDQFHRUWLPHFRQVLGHUHGLQWKH

DQDO\VLV+RZHYHUHYHQLIDSURMHFWIDOOVZLWKLQWKHVHoverall temporal and spatial bounds, the 

effects many not overlap in space and time with the effects of continued storage, especially for 

SURMHFWVZLWKVKRUW-WHUPLPSDFWV)RUH[DPSOHFRQVWUXFWLQJDVPDOOGRFNDORQJDVKRUHOLQH

would have temporary impacWVRQDTXDWLFUHVRXUFHV8QOHVVWKHGRFNZDVFRQVWUXFWHGGXULQJ

the period of continued storage, the impacts would not likely overlap with potential impacts from 

FRQWLQXHGVWRUDJH2QWKHRWKHUKDQGFRQVWUXFWLRQDQGRSHUDWLRQRIDGDPFRXOGKDYHORQJteUPLPSDFWVWKDWODVWVHYHUDOGHFDGHV7KHUHIRUHWKHLPSDFWVFRXOGEHRYHUODSSLQJZLWK

FRQWLQXHGVWRUDJHHYHQLIGDPRSHUDWLRQVFHDVHGVHYHUDO\HDUVEHIRUHFRQWLQXHGVWRUDJH

Resource-VSHFLILFDQDO\VHVLQ6HFWLRQRQO\GHVFULEHDFWLYLWLHVWKDWZRXOGoverlap in both 

VSDFHDQGWLPHZLWKSRWHQWLDOLPSDFWVIURPFRQWLQXHGVWRUDJH

6.3 Past, Present, and Reasonably Foreseeable Actions 

This section describes the NRC’s methodology for identifying past, present, and reasonably 

IRUHVHHDEOHDFWLRQV$VGHVFULEHGLQ &(4JXLGDQFH&(4LGHQWLI\LQJUHDVRQDEO\
&XPXODWLYH,PSDFWV

185(*௅ 6-4 September 2014 

IRUHVHHDEOHIXWXUHDFWLRQVLVDFULWLFDOFRPSRQHQWRIDFXPXODWLYHLPSDFWVDQDO\VLV+RZHYHU

the CEQ also recognizes that agencies should not engage in speculation in an effort to identify 

all actions that FRXOGFRQWULEXWHWRRYHUDOOSRWHQWLDOFXPXODWLYHHIIHFWV*LYHQWKHQDWLRQDOVFRSH

RIWKH86QXFOHDULQGXVWU\DQGWKHORQJWLPHIUDPHVWKDWDUHXQGHUFRQVLGHUDWLRQLQWKLV*(,6

as described in Chapter 1, it is not practical to consider all potential pubOLFDQGSULYDWHSURMHFWV

For this reason, reasonably foreseeable future actions that will be considered in the cumulative 

effects analysis include the following: 

x general trends or activities that the NRC has previously determined to occur near at-reactor 

and away-from-reactor storage facilities, 

x programmatic actions for which Federal agencies have prepared and published NEPA 

documents, 

x programs and policies enabled by legislation, and 

x NRC activities or connected actions that could occur at or beyond the storage site during 

continued storage

The following sections summarize the past, present, and reasonably foreseeable actions 

FRQVLGHUHGLQWKLVFXPXODWLYHDQDO\VLVLQFOXGLQJERWKJHQHUDOWUHQGVLQ6HFWLRQDQGRWKHU

NRC-regulated or spent fuel-relateGDFWLYLWLHVLQ6HFWLRQ

6.3.1 General Trends and Activities 

%HFDXVHRIWKHXQFHUWDLQW\RIVSHFLILFDFWLYLWLHVWKDWPD\RFFXURYHUYHU\ORQJWLPHSHULRGVLQWKH

future, the NRC considered the general types of activities that occur near at-reactor and awayfrom-UHDFWRUVWRUDJHIDFLOLWLHVDQGWKHOLNHO\IXWXUHWUHQGVRIWKHVHDFWLYLWLHV7KLVDSSURDFK

IROORZV&(4JXLGDQFHWKDWUHFRPPHQGVORRNLQJDWWKHWUHQGVRIYDULRXVDFWLRQVWR

analyze the potential activities that could occur through the reasonably foreseeable future, 

HVSHFLDOO\LQVLWXDWLRQVZLWKKLJKXQFHUWDLQW\ The NRC notes that the uncertainty related to the 

H[WHQWDQGLQWHQVLW\RIUHDVRQDEO\IRUHVHHDEOHDFWLYLWLHVJHQHUDOO\LQFUHDVHVZLWKWLPHLQWRWKH

IXWXUH

To determine typical activities that occur near at-reactor and away-from-reactor storage 

facilities, the NRC reviewed the cumulative impacts evaluations in NUREGíGeneric 

Environmental Impact Statement for License Renewal of Nuclear Plants, Revision 1 (License 

5HQHZDO*(,615&013a), site-VSHFLILF(,6VIRUQHZDQGRSHUDWLQJUHDFWRUVHJ15&

2011a–e, 2012a, 2013b,c), and site-specific at-reactor and away-from-UHDFWRU,6)6,

HQYLURQPHQWDODVVHVVPHQWV($VRUHQYLURQPHQWDOLPSDFWVWDWHPHQWV(,6VHJ15&

D7KH15&DOVo reviewed licensing documents for power reactors because at-reactor 

storage facilities are located at the reactor site, and therefore, at-reactor storage facilities are 

surrounded by the same activities as those identified in site-VSHFLILF(,6VIRUQHZUHactors, 
&XPXODWLYH,PSDFWV

September 2014 6- 185(*௅

VXSSOHPHQWDO(,6VIRUOLFHQVHUHQHZDORIRSHUDWLQJUHDFWRUVDQGLQWKH/LFHQVH5HQHZDO*(,6

IRURSHUDWLQJUHDFWRUVTable 6-1 GHVFULEHVWKHW\SHVRIDFWLYLWLHVWKDWWKH15&LGHQWLILHG

The NRC also evaluated the reasonably foreseeable trend for each activity, primarily using 

SURMHFWLRQVSUHSDUHGE\)HGHUDO6WDWHDQGORFDODJHQFLHV,QVRPHFDVHVWKH15&

FRQVLGHUHGSURMHFWLRQVHVWLPDWHGE\LQGXVWU\-based policy organizations, especially for activities 

ZLWKOLPLWHG)HGHUDO6WDWHDQGORFDORYHUVLJKW7UHQGVLQDFWLYLWLHVIDFLOLWLHVRUSURFHVVHVDUH

based on proMHFWLRQVDVIDULQWRWKHIXWXUHDVUHDVRQDEO\IRUHVHHDEOHIRUWKHSDUWLFXODULQGXVWU\

RUDFWLYLW\)RUPDQ\DFWLYLWLHVWKHDYDLODEOHSURMHFWLRQVFRYHUVKRUWHUWLPHSHULRGVRQWKHRUGHU

RIWR \HDUV7KH15&TXDOLWDWLYHO\XVHGWKHVHSURMHFWLRQVWRestimate reasonable trends 

GXULQJFRQWLQXHGVWRUDJH:KLOHWKH15&FRQVLGHUVWKLVDUHDVRQDEOHapproach based on the 

best available data, the NRC also notes that applying the trends beyond the time period 

specified for each activity introduces DGGLWLRQDOXQFHUWDLQW\,QDGGLWLRQWKH15&DVVXPHGWKDW

local, State, and Federal authorities would continue to have oversight over the construction and 

operation of many of the activities described in Table 6-1

Table 6-1*HQHUDO7UHQGVDQG+XPDQ$FWLYLWLHV2FFXUULQJDWRUQHDU6WRUDJH)DFLOLWLHV

Activity or Stressor Reasonably Foreseeable Future Trend 

Increased Energy Demand 

 Overall energy demand Total energy use will increase by 10% from 2011 to 2040 

(,$D)RUDW-reactor storage facilities, shutdown of the 

reactor will likely require replacement power, which may be 

built at the reactor site depending on spatial and water-use 

requirements, power needs, and the business plans of the 

RSHUDWRU15&D

 Overall electricity consumption ,QFUHDVHGHOHFWULFLW\FRQVXPSWLRQDWDQDYHUDJHDQQXDOUDWH

RI(,$D

 New and continued construction 

and operation of gas-fired plants 

$ERXWDQQXDOLQFUHDVHIURPWR(,$D

 New and continued construction 

and operation of coal-fired plants 

$ERXWDQQXDOLQFUHDVHIURPWR(,$D

 New and continued construction 

and operation of nuclear plants 

$ERXWDQQXDOLQFUHDVHIURPWR(,$D

 Continued operation of oil-fired 

plants 

$ERXWDQQXDOLQFUHDVHIURPWR(,$D

 New and continued construction 

and operation of wind farms 

$ERXWDQQXDOLQFUHDVHIURPWR(,$E

 New and continued construction 

and operation of conventional 

hydropower plants 

$ERXWDQQXDOLQFUHDVHIURPWR(,$E

 New and continued construction 

and operation of solar plants 

About WRDQQXDOLQFUHDVHIURPWR

(,$ E
&XPXODWLYH,PSDFWV

185(*௅ 6-6 September 2014 

Table 6-1 *HQHUDO7UHQGVDQG+XPDQ$FWLYLWLHV2FFXUULQJDWRUQHDU6WRUDJH)DFLOLWLHV

(cont’d)

Activity or Stressor Reasonably Foreseeable Future Trend 

 Construction and operation of 

transmission lines 

About 29,000 additional circuit miles of high-voltage 

WUDQVPLVVLRQFDSDFLW\IURPWR(,$

 New and continued construction 

and operation of pipelines 

About 13,000 additional miles of natural gas pipelines and 

19,000 additional miles of oil pipeline infrastructure through 

,1*$$

 New and continued construction 

and operation of petroleum and 

liquefied natural gas facilities and 

terminals 

'RPHVWLFSURGXFWLRQRIOLTXHILHGQDWXUDOJDVLVSURMHFWHGWR

LQFUHDVHIURPDERXWRI the natural gas supply in 2010 to 

DERXWLQ,1*$$13&

 New and continued operation of oil 

refineries 

,QFUHDVHLQRLOUHILQHU\FDSDFLW\IURPDERXWWRPLOOLRQ

barrels of oil per day from 2010 to 2030, depending on 

economic JURZWKDQGSULFHDVVXPSWLRQV(,$F

$GGLWLRQDOFDSDFLW\ZLOOPRVWOLNHO\EHIURPH[SDQVLRQV

XSGDWHVDQGPRGLILFDWLRQVWRH[LVWLQJUHILQHU\IOHHWUDWKHU

WKDQFRQVWUXFWLRQRIQHZIDFLOLWLHV13&

 New and continued oil and gas 

H[SORUDWLRQDQGH[WUDFWLRQDFWLYLWLHV

Domestic production of crude oil increases, mostly due to 

RQVKRUHSURGXFWLRQRIVKDOHVDQGWLJKWIRUPDWLRQV1DWXUDO

JDVLVH[SHFWHGWRLQFUHDVHIURPWRRIHOHFWULF

SRZHUJHQHUDWLRQIURPWR(,$D

 New and continued uranium ore 

H[SORUDWLRQDQGH[WUDFWLRQDFWLYLWLHV

1HZDQGFRQWLQXHGXUDQLXPRUHH[SORUDWLRQDQGH[WUDFWLRQ

DFWLYLWLHVH[SHFWHGEDVHGRQWKHDQQXDOLQFUHDVHIURP

WRIRUQXFOHDUSRZHUJHQHUDWLRQ

Continued Use of Radiological Materials 

 Construction and operation of new 

DQGH[LVWLQJDW-UHDFWRU,6)6,V

,QFUHDVHLQWRWDOFRPPHUFLDOVSHQWIXHOE\DERXWWR

2400 MT/yr (NRC G$ERXWGU\VWRUDJHV\VWHPV

ZRXOGEHORDGHGE\ZLWKDQDGGLWLRQDOV\VWHPV

WRWDOORDGHGE\%5& 

 New and continued activities at 

hospitals and industrial facilities that 

produce and use radioactive 

materials, such as medical or 

industrial isotopes 

,QFUHDVHOLNHO\JLYHQWKHSUHYDOHQFHRIQXFOHDUPHGLFLQHLQ

current treatment technologies (112 million nuclear 

medicine/radiation therapy procedures annually [NRC 2000]), 

FXUUHQWGHPDQGHJ)5DQGLQFUHDVLQJ

population and aging demographics

 Continued operation of research 

and test reactors 

As of June 2013, 31 NRC-licensed research reactors operate 

LQWKH8QLWHG6WDWHVRIZKLFKKDYHEHHQJUDQWHGD

renewed license and 14 are currently under review for license 

renewal (NRC 2013e6LPLODUOHYHOVDUHH[SHFWHGLQIXWXUH

 Continued operation of fuel 

fabrication facilities 

6OLJKWGHFUHDVHEDVHGRQDQHVWLPDWHRIPLOOLRQ

VHSDUDWLYHZRUNXQLWVLQWRPLOOLRQVHSDUDWLYHZRUN

XQLWVLQ(,$G

 
&XPXODWLYH,PSDFWV

September 2014 6- 185(*௅

Table 6-1 *HQHUDO7UHQGVDQG+XPDQ$FWLYLWLHV2FFXUULQJDWRUQHDU6WRUDJH)DFLOLWLHV

(cont’d)

Activity or Stressor Reasonably Foreseeable Future Trend 

Increased Water Demand 

 Continued transfer of water within 

and across water basins 

,QFUHDVHOLNHO\WRHVWDEOLVKUHOLDEOHZDWHUVXSSOLHVWRVXSSRUW

SRSXODWLRQJURZWKHJ7H[DV:DWHU'HYHORSPHQW%RDUG



 New and continued operation of 

drinking water-treatment plants and 

water-supply facilities 

Total withdrawals of water for consumption to increase by 

DERXWIURPWR86$&(

Population Growth and Demographic Shifts 

 Overall Population Growth (in the 

86

7RWDO86SRSXODWLRQH[SHFWHGWRLQFUHDVHIURPPLOOLRQ

WRPLOOLRQ86&%

Increased Urbanization 

 River, shoreline, canal, or channel 

modifications including dredging 

and erosion-prevention programs 

$FWLYLWLHVH[SHFWHGWRFRQWLQXHEDVHG on statutory authority 

IRU86$UP\&RUSVRI(QJLQHHUV86$&(SRSXODWLRQ

JURZWKDQGXUEDQL]DWLRQ

 Construction of housing units $QLQFUHDVHLQWRWDOKRXVLQJXQLWVLVH[SHFWHGIURP

 PLOOLRQXQLWVLQWRWRPLOOLRQXQLWVLQ

to WRPLOOLRQXQLWVLQ3LWNLQDQG0\HUV

 Construction of commercial 

buildings 

Similar to housing construction, commercial construction 

ZRXOGEHH[SHFWHGWRLQFUHDVHZLWKSRSXODWLRQJURZWKDQG

FRQWLQXHGXUEDQL]DWLRQ

:DWHUIURQWdevelopment Coastal populations likely to increase, particularly in warmer 

coastal regions in the south based on population growth and 

KRXVLQJWUHQGV

Transportation 

 Construction of transportation 

LQIUDVWUXFWXUHHJURDGVEULGJHV

and rail) 

$GGLWLRQDOLQIUDVWUXFWXUHOLNHO\EDVHGRQSRSXODWLRQJURZWK,Q

addition, increased reliance on mass transit would reduce the 

need for new long-distance highway infrastructure (National 

5HVHDUFK&RXQFLO

Other Activities and Stressors 

Continued agricultural activities, 

aquaculture activities, and 

commercial fishing 

Agricultural and aquaculture production and commercial 

fishing would likely increase to provide food for an increasing 

QDWLRQDOSRSXODWLRQ86'$

Continued industrial and 

manufacturing activities 

,QGXVWULDODQGPDQXIDFWXULQJDFWLYLWLHVHJPLQHVTXDUULHV

glass manufacturing, chemical facilities—including organic 

chemical, inorganic chemical, and other miscellaneous 

chemical product and preparation manufacturing) would be 

anticipated to increase to provide goods and services for an 

LQFUHDVLQJQDWLRQDOSRSXODWLRQ
&XPXODWLYH,PSDFWV

185(*௅ 6- September 2014 

Table 6-1 *HQHUDO7UHQGVDQG+XPDQ$FWLYLWLHV2FFXUULQJDWRUQHDU6WRUDJH)DFLOLWLHV

(cont’d)

Activity or Stressor Reasonably Foreseeable Future Trend 

Continued resource management at 

State and Federal parks, preserves, 

wildlife management areas, national 

wildlife refuges, and recreational 

areas, or other private or public 

efforts to restore, preserve, or 

enhance natural communities 

Government land management agencies will continue to 

operate and manage Federal and State properties in 

DFFRUGDQFHZLWKWKHLUVWDWXWRU\DXWKRULW\/HJLslation in 

&RQJUHVVRULQ6WDWHOHJLVODWXUHVPD\UHYLVHHLWKHUH[SDQG

RUUHGXFHDJHQF\DXWKRULW\HJ136&&

Continued operation and closure of 

various military facilities 

Military facilities will continue to support combat readiness 

DQGQDWLRQDOVHFXULW\EXWSURMHFWLRQVLQGLFDWHWKDWIXWXUH

overall military budgets will be reduced, accompanied by a 

reduction in active-GXW\VWUHQJWK)5

Climate change ,QFUHDVHGWHPSHUDWXUHVHD-level rise, and changes in 

precipitation levels DVGHVFULEHGLQWKH86 Global Climate 

5HVHDUFK3URMHFW*&5314) Depending on the 

assumed scenario, global temperatures in 2100 are predicted 

to increase by 1°C (most aggressive carbon emissions 

control) to &OHDVWDJJUHVVLYHFDUERQHPLVVLRQVFRQWURO

Sea level is predicted to increase 30WR2 PE\

Reduced snowpack in western mountains is predicted 

(USACE 

6.3.2 Other NRC-Regulated or Spent Fuel-Related Activities during Continued 

Storage 

,QDGGLWLRQWRWKHLQFUHPHQWDOLPSDFWVIURPFRQWLQXHGVWRUDJHGHVFULEHGLQ&KDSWHUVDQG

other NRC-regulated or spent fuel-related activities could affect the same resources as those 

DIIHFWHGE\FRQWLQXHGVWRUDJH7KHVHDFWLYLWLHVLQFOXGHRWKHU15&-regulated actions that would 

occuUDWWKHVWRUDJHVLWHRUFRQQHFWHGDFWLRQVWKDWFRXOGRFFXUDWRUEH\RQGWKHVWRUDJHVLWH$

VXPPDU\RIWKHVHDFWLYLWLHVFRQVLGHUHGLQWKLVFXPXODWLYHDQDO\VLVLVSURYLGHGEHORZ1RWHWKDW

some of the activities apply only to a subset of the timeframes dHVFULEHGLQ&KDSWHUVDQG

)RUH[DPSOHGU\WUDQVIHUV\VWHP'76FRQVWUXFWLRQDQGGHFRPPLVVLRQLQJZRXOGRFFXURQO\

during long-term storage or indefinite storage, but would not occur during short-WHUPVWRUDJH

6.3.2.1 Final Reactor Shutdown Activities Prior to Decommissioning 

7KHVHDFWLYLWLHVFRXOGLQYROYHDQLQLWLDOLQFUHDVHLQVWDIIWRH[HFXWHVKXWGRZQ: a decrease and 

XOWLPDWHO\DFHVVDWLRQRIUHDFWRUSRZHURXWSXWWRJULGDQLQFUHDVHLQSRZHUGHPDQGWRVXSSRUW

RQVLWHDFWLYLWLHVDGHFUHDVHLQGHPDQGIRU SRZHUSODQWRSHUDWLRQDOFRROLQJDQGWKHSRWHQWLDOIRU

UHPRYDORIVRPHVWUXFWXUHVDQGHTXLSPHQW

$OVRVHHWKHGHVFULSWLRQRIVKXWGRZQDFWLYLWLHVLQ6HFWLRQ
&XPXODWLYH,PSDFWV

September 2014 6-9 185(*௅

6.3.2.2 Decommissioning of the Reactor Power Block (including the spent fuel pool), 

DTS, and ISFSI 

Decommissioning includes activities to remove radioactive materials from structures, systems, 

and components to demonstrate compliance with NRC release limits in 10 CFR Part 20, 

6XESDUW(5HDFWRUGHFRPPLVVLRQLQJRIIDFLOLWLHVQRWUHODWHGWRVSHQWIXHOVWRUDge could occur 

from the time that the licensee certifies that it has permanently ceased power operations until 

WKHOLFHQVHLVWHUPLQDWHG7RIDFLOLWDWHGHFRPPLVVLRQLQJDWVRPHVLWHVWKHRSHUDWRUPD\

construct a new spent fuel pool cooling system to allow the spent fuel pool to be isolated from 

RWKHUUHDFWRUSODQWV\VWHPV

Decommissioning of the spent fuel pool could begin after stored spent fuel has been transferred 

WRGU\VWRUDJH7KH15&JHQHULFDOO\HYDOXDWHGWKHHQYLURQPHQWDOLPSDFWVIURPUHDFWRU

decoPPLVVLRQLQJLQFOXGLQJWKHVSHQWIXHOSRROEXWQRW,6)6,VLQ NUREGíFinal Generic 

Environmental Impact Statement on Decommissioning of Nuclear Facilities, Supplement 1

'HFRPPLVVLRQLQJ*(,615&7KH15&SUHYLRXVO\HYDOXDWHGWKHHQYLURQPHQWDO

impacts of decommissioning an away-from-UHDFWRU,6)6,LQ185(*íFinal Environmental 

Impact Statement for the Construction and Operation of an Independent Spent Fuel Storage 

Installation on the Reservation of the Skull Valley Band of Goshute Indians and the Related 

Transportation Facility in Tooele County, Utah 3)6)(,615&DDQGLQVLWH-specific 

at-UHDFWRU,6)6,VLQWKH&DOYHUW&OLIIV+XPEROGW%D\+%5RELQVRQ6XUU\2FRQHHDQG'LDEOR

Canyon EAs (NRC D–FE'HFRPPLVsioning of the DTS is only 

applicable for long-WHUPDQGLQGHILQLWHVWRUDJH$OVRVHHWKHGHVFULSWLRQRIGHFRPPLVVLRQLQJ

DFWLYLWLHVLQ6HFWLRQ

6.3.2.3 Activities to Prepare the Spent Fuel for Transportation to a Repository for Final 

Disposal 

These activities would include transferring spent fuel that was stored in dual-purpose canisters 

from the storage casks to transportation packages and then loading the transportation packages 

RQFRQYH\DQFHVEHIRUHWUDQVSRUWDWLRQWRDUHSRVLWRU\6SHQWIXHOVWRUHGLQVWRUDge-only casks 

or that would otherwise require bare fuel handling (as described in Chapter 2) would be 

transferred to transportation-certified packages using the spent fuel pool for short-term storage 

and the DTS long-WHUPVWRUDJHWLPHIUDPH7KHVHWUDQVSRUtation-related activities could begin 

ZKHQDUHSRVLWRU\EHJLQVDFFHSWLQJVKLSPHQWVRIVSHQWIXHOIURPSRZHUUHDFWRUV7KLVDFWLYLW\

would only occur for short-term and long-term storage, because indefinite storage assumes that 

DUHSRVLWRU\LVQHYHUEXLOW
&XPXODWLYH,PSDFWV

185(*௅ 6-10 September 2014 

6.3.2.4 Transportation of Spent Fuel from an At-Reactor or Away-From-Reactor 

Storage Facility to a Repository for Disposal 

$VGHVFULEHGLQ6HFWLRQWKH)HGHUDOJRYHUQPHQWKDVDGRSWHGGHHSJHRORJLFGLVSRVDODV

the national solution for spent fuel disposal (NucOHDU:DVWH3ROLF\$FWRIDQGWKH

86 Department of Energy (DOE) has reaffirmed the Federal government’s commitment to the 

XOWLPDWHGLVSRVDORIVSHQWIXHO'2(:KHQDUHSRVLWRU\LVDYDLODEOHWRDFFHSWVKLSPHQWV

of spent fuel, facility operators would ship spent fuel in NRC-approved transportation packages 

IURPIDFLOLW\ORFDWLRQVDFURVVWKH8QLWHG6WDWHVWRDUHSRVLWRU\VLWH6KLSPHQWVZRXOGEH

UHTXLUHGWRFRPSO\ZLWKDSSOLFDEOH15&DQG86'HSDUWPHQWRI7UDQVSRUWDWLRQUHJXODWLRQVIRU

the traQVSRUWDWLRQRIUDGLRDFWLYHPDWHULDOVLQ&)53DUWDQG&)53DUWV WKURXJK

7UDQVSRUWDWLRQRIVSHQWIXHOWRDUHSRVLWRU\ZRXOGRQO\RFFXUGXULQJVKRUW-term and longWHUPVWRUDJHEHFDXVHLQGHILQLWHVWRUDJHDVVXPHVDUHSRVLWRU\LVQHYHUEXLOW

6.4 Resource-Specific Analyses 

6.4.1 Land Use 

This section evaluates the effects of continued storage on land use when added to the 

DJJUHJDWHHIIHFWVRIRWKHUSDVWSUHVHQWDQGUHDVRQDEO\IRUHVHHDEOHIXWXUHDFWLRQV$V

GHVFULEHGLQ6HFWLRQVDQGWKHLQFUHPental impacts from continued storage on land use 

would be SMALL for all timeframes at both at-reactor and away-from-UHDFWRUVWRUDJHIDFLOLWLHV

The geographic area considered in the cumulative land use analysis includes all affected land 

surrounding the at-reactor and away-from-UHDFWRUVWRUDJHIDFLOLWLHV5HVLGHQWLDOFRPPHUFLDO

industrial, agricultural, forested, and recreational lands typically surround spent fuel storage 

IDFLOLWLHV'HSHQGLQJRQWKHVLWHWKHODQGVXUURXQGLQJDVSHQWIXHOVWRUDJHIDFLlity could include 

SULYDWHDQGSXEOLFODQGVLQDUDQJHRISROLWLFDOMXULVGLFWLRQVLQFOXGLQJWRZQVWRZQVKLSVVHUYLFH

GLVWULFWVFRXQWLHVDQGSDULVKHV,QDGGLWLRQ6WDWH)HGHUDODQG1DWLYH$PHULFDQODQGVDUH

present within the area considered for this DQDO\VLV

6.4.1.1 Potential Cumulative Impacts from General Trends and Activities 

&XPXODWLYHLPSDFWVRQODQGXVHLQFOXGHFKDQJLQJDQGGLVWXUELQJH[LVWLQJODQG-use 

conditions, (2) restricting access or establishing right-of-way access, (3) restricting agricultural 

or recreational activities, DQGDOWHULQJHFRORJLFDORUKLVWRULFDQGFXOWXUDOUHVRXUFHVHJ

NRC 2011a–e, 2012a, 2013a–F&XPXODWLYHLPSDFWVFRXOGRFFXUIURPWKHDFWLYLWLHVGHVFULEHG

LQ6HFWLRQVXFKDVFRQVWUXFWLQJDQGRSHUDWLQJQHZDQGH[LVWLQJHQHUJ\SURMHFWVDQG

LQIUDVWUXFWXUHHJUHSODFHPHQWSRZHUZDWHUGHYHORSPHQWSURMHFWVDQGFRQVtructing housing 

XQLWVFRPPHUFLDOEXLOGLQJVURDGVEULGJHVDQGUDLOOLQHVHJ15&D–e, 2012a, 

 
&XPXODWLYH,PSDFWV

September 2014 6-11 185(*௅

2013a–F,QDGGLWLRQFOLPDWHFKDQJHFDQaffect agricultural and ranching land uses because of 

changes in crop yields and livestock producWLYLW\*&53 Climate change can also lead 

to higher sea levels (GCRP 2014), thereby changing land use through inundation and loss of 

coastal wetlands and other low-O\LQJDUHDV

The magnitude of cumulative land-use impacts resulting from general trends taking place near a 

storage facility would depend on current land-use patterns and proposed land-use changes, the 

QXPEHUDQGGHQVLW\RIDFWLRQVDQGWKHH[WHQWWRZKLFKWKHVHDFWLRQVIDFLOLWLHVRUSURMHFWV

employ mitigation measures to reduce impacWV7KHFXPXODWLYHLPSDFWVIURPJHQHUDOWUHQGV

DQGDFWLYLWLHVZRXOGUDQJHIURPPLQLPDOHJPLQRUFKDQJHVLQODQGXVHIURPOLPLWHG

GHYHORSPHQWLQWKHDUHDVHH15&GWRQRWLFHDEOHHJFRQVWUXFWLRQDQGRSHUDWLRQRID

new coal-fired power plant, new transmission lines, and climate change in the area, see NRC 

D*URZWKFRQWUROPHDVXUHVVXFKDV]RQLQJUHVWULFWLRQVDQGLPSOHPHQWDWLRQRIORFDOODQG

XVHRUPDVWHUSODQVDUHH[SHFWHGWROLPLWGHYHORSPHQWQHDUDVWRUDJHIDFLOLW\7KHUHIRUHWKH

cuPXODWLYHLPSDFWVDUHQRWH[SHFWHGWREHGHVWDELOL]LQJHJPDMRUFKDQJHVLQODQGXVHIURP

XQFRQWUROOHGGHYHORSPHQWLQWKHDUHD

6.4.1.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

Activities 

Cumulative impacts on land-use conditions could result from other NRC-regulated or spent fuelrelated activities, such as decommissioning of the reactor power block (including the spent fuel 

SRRO,6)6,VDQG'76

Activities associated with decommissioning of the reactor power block (including the spent fuel 

SRROWKDWFRXOGLPSDFWODQGXVHLQFOXGHDGGLWLRQDQGH[SDQVLRQRIVWDJLQJDQGOD\GRZQ

areas for equipment, (2) construction of temporary buildings and parking areas, (3) removal of 

large reactor components, (4) structure dismantlementDQGORZ-OHYHOZDVWH//:VWRUDJH

DQGSDFNDJLQJ15&7RIDFLOLWDWHGHFRPPLVVLRQLQJDWVRPHVLWHVWKHRSHUDWRUPD\

construct a new spent fuel pool cooling system to allow the spent fuel pool to be isolated from 

other reactor plant systems in RUGHU,QWKH'HFRPPLVVLRQLQJ*(,6IRUSRZHUUHDFWRUVWKH

NRC (2002) determined that changes to land use from these activities would be temporary and 

ZRXOGQRWEHGHWHFWDEOH0RVWUHDFWRUVLWHVKDYHVXIILFLHQWDUHDIRUWKHVHDFWLYLWLHVZLWKLQWKH

previoXVO\GLVWXUEHGDUHDZKHWKHUGXULQJFRQVWUXFWLRQRURSHUDWLRQRIWKHVLWHWKHUHIRUHQR

DGGLWLRQDOODQGGLVWXUEDQFHZRXOGEHDQWLFLSDWHG7KHLPSDFWVIURPGHFRPPLVVLRQLQJVSHQWIXHO

SRROVZHUHFRQVLGHUHGLQWKH'HFRPPLVVLRQLQJ*(,6*LYHQWKDWWKHLPSDcts from 

decommissioning reactors and spent fuel pools would be similar to that described in the 

'HFRPPLVVLRQLQJ*(,6IRUUHDFWRUVLPSDFWVRQRQVLWHODQGXVHGXULQJGHFRPPLVVLRQLQJDUH

H[SHFWHGWREHPLQLPDO

$FWLYLWLHVDVVRFLDWHGZLWKGHFRPPLVVLRQLQJ,6)6,VWKDWFRXOGLPSDFWODQGXVHLQFOXGH

(1) GHFRQWDPLQDWLQJWKHFRQFUHWHVWRUDJHFDVNVGLVPDQWOLQJDQGUHPRYLQJWKHFRQFUHWH
&XPXODWLYH,PSDFWV

185(*௅ 6-12 September 2014 

VWRUDJHFDVNVFRQFUHWHSDGVDQGVXSSRUWIDFLOLWLHVLQFOXGLQJWKH'76DQGUHPRYLQJDQ\

contaminated soil identified duriQJWKHILQDOUDGLRORJLFDOVLWHVXUYH\,QPRVWFDVHVODQG

GLVWXUEDQFHLPSDFWVDVVRFLDWHGZLWKGHFRPPLVVLRQLQJ,6)6,VZRXOGEHVLPLODUWRRUOHVVWKDQ

ODQGGLVWXUEDQFHLPSDFWVDVVRFLDWHGZLWKFRQVWUXFWLQJ,6)6,V15&Díc, 2009, 

E$IWHUGHcommissioning activities are complete, the area previously occupied by the 

at-reactor or away-from-UHDFWRU,6)6,ZRXOGW\SLFDOO\EHFRYHUHGZLWKWRSVRLOFRQWRXUHGDQG

UHSODQWHGZLWKQDWLYHYHJHWDWLRQ15&F7KHJRDORIGHFRPPLVVLRQLQJLVWRUHOHDVe the 

VLWHIRUXQUHVWULFWHGXVH%HFDXVHWKHODQGGLVWXUEDQFHLPSDFWVIURPGHFRPPLVVLRQLQJ

at-reactor and away-from-UHDFWRU,6)6,VZRXOGEHVLPLODUWRRUOHVVWKDQWKRVHDVVRFLDWHGZLWK

FRQVWUXFWLQJ,6)6,VLPSDFWVRQODQGXVHGXULQJGHFRPPLVVLRQLQJDUHH[SHFWHGWREHPLQLPDO

6.4.1.3 Conclusion 

Cumulative impacts on land use include the incremental effects from continued storage when 

added to the aggregate effects of other past, present, and reasonably foreseeable future 

DFWLRQV$VGHVFULEHGLQ6HFWLRQVDQG WKHLQFUHPHQWDOLPSDFWVIURPFRQWLQXHGVWRUDJH

on land use is SMALL for all timeframes at both at-reactor and away-from-reactor storage 

IDFLOLWLHV,QDGGLWLRQSDVWSUHVHQWDQGUHDVRQDEO\IRUHVHHDEOHDFWLYLWLHVtake place in the 

geographic area of interest that could contribute to cumulative effects on ODQGXVH7KH

cumulative impacts on land use from continued storage when added to other past, present, and 

reasonably foreseeable Federal and non-Federal activities are SMALL to MODERATE 

depending on land-XVHSDWWHUQVDQGDFWLYLWLHVVXUURXQGLQJWKHVLWH$60$//LPSDFWZRXOG

RFFXULIQRRWKHUDFWLRQVRFFXUWKDWKDYHRYHUODSSLQJQRWLFHDEOHHIIHFWVRQODQGXVH$

MODERATE impact would occur if NRC or other Federal or non-Federal actions, such as 

construction and operation of other nearby nuclear, coal-fired, or gas-fired power plants or 

future urbanization, have overlapping impacts with the continued storage of waste that 

QRWLFHDEO\DOWHUHGODQGXVH$WVWRUDJHIDFLOLWLHVZKHUHWKHFXPXODWLYHLPSDFts would be 

MODERATE from other Federal or non-Federal activities, the NRC determined the cumulative 

impacts would likely remain MODERATE whether or not continued storage occurred because 

the incremental impacts from continued storage would be minor, especially in comparison to 

RWKHUJHQHUDOWUHQGVVXFKDVXUEDQL]DWLRQ

6.4.2 Socioeconomics 

This section evaluates the socioeconomic effects of continued storage when added to the 

DJJUHJDWHHIIHFWVRIRWKHUSDVWSUHVHQWDQGUHDVRQDEO\IRUHVHHDEOHIXWXUHDFWLRQVAs 

GHVFULEHGLQ6HFWLRQVDQGthe adverse effects of continued storage are SMALL for all 

at-reactor and away-from-reactor spent fuel storage facilities because of the small number of 

workers required to maintain and monitor the storage of spent fueO,QDGGLWLRQconstruction and 

operation of an away-from-reactor storage facility could generate potentially LARGE beneficial 

economic impacts in some rural communities as well as SMALL adverse socioeconomic 

impacts due to increased demand for housing and public services
&XPXODWLYH,PSDFWV

September 2014 6-13 185(*௅

The geographic area considered in the cumulative socioeconomic resources analysis is the 

socioeconomic region of influence, which includes the areas where spent fuel storage workers 

DQGWKHLUIDPLOLHVUHVLGHVSHQGWKHLULQFRPHDQGXVHWKHLUEHQHILWV7KXVLQWKHVHDUHDV

storage facility workers both directly and indirectly affect the eFRQRPLFFRQGLWLRQVRIWKHUHJLRQ

6.4.2.1 Potential Cumulative Impacts from General Trends and Activities 

Cumulative socioeconomic impacts in local communities could affect (1) employment and 

LQFRPHWD[UHYHQXHVSRSXODWLRQDQGKRXVLQJGHPDQGDQGWKH availability and 

GHPDQGIRUSXEOLFVHUYLFHV15&GDD1HZenergy SURMHFWVHJ

UHSODFHPHQWSRZHULQGXVWULDOFRPPHUFLDODQGDJULFXOWXUDOGHYHORSPHQWDQGUHJLRQDOWRXULVP

and recreation, could cause an increase in population, demand for housing and services, traffic 

YROXPHDQGWD[UHYHQXHSDLGWRORFDOMXULVGLFWLRQV,QDGGLWLRQDQDW-UHDFWRU,6)6,ORFDWHGDWRU

QHDUDQRSHUDWLQJUHDFWRUZRXOGH[SHULHQFHFXPXODWLYHLPSDFWVDVVRFLDWHGZith reactor 

RSHUDWLRQVVXFKDVWUDIILFDQGWD[UHYHQXH

7KHPDJQLWXGHRIWKHVRFLRHFRQRPLFLPSDFWUHVXOWLQJIURPJHQHUDOWUHQGVZLWKLQFORVHSUR[LPLW\

of a spent fuel storage facility would depend on the intensity of developmenW&XPXODWLYH

impacts would be specific to the region in which the storage facility is located and would range 

IURPPLQLPDOHJPLQRULQFUHDVHLQGHPDQGIRUSXEOLFVHUYLFHVFDXVHGE\FRQVWUXFWLRQDQG

operation of a new industry or power plant, see NRC GWRQRWLFHDEOHHJQRWLFHDEOH

increase in housing and rental prices because of increased demand caused by the construction 

and operation of a new industry or SRZHUSODQWVHH15&,Qmost situations, the 

cumulative impacts could be both adverse and EHQHILFLDOHJLQFUHDVHd traffic, demand for 

public services, and increased SURSHUW\WD[UHYHQXHVHH15&D

6.4.2.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

Activities 

Cumulative impacts could result from other NRC-regulated or spent fuel-related activities, such 

DVGHFRPPLVVLRQLQJWKHSRZHUEORFNLQFOXGLQJWKHVSHQWIXHOSRRO,6)6,DQG'767KH

H[WHQWWRZKLFKLPSDFWVwould be cumulative would depend on the timing of decommissioning in 

UHODWLRQWRRWKHUDFWLYLWLHVHJtermination of reactor operations and power SODQWVKXWGRZQ

The immediate socioeconomic impact caused by terminating reactor operations and power plant 

VKXWGRZQZRXOGEHJUHDWHUWKDQWKHLPSDFWIURPGHFRPPLVVLRQLQJWKHSRZHUEORFN7KH

socioeconomic impacts from terminating reactor operations and power plant shutdown are 

GHVFULEHGLQERWKWKH'HFRPPLVVLRQLQJ*(,615&DQGWKH/LFHQVH5HQHZDO*(,6

15&DDVGHVFULEHGEHORZ

$VGLVFXVVHGLQ6HFWLRQWKHVL]HRIWKHQXFOHDUSRZHUSODQWRSHUDWLRQVZRUNIRUFHYDULHV

FRQVLGHUDEO\DPRQJRSHUDWLQJ86QXFOHDUSRZHUIDFLOLWLHVDQGUDQJHVIURPWR
&XPXODWLYH,PSDFWV

185(*௅ 6-14 September 2014 

2,400 ZRUNHUV2SHUDWLQJQXFOHDUSRZHUSODQWVJHQHUDOO\SURYLGHDVLJQLILFDQWDPRXQWRIWD[

UHYHQXHWRORFDOFRPPXQLWLHVDQGSXEOLFVFKRROGLVWULFWV,PSDFWVDVVRFLDWHGZLWKSRZHUSODQW

VKXWGRZQLQFOXGHWKHORVVRIMREVDWWKHQXFOHDUSODQWDQGLQVXUURXQGLQJFRPPXQLWLHVDQGD

corresponding reductioQLQWD[SD\PHQWVGHPDQGIRUKRXVLQJDQGSXEOLFVHUYLFHVDQGWUDIILF

YROXPH$VVWDWHGLQ6HFWLRQSURSHUW\WD[SD\PHQWVZRXOGFRQWLQXHDVORQJDVVSHQWIXHOLV

VWRUHGRQVLWH3XEOLFO\RZQHGWD[-H[HPSWQXFOHDUSRZHUSODQWVIXOO\GHSUHFLDWHGSODQWV, or 

SODQWVORFDWHGLQXUEDQRUDQXUEDQL]LQJDUHDZLWKDODUJHRUJURZLQJWD[EDVHZRXOGQRW

H[SHULHQFHPDQ\FKDQJHVLQRYHUDOOVRFLRHFRQRPLFFRQGLWLRQV15&,QUDUH

circumstances in which a large nuclear power plant located in a rural area permanently ceases 

RSHUDWLRQVHDUO\DQGGHOD\VGHFRPPLVVLRQLQJWKHDIIHFWHGDUHDFRXOGH[SHULHQFHJUHDWHU

LPSDFWV15&,PSDFWVIURPWKHORVVRUUHGXFWLRQRIWD[UHYHQXHEHFDXVHRIWKH

termination of reactor operations and power plant shutdown on community services could range 

IURP60$//WR/$5*(15&D&RQVLGHULQJDOOYDULDEOHVVXFKDVSODQWVL]HDQG

community size as equivalent, plants that begin decommissioning immediately would have 

less immediate negative impacts because the workforce reduction would occur gradually 

(NRC 

,PSDFWVDVVRFLDWHGZLWKGHFRPPLVVLRQLQJDSRZHUEORFNLQFOXGLQJWKHVSHQWIXHOSRRODUH

GHVFULEHGLQWKH'HFRPPLVVLRQLQJ*(,615&:KLOHWKHUHZRXOGEHDQRYHUDOO

reduction in the number of workers at the nuclear plant during decommissioning, the size of the 

workforce would have already been substantially reduced after the termination of reactor 

RSHUDWLRQVDQGSRZHUSODQWVKXWGRZQ7KH'HFRPPLVVLRQLQJ*(,6HVWLPDWHGWKDWEHWZHHQ

100 and 200 workers would be neHGHGWRVXSSRUWGHFRPPLVVLRQLQJ15&7KH

socioeconomic impact from decommissioning the power block and spent fuel pool would 

GHSHQGRQWKHVL]HDQGORFDWLRQRIWKHIDFLOLW\DQGZRXOGHYHQWXDOO\UHVXOWLQWKHORVVRIMREV

upon completion, including UHGXFHGKRXVLQJGHPDQGWD[UHYHQXHVDQGGHPDQGIRUSXEOLF

VHUYLFHV+RZHYHUWKH15&FRQFOXGHGWKDWWKHRYHUDOOVRFLRHFRQRPLFLPSDFWIURP

decommissioning the power block would be SMALL due to the gradual reduction in the 

workforce and purchasing activities at the power plant site 15&

%HFDXVHRIWKHVPDOOHUZRUNIRUFHLQYROYHGWKHVRFLRHFRQRPLFLPSDFWIURPGHFRPPLVVLRQLQJ

DQ\,6)6,DQGDVVRFLDWHG'76ZRXOGEHOHVVWKDQH[SHULHQFHGIURPWKHGHFRPPLVVLRQLQJWKH

SRZHUEORFN'ecommissioning activities would commence after spent fuel has been 

transported offsite to either a repository or an away-from-UHDFWRUVWRUDJHIDFLOLW\)XQGLQJSODQV

IRUGHFRPPLVVLRQLQJ,6)6,V0<$3&&<$3&<$(&HVWLPDWHWKDW

DSSUR[LPDWHO\ZRUNHUVZRXOGEHQHHGHGWRGHFRPPLVVLRQthe storage facility over a 1- to 

-\HDUSHULRG'HFRPPLVVLRQLQJWKH'76FRXOGRFFXULQSDUDOOHOZLWKGHFRPPLVVLRQLQJWKH

,6)6,DQGZRXOGUHSUHVHQWDPLQRULQFUHDVHWRWKHZRUNIRUFH %DVHGRQ'2(¶V7RSLFDO6DIHW\

$QDO\VLV5HSRUW'2(LWZDVHVWLPDWHGWKDWD-person workforce could decommission 

WKH'76ZLWKLQGD\V:RUNIRUFHQXPEHUVDQGGXUDWLRQRIGHFRPPLVVLRQLQJDFWLYLWLHVZRXOG

YDU\IURPVLWHWRVLWH$UHYLHZRI15&($VDQG(,6VIRUFRQVWUXFWLRQRSHUDWLRQDQGUHQHZDO
&XPXODWLYH,PSDFWV

September 2014 6- 185(*௅

of site specifically licensed at-reactor and away-from-reactor ,6)6,V15&2001a, 2003, 

Díc, 2009, 2012b) did not identify any significant socioeconomic impacts during 

GHFRPPLVVLRQLQJRI,6)6,V7KHPDJQLWXGHRILPSDFWVIURPGHFRPPLVVLRQLQJDQ,6)6,DW

RWKHUVLWHVZRXOGEHVLPLODUWRWKDWGHVFULEHGLQWKH&DOYHUW&OLIIV+XPEROGW%D\+%5RELQVRQ

6XUU\2FRQHHDQG'LDEOR&DQ\RQ($VDQGWKH3)6)(,6EHFDXVHRIFRQVLGHUDWLRQVRI

workforce, housing dHPDQGWUDIILFQHWZRUNVDQGSXEOLFVHUYLFHV%HFDXVHWKHLPSDFWVIURP

decommissioning at-reactor and away-IURPUHDFWRU,6)6,VZRXOGEHVLPLODUWRWKDWGHVFULEHGLQ

site-VSHFLILF,6)6,($VDQGWKH3)6)(,6VRFLRHFRQRPLFLPSDFWVGXULQJGHFRPPLVVLRQLQJDUH

H[SHFWHGWREHPLQLPDO

6.4.2.3 Conclusion 

Cumulative impacts include the incremental effects from continued storage when added to the 

DJJUHJDWHHIIHFWVRIRWKHUSDVWSUHVHQWDQGUHDVRQDEO\IRUHVHHDEOHIXWXUHDFWLRQV$V

GHVFULEHGLQ6HFWLRQVDQGWKHadverse effects of continued storage are SMALL for 

at-reactor and away-from-reactor storage facilities because of the small number of workers 

UHTXLUHGWRPDLQWDLQDQGPRQLWRUWKHVWRUDJHRIVSHQWIXHO+RZHYHUconstruction and operation 

of an away-from-reactor storage facility could generate potentially LARGE beneficial economic 

impacts in some rural economies as well as SMALL adverse socioeconomic impacts due to 

increased demand for housing and public services,QDGGLWLRQother past, present, and 

reasonably foreseeable activities could also FRQWULEXWHWRFXPXODWLYHVRFLRHFRQRPLFLPSDFWV

The cumulative socioeconomic impacts from continued storage when added to other past, 

present, and reasonably foreseeable Federal and non-Federal activities, such as the termination 

of reactor operations, decommissioning, construction of replacement power SURMHFWV

XUEDQL]DWLRQDQGWUDQVSRUWDWLRQSURMHFWVDUH60$//WR/$5*(GHSHQGLQJRQWKHDFWLYLW\DQG

location of the action relative to the storage facility$60$//LPSDFt would occur if there are no 

RWKHUDFWLRQVWKDWKDYHRYHUODSSLQJQRWLFHDEOHVRFLRHFRQRPLFHIIHFWV$02'(5$7(LPSDFW

would occur if other Federal or non-Federal actions, such as construction and operation of a 

new power plant, have overlapping impacts with continued storage that would noticeably alter 

VRFLRHFRQRPLFFRQGLWLRQVHJLQFUHDVHGtraffic and WD[UHYHQXHs/$5*(LPSDFWVare 

XQOLNHO\EHFDXVHORFDOSODQQLQJDQG]RQLQJDXWKRULWLHVZRXOGHQVXUHWKDWQHZSURMHFWVGRQRW

destabilize socioeconomic conditions$WVWRUDJHIDFLOLWLHVIRUZKLFKWKHDGYHUVHFXPXODWLYH

impacts would range from MODERATE to LARGE because of other Federal and non-Federal 

activities, the adverse cumulative impacts would be MODERATE to LARGE regardless of 

continued storage because the incremental operational effects from continued storage would be 

minor when compared to other activities and economic trends, such as urbanization or 

construction and operation of new industries and SRZHUSODQWV

6.4.3 Environmental Justice 

This section describes the impacts on minority and low-income populations resulting from 

continued storage when added to the aggregate effects of other past, present, and reasonably 
&XPXODWLYH,PSDFWV

185(*௅ 6-16 September 2014 

IRUHVHHDEOHIXWXUHDFWLRQV$VGHVFULEHGLQ6HFWLRQVDQGPLQRULW\DQGORZ-income 

SRSXODWLRQVDUHQRWH[SHFWHGWRH[SHULence disproportionately high and adverse human health 

DQGHQYLURQPHQWDOHIIHFWVIURPWKHLQFUHPHQWDOLPSDFWVDVVRFLDWHGZLWKFRQWLQXHGVWRUDJH

7KHHQYLURQPHQWDOMXVWLFHFXPXODWLYHLPSDFWDQDO\VLVDVVHVVHVthe potential for minority and 

low-income populatiRQVWRH[SHULHQFHdisproportionately high and adverse human health and 

environmental effects from the continued storage of spent fuel combined with past, present, and 

UHDVRQDEO\IRUHVHHDEOHIXWXUHDFWLRQVAdverse health effects are measured in terms of the risk 

DQGUDWHRIIDWDORUQRQIDWDODGYHUVHLPSDFWVRQKXPDQKHDOWK$QDGYHUVHHQYLURQPHQWDOLPSDFW

LVDQLPSDFWWKDWLVGHWHUPLQHGWREHERWKKDUPIXODQGVLJQLILFDQWDVHPSOR\HGE\1(3$

Disproportionately high and adverse human health effects occur when the risk or rate of 

H[SRVXUHWRDQHQYLURQPHQWDOKD]DUGIRUDPLQRULW\RUORZ-income population is significant and 

H[FHHGVWKHULVNRUH[SRVXUHUDWHIRUWKHJHQHUDOSRSXODWLRQRUIRUDQRWKHUDSSURSULDWH

FRPSDULVRQJURXS'LVSURSRUWLRQDWHO\KLJKHQYironmental effects refer to impacts, or risk of 

impacts, on the natural or physical environment in a minority or low-income community that are 

VLJQLILFDQWDQGDSSUHFLDEO\H[FHHGWKHHQYLURQPHQWDOLPSDFWRQWKHODUJHUFRPPXQLW\6XFK

effects may include biRORJLFDOFXOWXUDOHFRQRPLFRUVRFLDOLPSDFWV15&D

Additionally, the cumulative impact assessment considers the potential radiological risk to 

minority and low-LQFRPHSRSXODWLRQJURXSVUHVLGLQJZLWKLQWKHNPPLUHJLRQIURPWKH

spent fuel VWRUDJHIDFLOLW\DVZHOODVWKHSRWHQWLDOH[SRVXUHIURPRWKHUVRXUFHVRIUDGLDWLRQIURP

RWKHUDFWLRQV$VVWDWHGLQ6HFWLRQVSHFLDOSRSXODWLRQJURXSVLQFOXGHSRSXODWLRQVWKDWUHO\

SULQFLSDOO\RQILVKRUZLOGOLIHIRUVXEVLVWHQFH

6.4.3.1 Potential Cumulative Impacts from General Trends and Activities 

Potentially adverse human health and environmental effects from activities associated with 

industrial, commercial, agricultural, and transportation developments can affect the resources 

on which minority and low-iQFRPHSRSXODWLRQVGHSHQGHJ fish, game animals, and native 

vegetation) 15&D)RUH[DPSOHSRWHQWLDOLPSDFWVRQPLQRULW\DQGORZ-income 

populations from the construction and operation of replacement power and other industrial 

SURMHFWVLQWKHYLFLQLW\RIVWRUDJHIDFLOLWLHVZRXOGPRVWO\FRQVLVWRIHQYLURQPHQWDOHJQRLVH

GXVWDQGWUDIILFDQGVRFLRHFRQRPLFHJHPSOR\PHQWDQGKRXVLQJHIIHFWVGXULQJ

FRQVWUXFWLRQ1RLVHDQGGXVWLPSDFWVGXULQJFRQVWUXFWLRQZRXOGEHof short duration and 

primDULO\OLPLWHGWRRQVLWHDFWLYLWLHV0LQRULW\DQGORZ-income populations residing along site 

DFFHVVURDGVFRXOGEHGLUHFWO\DIIHFWHGE\LQFUHDVHGFRPPXWHUYHKLFOHDQGWUXFNWUDIILF

+RZHYHUWKHVHHIIHFWVFRXOGEHOLPLWHGWRFHUWDLQKRXUVRIWKHGD\,QFreased demand for 

rental housing during construction could cause rental costs to temporarily rise, 

disproportionately affecting low-LQFRPHSRSXODWLRQVOLYLQJQHDUWKHVLWHWKDWUHO\RQLQH[SHQVLYH

KRXVLQJ+RZHYHUJLYHQWKHSUR[LPLW\RIPRVWLQGXVWULDOVites to urban areas, many workers 

FRXOGFRPPXWHWRWKHFRQVWUXFWLRQVLWHWKHUHE\UHGXFLQJWKHQHHGIRUUHQWDOKRXVLQJ
&XPXODWLYH,PSDFWV

September 2014 6- 185(*௅

The magnitude of human health and environmental effects resulting from all actions associated 

with general trends on minority and low-inFRPHSRSXODWLRQVOLYLQJZLWKLQFORVHSUR[LPLW\RID

VSHQWIXHOVWRUDJHIDFLOLW\ZRXOGGHSHQGRQWKHLQWHQVLW\RIWKHHIIHFWV6RPHRIWKHVHSRWHQWLDO

HIIHFWVKDYHEHHQLGHQWLILHGLQUHVRXUFHDUHDVSUHVHQWHGLQ&KDSWHUVDQGRIWKLV*(,6

Minority and low-income populations are subsets of the general population residing in the area 

DQGDOOZRXOGEHH[SRVHGWRWKHVDPHKD]DUGVJHQHUDWHGIURPDFWLYLWLHVDVVRFLDWHGZLWK

FRQWLQXHGVWRUDJH

6.4.3.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

Activities 

Cumulative impacts could result from other NRC-regulated or spent fuel-related activities, such 

as terminating reactor operations, shutting down the power plant, decommissioning the reactor 

power block (including the spent fuel pool) and ,6)6,VDQGFRQVWUXFWLQJDQGRSHUDWLQJWKH'76

The NRC also considers the potential for minority and low-LQFRPHSRSXODWLRQVWRH[SHULHQFH

disproportionately high and adverse human health effects and (1) whether the health effects 

would be significant, aWRUDERYHJHQHUDOO\DFFHSWHGQRUPVZKHWKHUWKHULVNRUUDWHRI

HQYLURQPHQWDOKD]DUGH[SRVXUHZRXOGEHVLJQLILFDQWH[FHHGRUOLNHO\H[FHHGWKHULVNRUUDWHWR

DQDSSURSULDWHFRPSDULVRQJURXSHJWKHJHQHUDOSRSXODWLRQDQGZKHWKHUKHDOWKHIIects 

would occur in a minority or low-income population already affected by cumulative or multiple 

DGYHUVHH[SRVXUHVIURPHQYLURQPHQWDOKD]DUGV15&

7KHLPSDFWVDVVRFLDWHGZLWKSODQWVKXWGRZQDUHGHVFULEHGLQERWKWKH'HFRPPLVVLRQLQJ*(,6

(NRC 2002) DQGWKH/LFHQVH5HQHZDO*(,615&D3ODQWVKXWGRZQDQGWKHUHVXOWLQJ

ORVVRIMREVLQFRPHDQGWD[UHYHQXHFRXOGKDYHDGLVSURSRUWLRQDWHHIIHFWRQPLQRULW\DQGORZLQFRPHSRSXODWLRQV15&D7KHORVVRIWD[UHYHQXHIRUH[DPSOHFRXOGUHGXFHthe 

availability or eliminate some of the community services on which low-income and minority 

SRSXODWLRQVPD\GHSHQG15&D

Environmental impacts associated with decommissioning activities at a nuclear power plant site 

DQGWKHH[WHQWWRZKLFKPLQRULWy and low-income populations could be affected are discussed in 

WKH'HFRPPLVVLRQLQJ*(,615&'HFRPPLVVLRQLQJWKHSRZHUEORFNDQGVSHQWIXHO

pool ZRXOGHYHQWXDOO\UHVXOWLQWKHORVVRIMREVXSRQFRPSOHWLRQ2WKHULPSDFWVZRXOGLQFOXGH

reduced housLQJGHPDQGWD[UHYHQXHVDQGWKHDYDLODELOLW\DQGGHPDQGIRUSXEOLFVHUYLFHV

15&'HFRPPLVVLRQLQJDFWLYLWLHVFRXOGDIIHFWDLUDQGZDWHUTXDOLW\LQWKHDUHDDURXQG

each nuclear plant site, which could cause health and other environmental impacts in minority 

and low-LQFRPHSRSXODWLRQVWKDWPLJKWEHSUHVHQWLQWKHDUHD15&3RSXODWLRQJURXSV

ZLWKSDUWLFXODUUHVRXUFHGHSHQGHQFLHVRUSUDFWLFHVHJVXEVLVWHQFHDJULFXOWXUHKXQWLQJDQG

fishing) could also be disproportionately affected (NRC 20 ,QDGGLWLRQWKHLPSDFWV

associated with eventual decommissioning would be considered when a licensee submits its 

post-VKXWGRZQGHFRPPLVVLRQLQJDFWLYLWLHVUHSRUWIRUUHYLHZXQGHU&)5DRU
&XPXODWLYH,PSDcts 

185(*௅ 6- September 2014 

10 &)5GDQGLWVOLFHQVHWHUPLQDWLRQSlan for review and approval per 

10 CFR DRU&)5L 

%HFDXVHDVPDOOHUZRUNIRUFHZRXOGEHQHHGHGLPSDFWVIURPGHFRPPLVVLRQLQJDQDW-reactor 

,6)6,DUHDQWLFLSDWHGWREHOHVVWKDQLPSDFts resulting from decommissioning the reactor power 

EORFN$VGLVFXVVHGLQ6HFWLRQDSSUR[LPDWHO\ZRUNHUVZRXOGEHQHHGHGWR

decommission an at-UHDFWRU,6)6,RYHUD- WR-\HDUSHULRG'HFRPPLVVLRQLQJRIWKH'76

could occur in parallel and woXOGUHSUHVHQWDPLQRULQFUHDVHWRWKHZRUNIRUFH:RUNIRUFH

QXPEHUVDQGGXUDWLRQRIGHFRPPLVVLRQLQJDFWLYLWLHVZRXOGYDU\IURPVLWHWRVLWH)RUDZD\-

from-UHDFWRU,6)6,VWKHLPSDFWVRIGHFRPPLVVLRQLQJZRXOGEHVLPLODUWRWKRVHDVVRFLDWHGZLWK

decommissioning the power block because the number of workers required to decommission 

ERWKIDFLOLWLHVDUHVLPLODU15&E

6.4.3.3 Conclusion 

Cumulative impacts on minority and low-income populations include the incremental effects 

from continued storage when added to the aggregate effects of other past, present, and 

UHDVRQDEO\IRUHVHHDEOHIXWXUHDFWLRQV$VGLVFXVVHGLQ6HFWLRQDQGRIWKLV*(,6

minority and low-LQFRPHSRSXODWLRQVDUHQRWH[SHFWHGWRH[SHULHQFHGLVSURSRUWLRQDWHO\KLJKDQG

adverse effects from the incremental impacts associated with the continued storage of spent 

IXHO,QDGGLWLRQWKH15&GHWHUPLQHGWKDWGLVSURSRUWLRQDWHO\KLJKDQGDGYHUVHKXPDQKHDOWK

HIIHFWVDUHQRWH[SHFWHGLQVSHFLDOSDWKZD\UHFHSWRUSRSXODWLRQVLQWKHUHJLRQDVDUHVult of 

VXEVLVWHQFHFRQVXPSWLRQRIZDWHUORFDOIRRGILVKDQGZLOGOLIH6LPLODUO\WKHUHZRXOGEHQR

FRQWULEXWRU\HIIHFWVWRKXPDQKHDOWKEH\RQGZKDWLVFXUUHQWO\EHLQJH[SHULHQFHGIRUWKHGXUDWLRQ

WKDWVSHQWIXHOUHPDLQVRQVLWH3RWHQWLDOHIIHFWVRFFXUring from other reasonably foreseeable 

RIIVLWHSURMHFWVZRXOGEHFRQVLGHUHGGXULQJ15&VLWH-VSHFLILFOLFHQVLQJUHYLHZVHJ

construction of an away-from-UHDFWRU,6)6,UHSODFHPHQWRI,6)6,DQGFRQVWUXFWLRQRSHUDWLRQ

DQGUHSODFHPHQWRID'76,QDGGLWion, as indicated in the Commission’s policy statement, 

HQYLURQPHQWDOMXVWLFHLPSDFWVZRXOGEHFRQVLGHUHGGXULQJsite-specific environmental reviews 

for specific NRC licensing actions )5

6.4.4 Air Quality 

This section evaluates the effects of continued storage on air quality resources when added to 

WKHDJJUHJDWHHIIHFWVRIRWKHUSDVWSUHVHQWDQGUHDVRQDEO\IRUHVHHDEOHIXWXUHDFWLRQVAs 

GHVFULEHGLQ6HFWLRQVDQG the incremental impacts from continued storage on air quality 

is SMALL for all timeframes at both at-reactor and away-from-UHDFWRUVWRUDJHIDFLOLWLHVH[FHSW

during short-term storage at away-from-UHDFWRU,6)6,VZKHUHWKHLPSDFWVZRXOGUDQJHIURP

SMALL to MODERATE because construction of a rail spur could result in noticeable impacts on 

DLUTXDOLW\
&XPXODWLYH,PSDFWV

September 2014 6-19 185(*௅

The geographic area considered in the cumulative air quality analysis includes the air quality 

control region in which an at-reactor or away-from-reactor storage facility LVORFDWHG7KLVDUHD

could include one or more counties that comprise the air quality control region surrounding the 

VLWHDVGHVFULEHGLQ6HFWLRQ

6.4.4.1 Potential Cumulative Impacts from General Trends and Activities 

Cumulative impacts on air quality could include degradation of air quality in air quality control 

regions that are already in or near nonattainment or maintenance for one or more national 

DPELHQWDLUTXDOLW\VWDQGDUGV)RUDW-reactor and away-from-reactor storage facilities, 

cumulative impacts could occur due to multiple activities that affect the air quality control region 

QHDUWKHVWRUDJHIDFLOLW\HJ HOHFWULFSRZHUJHQHUDWLRQJURXQGZDWHUDQGDLUWUDQVSRUWDWLRQ

and nearby heavy industries) associated with urbanization and industrial, commercial, 

DJULFXOWXUDODQGWUDQVSRUWDWLRQGHYHORSPHQWHJ15&D–e, 2012a, 2013a–F,QDGGLWLRQ

climate change can impact air quality because of higher or lower ambient air temperatures and 

changes in precipitation rates (GCRP 2014)RUDLUUHVRXUFHVQHDUDW-reactor storage facilities, 

additional cumulative impacts may include the following: (1) cumulative impacts due to the 

YDULRXVLPSDFWVIURPDQLQGLYLGXDOSRZHUSODQWRYHUWLPHHJ employee vehicles and 

emergency diesel generator testing) and (2) cumulative impacts due to closely sited power 

SODQWVHJ air pollutant emissions from nearby coal-ILUHGSRZHUSODQWV15&D

The magnitude of cumulative impacts resulting from all general trends within the air quality 

control region in which a storage facility is located would depend on the nature and location of 

WKHDFWLRQVWKHQXPEHUDQGGHQVLW\RIDFWLRQVDQGWKHH[WHQWWRZKLFKWKHVHDFWLRQVIDFLOLWLHV

RUSURMHFWVHPSOR\PLWLJDWLRQPHDVXUHVWRPLQLPL]HVXFKLPSDFWVThe cumulative impacts 

IURPJHQHUDOWUHQGVDQGDFWLYLWLHVZRXOGUDQJHIURPPLQLPDOHJPLQRUDLUHPLVVLRQV

associated with localized development in the area, see NRC FWRQRWLFHDEOHHJ

emissions from the construction and operation of a nearby coal-ILUHGSODQWVHH15&D

6.4.4.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

Activities 

Cumulative impacts on air quality resources could result from other NRC-regulated or spent 

fuel-related activities, such as (1) decommissioning of the reactor power block (including the 

VSHQWIXHOSRRO,6)6,VDQG'76ORDGLQJRISDFNDJHVIRUWUDQVSRUWDWLRQWRDUHSRVLWRU\DQG

(3) long-UDQJHWUDQVSRUWRIVSHQWIXHOWRDUHSRVLWRU\

Reactor power block decommissioning activities involve the use of large diesel-powered 

equipment for equipment removal, demolition of structures, worker transportation to and from the 

VLWHDQGWUDQVSRUWDWLRQRIGHPROLWLRQGHEULVWRZDVWHGLVSRVDOIDFLOLWLHV,QPRVWFDVHVair quality 

HIIHFWVZRXOGEHUHODWLYHO\PLQRUDQGVKRUWWHUPLQGXUDWLRQ$LUTXDOLW\ control measures, which 

PD\EHUHTXLUHGWRFRPSO\ZLWKDLUTXDOLW\SHUPLWVZRXOGDOVRPLQLPL]HDLUTXDOLW\LPSDFWVThe 

'HFRPPLVVLRQLQJ*(,615&DQDO\]HGWKHDLr quality impacts for decommissioning a 
&XPXODWLYH,PSDFWV

185(*௅ 6-20 September 2014 

UHDFWRULQFOXGLQJWKHVSHQWIXHOSRROV,QWKH'HFRPPLVVLRQLQJ*(,6IRUSRZHUUHDFWRUV

(including spent fuel pools), the NRC determined that there would be minimal impact on air 

quality and concluded that the impacts of decommissioning on air quality are not detectable 

(NRC 2002)7KH15&¶V($VIRUWKH&DOYHUW&OLIIVDQG'LDEOR&DQ\RQDW-UHDFWRU,6)6,VDQGWKH

PFSF away-from-UHDFWRU,6)6,(,6GLGQRWLGHQWLI\DQ\VLJQLILFDQWLPSDFWVRQDLUTXDOLW\

resources during GHFRPPLVVLRQLQJRIWKH,6)6,15&DD7KH15&DVVXPHV

that the types and magnitude of impacts described in the Calvert Cliffs and Diablo Canyon EAs 

DQGWKH3)6)(,6DUHUHSUHVHQWDWLYHRILPSDFWVIURPGHFRPPLVVLRQLQJDQDW-reactor or awayfrom-UHDFWRU,6)6,DWRWKHUVLWHVEHFDXVHWKHVHIDFLOLWLHVDUHW\SLFDOVL]HVRIDW-reactor and awayfrom-UHDFWRU,6)6,VDQGconsidered W\SLFDOGHFRPPLVVLRQLQJPHWKRGV*LYHQWKDWWKHLPSDFWV

IURPGHFRPPLVVLRQLQJUHDFWRUVVSHQWIXHOSRROVDQG,6)6,V would be similar to that described 

LQWKH'HFRPPLVVLRQLQJ*(,6IRUUHDFWRUVDQGVLWH-VSHFLILF,6)6,($VDQGWKH3)6)(,6

LPSDFWVRQDLUTXDOLW\UHVRXUFHVIURPGHFRPPLVVLRQLQJDUHH[SHFWHGWREHPLQLPDO

%HFDXVHWKHVDPHWUDQVSRUWHUVWUXFNVDQGRWKHUIRssil-fuel-powered equipment are used to 

transfer dual-purpose canisters from transportation packages to storage casks as are used to 

transfer them from storage casks to transportation packages, the loading of packages for 

transportation to a repository would have similar air emission sources, levels, and impact 

magnitude as the receiving of spent fuel at an away-from-reactor facility from at-reactor 

ORFDWLRQV$VGHVFULEHGLQ6HFWLRQWKH15&FRQFOXGHGWKDWWKHRSHUDWLRQRIDQDZD\-

from-UHDFWRU,6)6,LQFOXGLQJWKHDFWLYLW\RIORDGLQJFDVNVZRXOGEH60$//7KHUHIRUHWKH

LPSDFWPDJQLWXGHIRUWKHORDGLQJRISDFNDJHVIRUWUDQVSRUWDWLRQWRDUHSRVLWRU\ZRXOGEHVLPLODU

Disposal of spent fuel requires the long-range transportation from the storage site to a 

UHSRVLWRU\7KHDW-UHDFWRUVWRUDJHRSHUDWLRQH[DPLQHVWKHLPSDFWVRIDIDFLOLW\ZLWKD

1,600-MTU capacity whereas the away-from-UHDFWRURSHUDWLRQH[DPLQHVWKHLPSDFWVRIDIDFLOLW\

with a 40,000-078FDSDFLW\7KHFinal Supplemental Environmental Impact Statement for a 

Geologic Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive Waste 

at Yucca Mountain, Nye County, Nevada <XFFD0RXQWDLQ(,6'2(DVVHVVHVWKHDLU

TXDOLW\LPSDFWVIRUWKHWUDQVSRUWDWLRQRI078RIVSHQWIXHOZLWKLQ1HYDGD7KH

<XFFD 0RXQWDLQ(,6FRQFOXGHGWKDWWKHHPLVVLRQVIURPVSHQWIXHOWUDQVSRUWDWLRQGXULQJ

operations would be distributed over the entire length of the route, and no air quality standards 

ZRXOGEHH[FHHGHG%HFDXVHWKHDPRXQWRIspent fuel considered in the transportation 

analyses in this *(,6 LVOHVVWKDQWKHDPRXQWFRQVLGHUHGLQWKH<XFFD0RXQWDLQDQDO\VHVWKH

NRC concludes that the transportation of spent fuel to a repository would not be greater than 

the impact magnitude docuPHQWHGLQWKH<XFFD0RXQWDLQ(,6

6.4.4.3 Conclusion 

Cumulative impacts on air quality include the incremental effects from continued storage when 

added to the aggregate effects of other past, present, and reasonably foreseeable future 

DFWLRQV$VGHVFULEHGLQ6HFWLRQVDQGWKHLQFUHPHQWDOLPSDFWVIURPFRQWLQXHGVWRUDJH
&XPXODWLYH,PSDFWV

September 2014 6-21 185(*௅

on air quality are SMALL for all timeframes for both at-reactor and away-from-reactor storage 

IDFLOLWLHVH[FHSWGXULQJVKRUW-term storage at away-from-UHDFWRU,6)6,VZKHUHWKHLPSDFWV

woulGUDQJHIURP60$//WR02'(5$7(,QDGGLWLRQSDVWSUHVHQWDQGUHDVRQDEO\

foreseeable activities take place in the geographic area of interest that could contribute to 

FXPXODWLYHHIIHFWVWRDLUTXDOLW\UHVRXUFHVThe cumulative impacts from continued storage 

when added to other past, present, and reasonably foreseeable Federal and non-Federal 

activities, such as urbanization, energy development, or other industrial or commercial activities, 

DUH60$//WR02'(5$7($60$//LPSDFWZRXOGRFFXUDWVLWHVZKHUe storage facilities have 

minimal impacts on air quality and no other actions occur that had overlapping, noticeable 

HIIHFWVRQDLUTXDOLW\$02'(5$7(LPSDFWZRXOGRFFXULIRWKHUDFWLRQVRFFXUWKDWGLGKDYH

overlapping and noticeable effects on air quality, such as a nearby fossil-fuel-fired electricity 

JHQHUDWLQJVWDWLRQ$WVWRUDJHIDFLOLWLHVZKHUHWKHLQFUHPHQWDOLPSDFWVZRXOGEH60$//DQGWKH

cumulative impacts would be MODERATE from other Federal or non-Federal activities, the 

NRC determined the cumulative impacts would likely remain MODERATE whether or not 

continued storage occurred because the incremental impacts from continued storage would be 

minor, especially in comparison to other general trends, such as operation of fossil-fuel-fired 

power plaQW

6.4.5 Climate Change 

CRQWLQXHGVWRUDJHDFWLYLWLHVLQYROYHWKHHPLVVLRQRIJUHHQKRXVHJDVHVSULPDULO\FDUERQGLR[LGH

(CO27KHTXDQWLWLHVRIJUHHQKRXVHJDVHPLVVLRQVDUHRIWHQGHVFULEHGLQWHUPVRID&22

IRRWSULQWH[SUHVVHGDVPHWULFWRQVRI&22 HTXLYDOHQW$VGHVFULEHGLQ6HFWLRQVDQGWKH

incremental impacts from continued storage on climate change, in terms of emissions of 

JUHHQKRXVHJDVHV*+*VDUH60$//IRUDOOWLPHIUDPHVDWERWKDW-reactor and away-fromreactor storage facilitiesThe geographic area considered in the cumulative climate change 

DQDO\VLVLVZRUOGZLGH

6.4.5.1 Potential Cumulative Impacts from General Trends and Activities and from 

Other NRC-Regulated or Spent Fuel-Related Activities 

The magnitude of cumulative impacts resulting from all general trends taking place within the 

UHJLRQLQZKLFKDVWRUDJHIDFLOLW\LVORFDWHGPXVWEHSODFHGLQJHRJUDSKLFFRQWH[WIRUWKH

following reasons: 

x 7KHHQYLURQPHQWDOLPSDFWLVJOREDOUDWKHUWKDQORFDORUUHJLRQDO

x The effect is not particulDUO\VHQVLWLYHWRORFDWLRQRIWKHUHOHDVHSRLQW

x 7KHPDJQLWXGHVRILQGLYLGXDO*+*VRXUFHVUHODWHGWRKXPDQDFWLYLW\QRPDWWHUKRZODUJH

FRPSDUHGWRRWKHUVRXUFHVDUHVPDOOZKHQFRPSDUHGWRWKHWRWDOPDVVRI*+*VLQWKH

DWPRVSKHUH

x The total number and vaULHW\RI*+*VRXUFHVLVH[WUHPHO\ODUJHDQGWKHVRXUFHVDUH

XELTXLWRXV
&XPXODWLYH,PSDFWV

185(*௅ 6-22 September 2014 

These points are illustrated by the following comparison of annual CO2 emission rates 

(Table 6-2

Table 6-2&RPSDULVRQRI$QQXDO&DUERQ'LR[LGH(PLVVLRQ5DWHV

Source MT/yr(a)

Global emissions from fossil-fuel combustion (2010)(b) 

86HPLVVLRQVIURPIRVVLO-fuel combustion (2011)(c) 

1,000-0:HQXFOHDUSRZHUSODQWLQFOXGLQJIXHOF\FOHSHUFHQWFDSDFLW\IDFWRU(d) 260,000 

1,000-0:HQXFOHDUSRZHUSODQWGXULQJ6$)6725(d) 

$YHUDJH86KRPH(e) 19 

$YHUDJH86passenger vehicle(e) 

Source: (EPA 2013a, b 15&I H[SUHVVHGLQPHWULFWRQVSHU\HDURICO2

(a) Nuclear power emissions estimates are in units of metric tons of CO2-equivalent whereas the other energy 

alternatives emissions estimates are in units of metric tons of CO2,IQXFOHDUSRZHUHPLVVLRQVZHUHUHSUHVHQWHG

in metric tons of CO2WKHYDOXHZRXOGEHVOLJKWO\OHVVDVRWKHU*+*HPLVVLRQVZRXOGQRWEHLQFOXGHG

(b) (EPA 2013a)&KDSWHUH[SUHVVHGLQPHWULFWRQVSHU\HDURICO2

(c) (EPA 2013a), Table 3-H[SUHVVHGLQPHWULFWRQVSHU\HDURICO2

(d) 15&IH[SUHVVHGLQPHWULFWRQVSHU\HDURICO2-HTXLYDOHQW

(e) (EPA 2013bH[SUHVVHGLQPHWULFWRQVSHU\HDURI&2

(YDOXDWLRQRIFXPXODWLYHLPSDFWVRI*+*HPLVVLRQVUHTXLUHVWKHXVHRIDJOREDOFOLPDWHPRGHO

The GCRP report (GCRP 2014) provides a synthesis of the results of numerous climate 

PRGHOLQJVWXGLHV,QDGGLWLRQ, the CEQ issued draft guidance that recommends synthesis 

reports and peer-reviewed assessments from the GCRP as sources of the best scientific 

information available on reasonably foreseeable climate change impacts (CEQ 2010) The 

15&FRQFOXGHVWKDWWKHFXPXODWLYHLPSDFWVRI*+*HPLVVLRQVDURXQGWKHZRUOGDVSUHVHQWHG

LQWKH*&53UHSRUWDUHWKHDSSURSULDWHEDVLVIRULWVHYDOXDWLRQRIFXPXODWLYHLPSDFWV%DVHG

primarily on the scientific assessments of the GCRP and National Research Council, the EPA 

$GPLQLVWUDWRULVVXHGDGHWHUPLQDWLRQLQ FR WKDW*+*VLQWKHDWPRVSKHUHPD\

reasonably be anticipated to endanger public health and welfare, based on observed and 

SURMHFWHGHIIHFWVRI*+*VWKHLULPSDFWRQFOLPDWHFKDQJe, and the public health and welfare 

ULVNVDQGLPSDFWVDVVRFLDWHGZLWKVXFKFOLPDWHFKDQJH%DVHGRQWKHLPSDFWVVHWIRUWKLQWKH

GCRP report, and the CO2 emissions criteria in the final EPA “Prevention of Significant 

Deterioration and Title V Greenhouse *DV7DLORULQJ5XOH ́)5WKH15&FRQFOXGHV

WKDWWKHQDWLRQDODQGZRUOGZLGHFXPXODWLYHLPSDFWVRI*+*HPLVVLRQVDUHQRWLFHDEOHEXWQRW

GHVWDELOL]LQJ7KHUHYLHZWHDPEDVHVWKLVFRQFOXVLRQWKDWWKHHQYLURQPHQWPD\EHQRWLFHDEO\

DIIHFWHGE\*+*HPLssions but not destabilized on the tailored approach to addressing CO2

emissions in the EPA rule and the EPA Administrator’s determination, neither of which call for 

LPPHGLDWHDFWLRQVXFKDVFORVXUHRI*+*-HPLWWLQJIDFLOLWLHV7KHUHIRUHQDWLRQDODQGZRUOdwide 

FXPXODWLYHLPSDFWVRI*+*HPLVVLRQVUHIOHFWFRQGLWLRQVWKDWDUHQRWLFHDEOHEXWQRW

GHVWDELOL]LQJ7KH15&IXUWKHUFRQFOXGHVWKDWWKHFXPXODWLYHLPSDFWVZRXOGEHQRWLFHDEOH

but QRWGHVWDELOL]LQJZLWKRUZLWKRXWWKH*+*HPLVVLRQVIURPFRQWLQXHGVWRUDJH
&XPXODWLYH,PSDFWV

September 2014 6-23 185(*௅

6.4.5.2 Conclusion 

Cumulative impacts include the incremental effects from continued storage when added to the 

DJJUHJDWHHIIHFWVRIRWKHUSDVWSUHVHQWDQGUHDVRQDEO\IRUHVHHDEOHIXWXUHDFWLRQV$V

GHVFULEHGLQ6HFWLRQVDQGWKHLQFUHPHQWDOLPSDFWVIrom continued storage on climate 

change is SMALL for all timeframes at both at-reactor and away-from-UHDFWRUVWRUDJHIDFLOLWLHV

,QDGGLWLRQSast, present, and reasonably foreseeable activities take place worldwide that could 

contribute to climate change7KHFXPXODWLYHLPSDFWVIURPFRQWLQXHGVWRUDJHZKHQDGGHGWR

other past, present, and reasonably foreseeable Federal and non-Federal activities, such as 

operation of fossil-fuel-ILUHGSRZHUSODQWVZRXOGEH02'(5$7(

At storage facilities where the cumulative impacts would be MODERATE from other Federal or 

non-Federal activities, the NRC determined the cumulative impacts would likely remain 

MODERATE whether or not continued storage occurred because the incremental impacts from 

continued storage would be mLQRUHVSHFLDOO\LQFRPSDULVRQWRRWKHU*+*HPLWWHUVVXFKDV

operation of fossil-fuel-ILUHGSRZHUSODQW

6.4.6 Geology and Soils 

This section evaluates the effects of continued storage on geology and soils when added to the 

aggregate effects of other past, presHQWDQGUHDVRQDEO\IRUHVHHDEOHIXWXUHDFWLRQVAs 

GHVFULEHGLQ6HFWLRQVDQGWKHLQFUHPHQWDOLPSDFWVIURPFRQWLQXHGVWRUDJHRQJHRORJ\

and soils is SMALL for all timeframes at both at-reactor and away-from-UHDFWRUVWRUDJHIDFLOLWLHV

The geographic area considered in this cumulative analysis with regard to soils is the area 

within the site boundaries, and for geology is the area in the immediate vicinity of the at-reactor 

or away-from-reactor storage facility'HSHQGLQJRQWKHVLWHWKHDUHDFRXOd include rural and 

semi-XUEDQUHJLRQVDQGWKHDVVRFLDWHGHQYLURQPHQWDOFRQGLWLRQV

6.4.6.1 Potential Cumulative Impacts from General Trends and Activities 

Cumulative impacts on the geology and soils of an area include (1) access to mineral or energy 

resources, (2) destruction of unique geologic features, (3) soil loss and increased erosion 

potential induced by construction activities, (4) soil compaction and changes to surface drainage 

DVDUHVXOWRIXWLOLWLHVDQGVWUXFWXUHVDQGSRWHQWLDOVRLOFRQWDPLQDWLRQERWKUDGLRORJLFDODQG

nonradiological) through inadvertent spills during normal operations HJ15&D–e, 

2012a, 2013a–c)7KHVHLPSDFWVW\SLFally result from land-disturbing activities, including 

HDUWKPRYLQJJUDGLQJDQGH[FDYDWLRQIURPFRQVWUXFWLQJRSHUDWLQJDQGGHFRPPLVVLRQLQJQHZ

DQGH[LVWLQJHQHUJ\SURGXFLQJSODQWIDFLOLWLHVDQGDVVRFLDWHGLQIUDVWUXFWXUHV/DQGXVDJHLQWKH

vicinity of DVWRUDJHIDFLOLW\PD\DOVRDIIHFWWKHDFFHVVWRPLQHUDORUHQHUJ\UHVRXUFHV
&XPXODWLYH,PSDFWV

185(*௅ 6-24 September 2014 

The magnitude of geology and soils cumulative impacts resulting from general trends taking 

place within the region in which a storage facility is located would depend on current land 

utilization patterns, any proposed land-use changes, the density of impacting activities, and the 

H[WHQWWRZKLFKWKHVHDFWLYLWLHVIDFLOLWLHVRUSURMHFWVHPSOR\PLWLJDWLRQPHDVXUHVWRUHGXFHVXFK

LPSDFWVThe cumulative impacts from general trends and activities would range from minimal 

HJPLQRUJURXQG-disturbing activities associated with localized development in the area, see 

15&GWRQRWLFHDEOHHJVXIILFLHQWGHYHORSPHQWWRQRWLFHDEO\GLVWXUEVRLOQHDUWKH

storage facility, see NRC 20D

6.4.6.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

Activities 

Cumulative impacts on geologic resources and soils could result from other NRC-regulated or 

spent fuel-related activities, such as decommissioning of the reactor power block (including the 

VSHQWIXHOSRRO,6)6,DQG'76

Activities associated with decommissioning of the reactor that have a potential to affect soils 

LQFOXGHDGGLWLRQDQGH[SDQVLRQRIVWDJLQJDQGOD\GRZQDUHDVIRUHTXLSPHQWDQG

(2) construction oIWHPSRUDU\EXLOGLQJVURDGVDQGSDUNLQJDUHDV,QWKH'HFRPPLVVLRQLQJ

*(,6IRUSRZHUUHDFWRUVLQFOXGLQJVSHQWIXHOSRROV15&WKH15&GHWHUPLQHGWKDW

impacts on the soils from these activities would be temporary and would not be detectable or 

dHVWDELOL]LQJ)RUH[DPSOHLQWKHFDVHRIPRVWUHDFWRUVLWHVVXIILFLHQWSUHYLRXVO\GLVWXUEHG

DUHDVDUHDYDLODEOHIRUVWDJLQJOD\GRZQDQGFRQVWUXFWLRQVLWHV7KHUHIRUHLQWKH

'HFRPPLVVLRQLQJ*(,6LWZDVQRWDQWLFLSDWHGWKDWDGGLWLRQDOODQGZRXOGQHHG to be disturbed, 

WKHUHE\UHGXFLQJWKHSRWHQWLDOIRULQFUHDVHGVRLOVLPSDFWV15&,QDGGLWLRQ

LPSOHPHQWLQJEHVWPDQDJHPHQWSUDFWLFHV%03VZRXOGUHGXFHVRLOHURVLRQDQGFRPSDFWLRQ

These practices include, but are not limited to, minimizing the amount of disturbed land, 

stockpiling topsoil on laydown areas prior to use, mulching and seeding in disturbed areas, 

FRYHULQJORRVHPDWHULDOVZLWKJHRWH[WLOHVXVLQJVLOWIHQFHVWRUHGXFHVHGLPHQWORDGLQJWRVXUIDFH

water, and installing proper culvert ouWOHWVWRGLUHFWIORZVLQVWUHDPVRUGUDLQDJHV*LYHQWKDW

the impacts from decommissioning reactors and spent fuel pools would be similar to that 

GHVFULEHGLQWKH'HFRPPLVVLRQLQJ*(,6IRUUHDFWRUVLPSDFWVRQRQVLWHVRLOVGXULQJ

decommissioning of reactorVDQGVSHQWIXHOSRROVDUHH[SHFWHGWREH60$//

$FWLYLWLHVDVVRFLDWHGZLWKGHFRPPLVVLRQLQJRI,6)6,VWKDWFRXOGDIIHFWJHRORJ\DQGVRLOVLQFOXGH

(1) construction of roads and parking areas used during the demolition of the storage pads, 

casks, and support facilities and (2) removing any contaminated soils identified (from both 

radiological and nonradiological inadvertent spills) during the final radiological site survey under 

&)53DUW6XESDUW(35DGLRORJLFDO&ULWHULDIRU/LFHQVH7HUPLQDWLRQ ́ ,QPost cases, 

LPSDFWVDVVRFLDWHGZLWKGHFRPPLVVLRQLQJRI,6)6,VZRXOGEHVLPLODUWRRUOHVVWKDQWKRVH

LPSDFWVDVVRFLDWHGZLWKFRQVWUXFWLRQRI,6)6,V$IWHUGHFRPPLVVLRQLQJDFWLYLWLHVDUHFRPSOHWH

WKHDUHDSUHYLRXVO\RFFXSLHGE\WKH,6)6,VZRXOGW\SLFDOO\Ee covered with topsoil, contoured, 
&XPXODWLYH,PSDFWV

September 2014 6- 185(*௅

DQGUHSODQWHGZLWKQDWLYHYHJHWDWLRQ15&F)RUH[DPSOHWKH15&DVVXPHGWKDWWKH

W\SHVDQGPDJQLWXGHRILPSDFWVIURPGHFRPPLVVLRQLQJDQ,6)6,ZRXOGEHVLPLODUWRWKDW

GHVFULEHGLQWKH&DOYHUW&OLIIV,6)6,/LFHQVHRenewal EA (NRC 2012b) because the facility is a 

W\SLFDOVL]HH[SHFWHGIRUDQ,6)6,DQGWKHDQDO\VLVDVVXPHGW\SLFDOGHFRPPLVVLRQLQJSUDFWLFHV

Specifically, impacts on soils are related to the temporary disturbance of soil horizons as the 

,6)6,IRXQGDWLRQLVUHPRYHGDQGOHYHOLQJDQGUHJUDGLQJRIWKH,6)6,DUHDIROORZLQJ

GHFRPPLVVLRQLQJ15&E7KH15&H[SHFWVWKDWVXEVXUIDFHJHRORJ\ZRXOGQRWEH

LPSDFWHGE\,6)6,GHFRPPLVVLRQLQJEHFDXVHGHFRPPLVVLRQLQJDFWLYLWLHVW\SLFDOO\GRQRWH[WHQG

to a depth tKDWDIIHFWVWKHJHRORJ\15&%HFDXVHWKHLPSDFWVIURPGHFRPPLVVLRQLQJ

at-reactor and away-from-UHDFWRUV,6)6,VZRXOGEHVLPLODUWRWKDWGHVFULEHGLQVLWH-specific 

,6)6,($VDQG(,6VLPSDFWVRQJHRORJ\DQGVRLOVGXULQJGHFRPPLVVLRQLQJDUHH[SHFWHGto be 

60$//

6.4.6.3 Conclusion 

Cumulative impacts on geologic resources and soils include the incremental effects from 

continued storage when added to the aggregate effects of other past, present, and reasonably 

IRUHVHHDEOHIXWXUHDFWLRQV$VGHVFULEHGLQ6HFWLRQVDQGWKHLQFUHPHQWDOLPSDFWVIURP

continued storage on geologic resources and soils is SMALL for all scenarios at both at-reactor 

and away-from-UHDFWRUVWRUDJHIDFLOLWLHV,QDGGLWLRQSast, present, and reasonably foreseeable 

activities take place in the geographic area of interest that could contribute to cumulative effects 

WRJHRORJ\DQGVRLOV7KHFXPXODWLYHLPSDFWVRQJHRORJ\DQGVRLOVIURPFRQWLQXHGVWRUDJH

when added to other past, present, and reasonably foreseeable Federal and non-Federal 

activities, such as power plant construction or urbanization, would range from SMALL to 

02'(5$7($60$//LPSDFWZRXOGRFFXULIQRRWKHUDFWLRQVRFFXUWKDWKDGRYHUODSSLQJ

QRWLFHDEOHHIIHFWVRQJHRORJLFDOUHVRXUFHV$02'(5$7(LPSDFWZRXOG occur if other Federal 

or non-Federal actions, such as construction of new energy facilities, had overlapping impacts 

ZLWKWKHFRQWLQXHGVWRUDJHRIZDVWHWKDWQRWLFHDEO\DOWHUVRLODQGJHRORJLFDOUHVRXUFHV$W

storage facilities where the cumulative impacts would be MODERATE as a result of other 

Federal and non-Federal activities, the NRC determined that the cumulative impacts would 

likely remain MODERATE whether or not continued storage occurred because the incremental 

impacts from continued storage would be minor, especially in comparison to other trends, such 

DVZLGHVSUHDGXUEDQL]DWLRQ

6.4.7 Surface-Water Quality and Use 

This section evaluates the effects of continued storage on surface-water resources when added 

to the aggregate effects of other past, present, and reDVRQDEO\IRUHVHHDEOHIXWXUHDFWLRQVAs 

GHVFULEHGLQ6HFWLRQVDQGWKHLQFUHPHQWDOLPSDFWVIURPFRQWLQXHGVWRUDJHRQVXUIDFHwater resources is SMALL for all timeframes at at-reactor and away-from-reactor storage 

IDFLOLWLHV
&XPXODWLYH,PSDFWV

185(*௅ 6-26 September 2014 

The geographic area considered in the cumulative surface-water resources analysis includes 

WKHSRUWLRQRIZDWHUERGLHVHJVWUHDPVULYHUVSRQGVHVWXDULHVDQGPDULQHZDWHUV

potentially affected by the at-reactor or away-from-reactor storage facility

6.4.7.1 Potential Cumulative Impacts from General Trends and Activities 

Potential cumulative impacts on surface waterbodies would include conflicts in consumptive 

water use and changes to flow patterns and chemical compositions in waterbodies receiving 

discharges from the reactor planWRUVWRUDJHIDFLOLW\HJ15&D–e, 2012a, 2013a–F)RU

at-reactor and away-from-reactor storage sites, cumulative impacts could occur because of 

PXOWLSOHDFWLYLWLHVWKDWDIIHFWWKHVDPHZDWHUERG\HJ conflicting water demands to support 

urban, DJULFXOWXUDOFRPPHUFLDODQGLQGXVWULDOGHYHORSPHQWV,QDGGLWLRQFOLPDWHFKDQJHFDQ

affect surface-water resources near at-reactor and away-from-reactor storage sites because of 

runoff from more intense storms, drought, flooding, and sea-level rise (GCRP 2014)RU

at-reactor storage facilities, additional cumulative impacts on surface-water resources would 

include (1) cumulative impacts due to the various impacts from an individual power plant over 

WLPHHJ consumptive water use, altered current patterns at intake and discharge structures, 

altered chemical gradients) and (2) cumulative impacts due to closely sited power plants 

HJ consumptive water-use conflicts, additive effects of cooling-tower discharges on water 

temperature, and chemical comSRVLWLRQ15&D

The magnitude of cumulative impacts resulting from all general trends taking place within the 

region in which a storage facility is located would depend on the nature and location of the 

actions relative to important waterbodies, the QXPEHUDQGGHQVLW\RIDFWLRQVDQGWKHH[WHQWWR

ZKLFKWKHVHDFWLRQVLHIDFLOLWLHVRUSURMHFWVHPSOR\PLWLJDWLRQPHDVXUHVWRPLQLPL]HVXFK

LPSDFWV7KHFXPXODWLYHLPSDFWVIURPJHQHUDOWUHQGVDQGDFWLYLWLHVZRXOGUDQJHIURPPLQLPDO

HJFRQVXPSWLYH water use from all water users in the watershed would have minor alterations 

WRRYHUDOOYROXPHRIZDWHULQWKHZDWHUVKHGVHH15&GWRQRWLFHDEOHHJWKHGLVFKDUJH

and runoff of increased levels of dissolved solids, particularly during low-flow conditions, could 

QRWLFHDEO\DOWHUZDWHUTXDOLW\VHH15&G,QUDUHVLWXDWLRQVWKHFXPXODWLYHLPSDFWVIURP

JHQHUDOWUHQGVDQGDFWLYLWLHVFRXOGEHGHVWDELOL]LQJHJincreased water demand from power 

plants and the effects of climate change, especiaOO\XQGHUH[WUHPHGURXJKWFRQGLWLRQVFRXOG

potentially destabilize a river systemVHH15&H

6.4.7.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

Activities 

Cumulative impacts on surface-water resources could result from other NRC-regulated or spent 

fuel-related activities, such as ground-disturbing activities that could occur during shutdown, 

preparation activities for transportation of waste to a repository, and decommissioning of the 

UHDFWRUVSHQWIXHOSRRODQG,6)6,,PSacts could result from activities such as removal of 

shoreline or in-water structures, dredging or filling a stream or bay, runoff, and surface soil 
&XPXODWLYH,PSDFWV

September 2014 6- 185(*௅

HURVLRQ,QPRVWFDVHVVXFKVXUIDFH-water disturbances and water use for dust abatement 

would be relatively minor and short-WHUPLQGXUDWLRQStormwater control measures, which 

would be required to comply with National Pollutant Discharge Elimination System (NPDES) 

permits, also would minimize migration of sediments or other contaminants into surface 

waterboGLHV'UHGJLQJRUILOOLQJRIZDWHUERGLHVZRXOGUHTXLUHSHUPLWVIURPWKH86$UP\&RUSV

RI(QJLQHHUV86$&(ZKLFKFRXOGUHTXLUHDGGLWLRQDOPLWLJDWLRQRU%03VWRPLQLPL]HLPSDFWV

on surface-ZDWHUTXDOLW\,QDGGLWLRQRWKHU)HGHUDO6WDWHRUORFDOSHUPits may require or 

VXJJHVW%03V, and WKHOLFHQVHHZRXOGOLNHO\LPSOHPHQW%03VWRPLQLPL]HHURVLRQDQG

VHGLPHQWDWLRQDQGFRQWURODQ\UXQRIIVSLOOVRUOHDNV15&c

,QWKH'HFRPPLVVLRQLQJ*(,6IRUSRZHUUHDFWRUVLQFOXGLQJVSHQWIXHOSRROVWKH NRC (2002) 

determined that there would be minimal impact on surface-water resources and concluded that 

decommissioning nuclear power plants would result in SMALL impacts on surface-water 

UHVRXUFHVThe 15&¶V($VIRUWKH&DOYHUW&OLIIV+XPEROGW%D\DQG'LDEOR&DQ\RQ,6)6,V

DQGWKH3)6),6)6,(,6GLGQRWLGHQWLI\DQ\VLJQLILFDQWLPSDFWVRQVXUIDFH-water resources 

during decommissioning of an at-reactor, or away-from-UHDFWRU,6)6,15&c, 

DE7KH15&DVVXPHVWKDWWKHW\SHVDQGPDJQLWude of impacts from 

GHFRPPLVVLRQLQJDQ,6)6,DWRWKHUVLWHVZRXOGEHVLPLODUWRWKRVHGHVFULEHGLQWKH

Calvert &OLIIV+XPEROGW%D\DQG'LDEOR&DQ\RQ($VDQGWKH3)6)(,6GXHWRWKHOLPLWHG

amount of water required for decommissioning and minimal impacts from ground-disturbing 

DFWLYLWLHV*LYHQWKDWWKHLPSDFWVIURPGHFRPPLVVLRQLQJUHDFWRUVVSHQWIXHOSRROVDQG,6)6,V

ZRXOGEHVLPLODUWRWKRVHGHVFULEHGLQWKH'HFRPPLVVLRQLQJ*(,6IRUUHDFWRUVDQGVLWH-specific 

,6)6,($VDQG(,6LPSDFWVRQVXUIDFH-water resources from decommissioning are not 

H[SHFWHGWREHQRWLFHDEOH

6.4.7.3 Conclusion 

Cumulative impacts on surface-water resources include the incremental effects from continued 

storage when added to the aggregate effects of other past, present, and reasonably foreseeable 

IXWXUHDFWLRQV$VGHVFULEHGLQ6HFWLRQVDQGWKHLQFUHPHQWDOLPSDFWVIURPFRQWLQXHG

storage on surface-water resources is SMALL for all timeframes at at-reactor and away-fromUHDFWRUVWRUDJHIDFLOLWLHV,QDGGLWLRQSast, present, and reasonably foreseeable activities take 

place in the geographic area of interest that could contribute to cumulative effects on surfaceZDWHUUHVRXUFHV7KHFXPXODWLYHLPSDFWVIURPFRQWLQXHGVWRUDJHZKHQDGGHGWRRWKHUSDVW

present, and reasonably foreseeable Federal and non-Federal activities, such as urbanization, 

energy development, operation of other nearby power plants, or other water uses, would be 

60$//WR/$5*(GHSHQGLQJRQWKHFRQGLWLRQVDQGDFWLYLWLHVVXUURXQGLQJWKHVLWH$60$//

impact would occur if no other actions occur that have overlapping, noticeable effects on 

VXUIDFHZDWHU$02'(5$7(LPSDFWZRXOG occur if other Federal or non-Federal actions, such 

as operation of other nearby power plants or future urbanization, had overlapping impacts with 

the continued storage of waste that noticeably altered availability, flow patterns, and quality of 
&XPXODWLYH,PSDFWV

185(*௅ 6- September 2014 

VXUIDFHZDWHU$/$5*(LPSDFWZRXOGRFFXr if other Federal or non-Federal actions had 

overlapping impacts with the continued storage of waste that destabilized surface-water 

resources by permanently diminishing water quantity and water quality, or adversely altering 

flow patterns in surface wateUERGLHV$WVWRUDJHIDFLOLWLHVZKHUHWKHFXPXODWLYHLPSDFWVZRXOG

be MODERATE or LARGE from other Federal or non-Federal activities, the NRC determined 

that the cumulative impacts would likely remain MODERATE or LARGE whether or not 

continued storage occurred because the incremental impacts from continued storage would be 

PLQRUHVSHFLDOO\LQFRPSDULVRQWRRWKHUJHQHUDOWUHQGVVXFKDVFOLPDWHFKDQJH

6.4.8 Groundwater Quality and Use 

This section evaluates the effects of continued storage on groundwater when added to the 

DJJUHJDWHHIIHFWVRIRWKHUSDVWSUHVHQWDQGUHDVRQDEO\IRUHVHHDEOHIXWXUHDFWLRQV$V

GHVFULEHGLQ6HFWLRQVDQGWKHLQFUHPHQWDOLPSDFWVIURPFRQWLQXHGVWRUDJHRQ

groundwater resources is SMALL for all timeframes at both at-reactor and away-from-reactor 

VWRUDJHIDFLOLWLHV

The geographic area considered in the cumulative groundwater resources analysis includes the 

portion of the uppermost aquifer and offsite public groundwater wells potentially affected by the 

at-reactor or away-from-rHDFWRUVWRUDJHIDFLOLW\

6.4.8.1 Potential Cumulative Impacts from General Trends and Activities 

For at-reactor storage facilities, two types of cumulative impacts on groundwater include: 

(1) FRQVXPSWLYHZDWHUXVHDWDQLQGLYLGXDOSRZHUSODQWRYHUWLPHHJgroundwater use for the 

power plant’s potable and reactor water makeup needs) and (2) groundwater quality 

GHJUDGDWLRQEHQHDWKWKHLQGLYLGXDOSRZHUSODQWGXHWRVSLOOVDQGOHDNV15&D)RUERWK

at-reactor and away-from-reactor storage facilities, cumulative impacts on groundwater could 

occur from groundwater demands associated with current and planned urban, commercial, and 

agricultural developments outside the storage facility site and groundwater quality degradation 

at the site due to past and preseQWRIIVLWHDFWLYLWLHV,QDGGLWLRQFOLPDWHFKDQJHDQGDOWHUDWLRQV

in surface topography and watershed use due to new developments can affect groundwater 

levels and water levels in nearby surface ZDWHUERGLHVHJODNHVDQGULYHUV7KHVH

modifications could lead to changes in groundwater flow rates and reversal in groundwater flow 

GLUHFWLRQVDWRUQHDUWKHVLWH)RUH[DPSOHJURXQGZDWHUZLWKGUDZDOVDWFRDVWDOVLWHVFRXOGOHDG

WRVDOWZDWHULQWUXVLRQ0RUHRYHULQWHQVHXVHRIJURXQGZDWHURXWVLGHWKHVLWe for residential, 

industrial, or agricultural uses may cause land subsidence with temporary or permanent 

FKDQJHVLQORFDORUUHJLRQDOJURXQGZDWHUK\GURORJ\

The magnitude of cumulative impacts resulting from all actions taking place within the affected 

groundwater beneath and surrounding the storage facility would depend on the number of 

DFWLRQVIDFLOLWLHVRUSURMHFWVWKDWGUDZZDWHUIURPWKHDTXLIHUWKHRYHUDOOGHPDQGRQWKH
&XPXODWLYH,PSDFWV

September 2014 6-29 185(*௅

aquifer, the hydrogeologic characteristics of the aquifer, and whether facilitLHVIROORZ%03VWR

SURWHFWJURXQGZDWHUUHVRXUFHVIURPGHJUDGDWLRQDQGRYHUSXPSLQJ7KHFXPXODWLYHLPSDFWV

IURPJHQHUDOWUHQGVDQGDFWLYLWLHVZRXOGUDQJHIURPPLQLPDOHJpast and ongoing onsite and 

offsite activities do not cause noticeable impacts on the quality and quantity of groundwater 

resourcesVHH15&GWRQRWLFHDEOHHJpast and ongoing onsite and offsite activities do 

not destabilize, but noticeably alter the quality or quantity of groundwater resources, see NRC 

I,QUDUHVLWXDWions, the cumulative impacts from general trends and activities could be 

GHVWDELOL]LQJHJJURXQGZDWHUEHQHDWKWKHVLWHDQGDGMDFHQWDUHDVKDVEHHQDGYHUVHO\

affected and noticeably destabilized by past and ongoing onsite and offsite activities, see NRC 

F

6.4.8.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

Activities 

Cumulative impacts on groundwater resources could result from other NRC-regulated or spent 

fuel-related activities, such as ground-disturbing activities that could occur during shut down 

DFWLYLWLHVSUHSDUDWLRQDFWLYLWLHVIRUWUDQVSRUWDWLRQRIZDVWHWRDUHSRVLWRU\DVZHOODVGXULQJ

GHFRPPLVVLRQLQJRIWKHUHDFWRUVSHQWIXHOSRRODQG,6)6,'LUHFWLPSDFWVFRXOGUHVXOWIURP

activities such as removal of shoreliQHDFWLYHGUHGJLQJRUILOOLQJRIDVWUHDPRUED\,QGLUHFW

impacts may result from effects such as downward infiltration or seepage of contaminated 

surface water, oil, or other fluids from disturbed ground surface or streams into underlying 

JURXQGZDWHU or from inadvertent changes in horizontal hydraulic gradients from the site to the 

QHDUHVWVXUIDFHZDWHUERG\7KHVHW\SHVRILPSDFWVFRXOGDOWHUJURXQGZDWHUTXDOLW\DQGIORZ

rates, reverse groundwater flow directions, and induce saltwater intrusion at sites near the 

RFHDQ,QPRVWFDVHVKRZHYHUJURXQGZDWHUGLVWXUEDQFHVZRXOGUHVXOWLQUHODWLYHO\PLQRU

LPSDFWV15&:DWHUGHPDQGIRUSRZHUSODQWRSHUDWLRQDOFRROLQJZRXOGGHFUHDVHGXULQJ

ILQDOSRZHUUHDFWRUVKXWGRZQDFWLYLWLHVDQGGHFRPPLVVLRQLQJ :DWHUZLWKGUDZDOVZRXOG

FRQWLQXHWREHVXEMHFWWRDSSOLFDEOHZDWHUDSSURSULDWLRQRUDOORFDWLRQSHUPLWUHTXLUHPHQWVDV

ZHOODV&OHDQ:DWHU$FW6HFWLRQEUHTXLUHPHQWVIRUPLQLPL]LQJDGYHUVHHQYLURQPHQWDO

impacts associated with the use of cooling-water intake VWUXFWXUHV7KLVZRXOGDOVROLPLWWKH

LPSDFWRQVXUILFLDOJURXQGZDWHUV\VWHPV13'(6SHUPLWVZRXOGSUHVFULEHHIIOXHQWOLPLWVIRUWKH

facility’s surface-water discharge to minimize the potential for indirect contamination of 

groundwaterDredging or filling of waterbodies would require permits from the USACE, which 

could UHTXLUHDGGLWLRQDOPLWLJDWLRQRU%03VWRPLQLPL]HLQDGYHUWHQWFKDQJHVLQVLWH

K\GURJHRORJ\DQGWKHSRWHQWLDOIRUVHDZDWHULQWUXVLRQDWDVLWHQHDUWKHRFHDQ

,QWKH'HFRPPLVVLRQLQJ*(,6IRUQXFOHDUSRZHUUHDFWRUVLQFOXGLQJVSHQWIXHOSRROVWKH

NRC (2002) determined that there would be minimal impact on groundwater use and quality and 

concluded that decommissioning nuclear power plants would result in SMALL impacts on 

JURXQGZDWHUThe 15&¶V($VDQG(,6VIRUWKH&DOYHUW&OLIIV+XPEROGW%D\DQG'LDEOR

CaQ\RQ,6)6,VDQGWKH3)6),6)6,(,6GLGQRWLGHQWLI\DQ\VLJQLILFDQWLPSDFWVRQJURXQGZDWHU

resources during decommissioning of an at-reactor, or away-from-UHDFWRU,6)6,15&D
CumulatLYH,PSDFWV

185(*௅ 6-30 September 2014 

FE7KH15&DVVXPHVWKDWWKHW\SHVDQGPDJQLWXGHRILPSDcts from 

GHFRPPLVVLRQLQJDQ,6)6,DWRWKHUVLWHVZRXOGEHVLPLODUWRWKRVHGHVFULEHGLQWKH&DOYHUW

&OLIIV+XPEROGW%D\DQG'LDEOR&DQ\RQ($VDQGWKH3)6)(,6EHFDXVHDVLPLODUDPRXQWRI

ZDWHUXVHLVH[SHFWHG*LYHQWKDWWKHLPSDFWVIURPGHFRPPLVVLRQLQJ reactors, spent fuel pools, 

DQG,6)6,VZRXOGEHVLPLODUWRWKRVHGHVFULEHGLQWKH'HFRPPLVVLRQLQJ*(,6IRUUHDFWRUVDQG

site-VSHFLILF,6)6,($VDQG(,6LPSDFWVRQJURXQGZDWHUIURPGHFRPPLVVLRQLQJDUHH[SHFWHG

WREH60$//

6.4.8.3 Conclusion 

Cumulative impacts on groundwater resources include the incremental effects from continued 

storage when added to the aggregate effects of other past, present, and reasonably foreseeable 

IXWXUHDFWLRQV$VGHVFULEHGLQ6HFWLRQVDQGWKHLQFUHPHQWDOLPSDFWVIURPFRQWLQXed 

storage on groundwater resources is SMALL for all timeframes at both at-reactor and awayfrom-UHDFWRUVWRUDJHIDFLOLWLHV,QDGGLWLRQSast, present, and reasonably foreseeable activities 

take place in the geographic area of interest that could contribute to cumulative effects to 

JURXQGZDWHU7KHFXPXODWLYHLPSDFWVIURPFRQWLQXHGVWRUDJHZKHQDGGHGWRRWKHUSDVW

present, and reasonably foreseeable Federal and non-FHGHUDODFWLYLWLHVVXFKDVXUEDQL]DWLRQ

energy development, landfills, agricultural, inGXVWULDORURWKHUZDWHUXVHUVUDQJHIURP60$//WR

/$5*(GHSHQGLQJRQWKHFRQGLWLRQVDQGDFWLYLWLHVVXUURXQGLQJWKHVLWH$60$//LPSDFWZRXOG

occur if continued storage and no other actions occur that have overlapping, noticeable effects 

RQJURXQGZDWHU A MODERATE impact would occur if other Federal or non-Federal actions, 

such as operation of other nearby power plants or future urbanization, had overlapping impacts 

with the continued storage of waste that noticeably altered groundwater quality and/or with the 

FRQWLQXHGZLWKGUDZDOVRIJURXQGZDWHUWKDWPD\DGYHUVHO\LPSDFWVLWHJURXQGZDWHUK\GURORJ\

A LARGE impact would occur if elevated radionuclide concentrations in groundwater from past 

and ongoing onsite and offsite activities or significant changes in groundwater hydrology at or 

QHDUWKHVLWHHJDOWHUHGK\GUDXOLFLQWHUDFWLRQVEHWZHHQXQGHUO\LQJVKDOORZDQGFRQILQHG

aquifers, or groundwater flow reversal, which may lead to saltwater intrusion at a site near the 

ocean) occur that would destabilize the TXDOLW\DQGTXDQWLW\RIJURXQGZDWHUUHVRXUFHV$W

storage facilities where the cumulative impacts would be MODERATE or LARGE from other 

Federal or non-Federal activities, the NRC determined that the cumulative impacts would likely 

remain MODERATE or LARGE whether or not continued storage occurred because the 

incremental impacts from continued storage would be minor, especially in comparison to other 

JHQHUDOWUHQGVVXFKDVFOLPDWHFKDQJH

6.4.9 Terrestrial Resources 

This section evaluates the effects of continued storage on terrestrial resources, including 

terrestrial special status species and habitats, when added to the aggregate effects of other 

SDVWSUHVHQWDQGUHDVRQDEO\IRUHVHHDEOHIXWXUHDFWLRQV$VGHVFULEHGLQ6HFWLRQWKH

incremental impact on terrestrial resources from continued storage is SMALL for at-reactor 
&XPXODWLYH,PSDFWV

September 2014 6-31 185(*௅

VWRUDJHIDFLOLWLHVGXULQJDOOWLPHIUDPHV$VGHVFULEHGLQ6HFWLRQWKHincremental impacts at 

away-from-reactor storage facilities during the short-term timeframe would be SMALL to 

MODERATE, depending on whether construction activities noticeably alter suitable habitat for 

ORFDOWHUUHVWULDOVSHFLHV'XULQJWKHORQJ-term and indefinite storage timeframes, the impacts at 

away-from-UHDFWRUVWRUDJHIDFLOLWLHVZRXOGEH60$//

The geogrDSKLFDUHDFRQVLGHUHGLQFOXGHVWHUUHVWULDOKDELWDWVRQRUDGMDFHQWWRWKHDW-reactor or 

away-from-reactor storage facility site affected by continued storage as well as other terrestrial 

habitats in the surrounding landscape closely interconnected by movement or migration of 

VSHFLHV ,QDGGLWLRQWHUUHVWULDOHFRORJ\HYDOXDWLRQVIRFXVRQWKHKDELWDWVDQGVSHFLHVERWK

SODQWVDQGDQLPDOVZLWKLQDQHFRV\VWHP

6.4.9.1 Potential Cumulative Impacts from General Trends and Activities 

Cumulative impacts on terrestrial habitats and wildlife may occur because of habitat loss and 

GHJUDGDWLRQGLVWXUEDQFHDQGGLVSODFHPHQWLQMXU\DQGPRUWDOLW\DQGREVWUXFWLRQRIPRYHPHQW

HJ15&D–e, 2012a, 2013a–F)DFWRUVWKDWFRXOGLQIOXHQFHLPSDFWVRQWHUUHVWULDO

resources incluGHH[SRVXUHWRHOHYDWHGQRLVHOHYHOVDQGFRQWDPLQDQWVDOWHUHGVXUIDFH-water 

and groundwater quality and flow patterns, and hazards associated with direct contact with 

SK\VLFDOVWUXFWXUHVHJELUGFROOLVLRQVZLWKEXLOGLQJVDQGRWKHUVWUXFWXUHV$GYHUVe impacts 

W\SLFDOO\UHVXOWIURPDFWLYLWLHVHJFRQVWUXFWLRQDVVRFLDWHGZLWKXUEDQL]DWLRQLQGXVWULDODQG

FRPPHUFLDOGHYHORSPHQWDJULFXOWXUDOGHYHORSPHQWWUDQVSRUWDWLRQGHYHORSPHQWZDWHUSURMHFWV

DQGUHJLRQDOWRXULVPDQGUHFUHDWLRQ0LJUDWRU\DQGPobile species may be affected by activities 

FDUULHGRXWLQORFDWLRQVUHPRWHIURPWKHVWRUDJHIDFLOLW\VLWH9HJHWDWLYHFRPPXQLWLHVLQFOXGLQJ

IORRGSODLQDQGZHWODQGFRPPXQLWLHVDOVRPD\EHDIIHFWHGE\DFWLYLWLHVHJ clearing and 

grading) associated with these actions, thus creating conditions favorable for invasive species to 

HVWDEOLVKLQWKHDUHD

COLPDWHFKDQJHPD\DGGWRWKHFXPXODWLYHLPSDFWRQWHUUHVWULDOVSHFLHVDQGKDELWDWVHJ15&

2011a–e, 2012a, 2013a–c&OLPDWHPRGHOVSURMHFWWKDWWKHUHwill be changes in precipitation 

rates in the United States and that these changes could alter the character of terrestrial habitats 

*&537KLVFRXOGIXUWKHUVWUHVVWHUUHVWULDOresources affected by the activities described 

DERYH)RUH[DPSOHUHGXFHGSUHFLSLWDWLRQFRXOGFRQWULEXWHWRGUDZGRZQVLQVRPHFRROLQJwater sources and contribute to impacts on shoreline habitats of those systems&HUWDLQDUHDV

PLJKWH[SHULHQFHLQFUHDVHGLQVWHDGRIGHFUHDVHGSUHFLSLWDWLRQ,QWKHVHDUHDVLQFUHDVHG

precipitation and sea-level rise could inundate low-O\LQJDUHDVDWFRDVWDOIDFLOLWLHVHJ

NRC G6WRUPIUHTXHQF\DQGLQWHQVLW\DOVRFRXOGLQFUHDVHDQGWHPSHUDWXUHVFRXOGYDU\

ThHSRVLWLRQRIHFRUHJLRQVFDQEHH[SHFWHGWRVKLIWLQUHVSRQVHWRWKHVHFKDQJHVDQG

WHUUHVWULDOHFRV\VWHPVFDQEHH[SHFWHGWRH[SHULHQFHJUDGXDOWUDQVLWLRQVWKDWZLOOVWUHVVVSHFLHV

DQGKDELWDWV*&536LPLODUO\VSHFLHVUDQJHVPD\VKLIWLQDFFRUGDQce with the changing 

HQYLURQPHQWDOFRQGLWLRQVDQGKDELWDWV*&53'XULQJFRQWLQXHGVWRUDJHDVKLIWLQ

species ranges could result in a storage facility affecting certain species that were not present 
&XPXODWLYH,PSDFWV

185(*௅ 6-32 September 2014 

prior to continued storage,IWKHVSHFies is protected under the Endangered Species Act of 

DVDPHQGHG(6$ DQGLIWKHFULWHULDLQ&)5Part 402 are met for initiation or 

reinitiation RI6HFWLRQFRQVXOWDWLRQ the NRC would be required to initiate or reinitiate ESA 

6HFWLRQFRQVXOWDWLRQZLWKWKH86)LVKDQG:LOGOLIH6HUYLFH):6RU1DWLRQDO0DULQH

)LVKHULHV6HUYLFH10)6$VGHVFULEHGLQ6HFWLRQWKH15&ZRXOGHYDOXDWHDQ\SRWHQWLDO

LPSDFWVRQWKRVHVSHFLHVDQG):6RU10)6PD\UHTXLUHPLWLJDWLRQWRPLnimize impacts on 

WKRVHVSHFLHV

The magnitude of cumulative impacts resulting from all general trends taking place within the 

region in which a storage facility is located would depend on the nature and location of the 

actions relative to important terrestrial resources, the number (and density) of actions, and the 

H[WHQWWRZKLFKWKHVHDFWLRQVIDFLOLWLHVRUSURMHFWVHPSOR\PLWLJDWLRQPHDVXUHVWRPLQLPL]H

VXFKLPSDFWV7KHFXPXODWLYHLPSDFWVIURPJHQHUDOWUHQGVDQGDFWLYLWLHVZRXOGUDQJHIURP

minimal (eJWHPSRUDU\DQGPLQRUFKDQJHVWRWHUUHVWULDOKDELWDWIURPOLPLWHGGHYHORSPHQWLQ

WKHDUHDVHH15&EWRQRWLFHDEOHHJQRWLFHDEOHwetland loss and fragmentation of 

wetland and upland forest habitatsVHH15&D

6.4.9.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

Activities 

Cumulative impacts on terrestrial resources could result from other NRC-regulated or spent fuelrelated activities, such as ground-disturbing activities that could occur during shutdown 

DFWLYLWLHVpreparation activities to transport ZDVWHWRDUHSRVLWRU\DQGGHFRPPLVVLRQLQJRIWKH

UHDFWRUVSHQWIXHOSRRODQG,6)6,)RUH[DPSOHLQFUHPHQWDOLPSDFWVFRXOGUHVXOWIURP

shoreline activities (dredging or filling of wetlands), operation of the cooling system on shoreline 

vegetation (water withdrawal and discharge water temperature increases), and habitat 

disturbance and fragmentation from development or removal of infrastructure and power 

transmission-line and cooling-water pipeline rights-of-ways WRVXSSRUWIXWXUHSURMHFWV

,QFUHPHQWDOLPSDFWVIURPFRQWLQXHGVWRUDJHPD\UHVXOWIURPHIIHFWVVXFKDVUXQRIIEHFDXVHRI

ground-GLVWXUELQJDFWLYLWLHVDQGVXUIDFHHURVLRQ7RKHOSSURWHFWWHUUHVWULDOKDELWDWVstormwater 

control measures, which would be required to comply with NPDES permitting, would minimize 

HURVLRQDQGWKHIORZRIGLVWXUEHGVRLOVRURWKHUFRQWDPLQDQWVLQWRWHUUHVWULDOKDELWDWVSome 

activities could require permits from the USACE, which would require mitigation for impacts on 

MXULVGLFWLRQDOZHWODQGV&RQVXOWDWLRQZLWKWKH):6DQG other Federal, State, or local groups 

FRXOGUHVXOWLQWKHLGHQWLILFDWLRQRIDGGLWLRQDOPLWLJDWLRQRU%03Vto minimize impacts on 

terrestrial resources from noise, dust, migratory bird collisions with crane booms or other 

construction equipment, and habitat alteration from introduction of invasive plant species,Q

most cases, terrestrial disturbances would result in relatively minor, short-term impacts 

HJ 15&H
&XPXODWLYH,PSDFWV

September 2014 6-33 185(*௅

,QWKH'HFRPPLVVLRQLQJ*(,6for power reactors (including spent fuel pools), NRC (2002) 

determined that terrestrial resources resulting from activities occurring within the facility’s 

RSHUDWLRQDODUHDVZRXOGEH60$//7KHNRC’s EAs for the Calvert Cliffs (NRC 2012b), 

+XPEROGW%D\15&FDQG'LDEOR&DQ\RQ,6)6,V15&DQGWKH3)6),6)6,(,6

(NRC 2001a) did not identify any significant impacts on terrestrial resources during 

decommissioning of an at-reactor or away-from-UHDFWRU,6)6,7KH15&DVVXPHVWKDWWKH

types and magQLWXGHRILPSDFWVIURPGHFRPPLVVLRQLQJDQ,6)6,DWRWKHUVLWHVZRXOGEHVLPLODU

WRWKDWGHVFULEHGLQWKH&DOYHUW&OLIIV+XPEROGW%D\DQG'LDEOR&DQ\RQ($VDQGWKH3)6)(,6

because of the limited size and minimal impacts from ground-GLVWXUELQJDFWLYLWLHV Therefore, 

impacts from decommissioning would likely result in relatively short-term impacts and, most of 

WKHWLPHZLWKLQSUHYLRXVO\GLVWXUEHGDUHDV*LYHQWKDWWKHLPSDFWVIURPGHFRPPLVVLRQLQJ

UHDFWRUVVSHQWIXHOSRROVDQG,6)6,VZRXOGEHVLPLODUWR impacts described in the 

'HFRPPLVVLRQLQJ*(,6IRUUHDFWRUVDQGVLWH-VSHFLILF,6)6,($VDQG(,6LPSDFWVRQWHUUHVWULDO

resources from decommissioning are H[SHFWHGWREHPLQLPDO

6.4.9.3 Conclusion 

Cumulative impacts on terrestrial resources include the incremental effects from continued 

storage when added to the aggregate effects of other past, present, and reasonably foreseeable 

IXWXUHDFWLRQV$VGHVFULEHGLQ6HFWLRQWKHLQFUHPHQWDOLPSDFWIURPFRQWLQXHGVWRUDJHRQ

terrestrial resources is SMALL for at-reaFWRUVWRUDJHIDFLOLWLHVGXULQJDOOWLPHIUDPHVAs 

GHVFULEHGLQ6HFWLRQWKHincremental impacts at away-from-reactor storage facilities during 

the short-term timeframe would be SMALL to MODERATE, depending on whether construction 

activities noticeably DOWHUVXLWDEOHKDELWDWIRUORFDOWHUUHVWULDOVSHFLHV'XULQJWKHORQJ-term and 

indefinite storage timeframes, the impacts at away-from-reactor storage facilities would be 

60$//,QDGGLWLRQSDVWSUHVHQWDQGUHDVRQDEO\IRUHVHHDEOHDFWLYLWLHVWKDWWDNH place in the 

JHRJUDSKLFDUHDRILQWHUHVWFRXOGFRQWULEXWHWRFXPXODWLYHHIIHFWVWRWHUUHVWULDOUHVRXUFHVThe 

cumulative impacts from continued storage when added to other past, present, and reasonably 

foreseeable Federal and non-Federal activities, such as urbanization and energy development, 

range from SMALL to MODERATE depending on the conditions and activities surrounding the 

VLWH$WVLWHVZKHUHFRQWLQXHGVWRUDJHKDVPLQLPDOLPSDFWVRQWHUUHVWULDOUHVRXUFHVDQGQR

other actions occur that have overlapping, noticeable effects on terrestrial resources, the 

FXPXODWLYHLPSDFWVFDQEHH[SHFWHGWREH60$//$WVLWHVZKHUHFRQVWUXFWLRQRIDQDZD\-

from-reactor storage facility has noticeably altered terrestrial resources, or other actions have 

overlapping, QRWLFHDEOHHIIHFWVRQWHUUHVWULDOUHVRXUFHVWKHFXPXODWLYHLPSDFWVFDQEHH[SHFWHG

WREH02'(5$7()RUH[DPSOHLQPRUHXUEDQL]HGDUHDVZKHUHFHUWDLQKDELWDWVDUHOLPLWHG

MODERATE cumulative impacts may be possible if other Federal or non-Federal actions, such 

as operation of other nearby power plants or future urbanization, have overlapping impacts with 

WKHFRQWLQXHGVWRUDJHRIZDVWHWKDWQRWLFHDEO\DOWHUHGWHUUHVWULDOUHVRXUFHV)RUDW-reactor 

storage facilities where the cumulative impacts would be MODERATE from other Federal or 

non-Federal activities, the NRC determined that the cumulative impacts would likely remain 
&XPXODWLYH,PSDFWV

185(*௅ 6-34 September 2014 

MODERATE whether or not continued storage occurred because the incremental impacts from 

an at-reactor continued storage facility would be minor, especially in comparison to other 

JHQHUDOWUHQGVVXFKDVFOLPDWHFKDQJHRUXUEDQL]DWLRQ

6.4.10 Aquatic Resources 

This section evaluates the effects of continued storage on aquatic resources, including aquatic 

special status species, when added to the aggregate effects of other past, present, and 

UHDVRQDEO\IRUHVHHDEOHIXWXUHDFWLRQV$VGHVFULEHGLQ6HFWLRQVDQGWKHLQFUHPHQWDO

impacts from continued storage on aquatic resources is SMALL for all timeframes at both 

at-reactor and away-from-UHDFWRUVWRUDJHIDFLOLWLHV

The geographic area considered in this analysis includes affected aquatic habitats on or 

DGMDFHQWWRWKHat-reactor or away-from-reactor storage facility site as well as other aquatic 

habitats in the surrounding landscape closely interconnected by movement or migration of 

VSHFLHVXVLQJDIIHFWHGKDELWDWVDepending on the site, this could include the potentially 

affected portion of streams, rivers, ponds, lakes, estuaries, or nearshore habitats of marine 

ZDWHUV

6.4.10.1 Potential Cumulative Impacts from General Trends and Activities 

Cumulative impacts on aquatic habitats and species can include (1) loss and degradation of 

KDELWDW VSHFLHVGLVWXUEDQFHGLVSODFHPHQWLQMXU\DQGPRUWDOLW\ obstruction of 

PRYHPHQWDQGLQWURGXction and spread of invasive species and diseases (as described in 

NRC 2011a–e, 2012a, 2013a–F7KHVHLPSDFWVUHVXOWIURPPDQ\JHQHUDOWUHQGVLGHQWLILHGLQ

Table 6-1VXFKDVLQGXVWULDOFRPPHUFLDODJULFXOWXUDODQGWUDQVSRUWDWLRQGHYHORSPHQW

increased water use and discharges to natural waterbodies from power plant operations 

(including potential replaFHPHQWSRZHUKDELWDWPRGLILFDWLRQDVVRFLDWHGZLWKXUEDQL]DWLRQDQG

ZDWHUGHYHORSPHQWSURMHFWVFRPPHUFLDODQGUHFUHDWLRQDOILVKLQJDQGUHJLRQDOWRXULVPDQG

UHFUHDWLRQ)RUDTXDWLFUHVRXUFHVQHDUDW-reactor storage facilities, additional cumulative 

impaFWVPD\LQFOXGHLPSDFWVIURPDQLQGLYLGXDOSRZHUSODQWRYHUWLPHHJ entrainment, 

impingement, radiological impacts, thermal discharges, and chemical discharges from the 

power plant), (2) the FXPXODWLYHLPSDFWVGXHWRFORVHO\VLWHGSRZHUSODQWVHJ the additive 

effects of entrainment, impingement, radiological impacts, thermal discharges, and chemical 

discharges from all nearby power plants), and (3) cumulative impacts due to multiple general 

WUHQGVWKDWDIIHFWWKHVDPHZDWHUERG\DWWKHUHDFWRUHJ dams, agriculture, urban, and 

LQGXVWULDOGHYHORSPHQW15&D

Climate FKDQJHPD\DGGWRWKHFXPXODWLYHLPSDFWRQDTXDWLFVSHFLHVDQGKDELWDWVHJ

NRC 2011a–e, 2012a, 2013a–cChanges to aquatic habitats could result from increased 

runoff, increased surface-water temperature, increased storm intensity and frequency, sea-level 

ULVHRFHDQDFLGLILFDWLRQDQGRWKHUELRORJLFDOVWUHVVRUV*&53 The position of 
&XPXODWLYH,PSDFWV

September 2014 6- 185(*௅

HFRUHJLRQVFDQEHH[SHFWHGWRVKLIWLQUHVSRQVHWRWKHVHFKDQJHVDQGPDULQHHFRV\VWHPs can 

EHH[SHFWHGWRH[SHULHQFHJUDGXDOtransitions, which would stress VSHFLHVDQGKDELWDWV

Similarly, species ranges may shift in correspondence to the changing environmental conditions 

DQGKDELWDWV*&53,QDddition, cooling system operations or other activities could 

increase the mortality of phytoplankton and macroalgae, which sequester atmospheric CO2 A 

reduction in these populations could mean that fewer organisms would be present to sequester 

atmospheric CO2, which may contribute to climate change

During continued storage, a shift in species ranges due to climate change or other activities 

could result in a storage facility affecting certain species that were not present prior to continued 

VWRUDJH,IWKHVSHFLHVLVSURWHFWHGXQGHUWKH(6$, DQGLIWKHFULWHULDLQ&)5Part 402 are 

met for initiation or reinitiation RI6HFWLRQFRQVXOWDWLRQthe NRC would be required to initiate or 

reinitiate (6$6HFWLRQFRQVXOWDWLRQZLWKWKH):6RU10)6$VGHVFULEHGLQ6HFWLRQWKH

15&ZRXOGHYDOXDWHDQ\SRWHQWLDOLPSDFWVRQWKRVHVSHFLHVDQGWKH):6RU10)6PD\

requirHPLWLJDWLRQWRPLQLPL]HLPSDFWVRQWKRVHVSHFLHV

The magnitude of cumulative impacts resulting from all general trends taking place within the 

region in which a storage facility is located would depend on the nature and location of the 

actions relative tRLPSRUWDQWZDWHUERGLHVWKHQXPEHUDQGGHQVLW\RIDFWLRQVDQGWKHH[WHQWWR

ZKLFKWKHVHDFWLRQVIDFLOLWLHVRUSURMHFWVHPSOR\PLWLJDWLRQPHDVXUHVWRPLQLPL]HVXFK

LPSDFWV7KHFXPXODWLYHLPSDFWVIURPJHQHUDOWUHQGVDQGDFWLYLWLHVZRXOGUDQJHIURPPLnimal 

HJWHPSRUDU\DQGPLQRUFKDQJHVWRDTXDWLFKDELWDWIURPOLPLWHGGHYHORSPHQWLQWKHDUHDVHH

15&FWRQRWLFHDEOHHJSDVWSRZHUSODQWRSHUDWLRQVUHVXOWLQJLQDQRWLFHDEOHGHFOLQHIRU

FHUWDLQILVKVSHFLHVVHH15&D,QUDUHVLWXDWLRQs, the cumulative impacts from general 

WUHQGVDQGDFWLYLWLHVFRXOGEHGHVWDELOL]LQJHJLIFROG-water fish species significantly decline in 

SRSXODWLRQDVDUHVXOWRIVLPXOWDQHRXVO\EHLQJVXEMHFWHGWRLPSLQJHPHQWDQGHQWUDLQPHQW

intense commercial fishing efforts, and warmer waters from climate change, see NRC 2011g

6.4.10.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

Activities 

Cumulative impacts on aquatic resources could result from other NRC-regulated or spent fuelrelated acWLYLWLHVVXFKDVVKXWGRZQDFWLYLWLHVSUHSDULQJZDVWHIRUWUDQVSRUWDWLRQWRDUHSRVLWRU\

DQGGHFRPPLVVLRQLQJRIWKHUHDFWRUSRZHUEORFNLQFOXGLQJWKHVSHQWIXHOSRRO,6)6,VDQG

'76*URXQG-disturbing activities could include the removal of shoreline or in-water structures 

or the active dredging or filling of a stream or bay, which could result in increased runoff and 

VXUIDFHHURVLRQ,QPRVWFDVHVLPSDFWVRQDTXDWLFUHVRXUFHVZRXOGEHPLQRUDQGVKRUW-WHUP

Aquatic habitats would likely be protected by stormwater control measures, which would 

PLQLPL]HWKHIORZRIGLVWXUEHGVRLOVRURWKHUFRQWDPLQDQWVLQWRDTXDWLFIHDWXUHVThese 

measures would be required to comply with 13'(6SHUPLWVDredging or filling of waterbodies 

would require permits from tKH86$&(ZKLFKFRXOGUHTXLUHDGGLWLRQDOPLWLJDWLRQRU%03VWR

PLQLPL]HLPSDFWVRQDTXDWLFUHVRXUFHV,QDGGLWLRQRWKHU)HGHUDO6WDWHRUORFDOSHUPLWVPD\
&XPXODWLYH,PSDFWV

185(*௅ 6-36 September 2014 

UHTXLUHRUVXJJHVW%03VWKDWthe licensee would likely implement to minimize erosion and 

sedimentDWLRQDQGFRQWURODQ\UXQRIIVSLOOVRUOHDNVHJ15&F

Shutdown activities could alter aquatic habitats as the amount of thermal discharge decreases 

RUFHDVHVHQWLUHO\)RUH[DPSOHVRPHDTXDWLFRUJDQLVPVVXFKDVPDQDWHHVFRQJUHJDWHDQG

overwinter in waters that are warmer than the surrounding water because of thermal discharge 

IURPWKHSODQWAs a result, manatees as well as other organisms, such as, sea turtles, or fish, 

could H[SHULHQFHFROGVKRFNEHFDXVHRIWKHFKDQJHLQWHPSHUDWXUHSome of these species are 

SURWHFWHGXQGHUWKH(6$$VGHVFULEHGLQ6HFWLRQfor nuclear power plants with a 

%LRORJLFDO2SLQLRQWKH15&ZRXOGQHHGWRUHLQLWLDWHFRQVXOWDWLRQZLWKWKH):6RU NMFS if there 

LVDVLJQLILFDQWFKDQJHLQWKHSODQWSDUDPHWHUVGHVFULEHGLQWKH%LRORJLFDO2SLQLRQWKDWFRXOG

DIIHFWOLVWHGVSHFLHVRUGHVLJQDWHGFULWLFDOKDELWDWVLQDPDQQHURUWRDQH[WHQWQRWSUHYLRXVO\

considered, such as reduced thermal discharge, anGLIWKHFULWHULDLQ&)5DUHPHWIRU

UHLQLWLDWLRQRI6HFWLRQFRQVXOWDWLRQ Consultation under the ESA would include an assessment 

and potential mitigation factors to offset cROGVKRFNRURWKHUSRWHQWLDOLPSDFWVRQOLVWHGVSHFLHV

,QDGGLWLRQRperation of the spent fuel pool would reduce this impact because some thermal 

GLVFKDUJHZRXOGEHH[SHFWHGGXULQJVSHQWIXHOSRRORSHUDWLRQVDVGHVFULEHGLQ6HFWLRQ

,QWKH'HFRPPLVVLRQLQJ*(,6IRUSRZHUUHDFWRUVLQFOXGLQJVSHQWIXHOSRROVWKHNRC (2002) 

determined that there would be minimal impact on aquatic resources and concluded that 

GHFRPPLVVLRQLQJQXFOHDUSRZHUSODQWVZRXOGUHVXOWLQ60$//LPSDFWVRQDTXDWLFUHVRXUFHV

ThH15&¶V($VIRUWKH&DOYHUW&OLIIV+XPEROGW%D\DQG'LDEOR&DQ\RQ,6)6,VDQGWKH3)6)

,6)6,(,6GLGQRWLGHQWLI\DQ\VLJQLILFDQWLPSDFWVRQDTXDWLFUHVRXUFHVGXULQJGHFRPPLVVLRQLQJ

of an at-reactor or away-from-UHDFWRU,6)6,15&DFE7KH15&

DVVXPHVWKDWWKHW\SHVDQGPDJQLWXGHRILPSDFWVIURPGHFRPPLVVLRQLQJDQ,6)6,DWRWKHUVLWHV

ZRXOGEHVLPLODUWRWKDWGHVFULEHGLQWKHSUHYLRXV($VDQG(,6EHFDXVHRIWKHOLPLWHGDPRXQWRI

water required for decommissioning and minimal impacts from ground-GLVWXUELQJDFWLYLWLHV

*LYHQWKDWWKHLPSDFWVIURPGHFRPPLVVLRQLQJUHDFWRUVVSHQWIXHOSRROVDQG,6)6,VZRXOGEH

VLPLODUWRWKDWGHVFULEHGLQWKH'HFRPPLVVLRQLQJ*(,6IRUUHDFWRUVDQGVLWH-VSHFLILF,6)6,($V

DQG(,6VLPSDFWVRQDTXDWLFUHVRXUFHVIURPGHFRPPLVVLRQLQJLVH[SHFWHGWREHPLQLPDO

6.4.10.3 Conclusion 

Cumulative impacts on aquatic resources include the incremental effects from continued 

storage when added to the aggregate effects of other past, present, and reasonably foreseeable 

future DFWLRQV$VGHVFULEHGLQ6HFWLRQVDQGWKHLQFUHPHQWDOLPSDFWVIURPFRQWLQXHG

storage on aquatic resource is SMALL for all timeframes at both at-reactor and away-fromUHDFWRUVWRUDJHIDFLOLWLHV,QDGGLWLRQSDVWSUHVHQWDQGUHDVRQDEO\IRUHVHHDble activities take 

place in the geographic area of interest that could contribute to cumulative effects on aquatic 

UHVRXUFHVThe cumulative impacts from past, present, and reasonably foreseeable Federal 

and non-FHGHUDODFWLYLWLHVVXFKDVXUEDQL]DWLRQHQHUJ\GHYHORSPHQWRURWKHUZDWHUXVHUV

would range from SMALL to LARGE depending on the conditions and activities surrounding the 
&XPXODWLYH,PSDFWV

September 2014 6- 185(*௅

VLWH$WVLWHVZKHUHWKHVXUURXQGLQJGHYHORSPHQWKDVEHHQOLPLWHGDQGQRRWKHUDFWLRQVRFFXU

that have overlapping, noticeable effects on aquatic resources, the cumulative impacts can be 

H[SHFWHGWREH60$//02'(5$7(FXPXODWLYHLPSDFWVFRXOG occur if other Federal or nonFederal actions, such as operation of other nearby power plants or future urbanization, had 

overlapping impacts with the continued storage of waste that noticeably altered aquatic 

UHVRXUFHV/$5*(LPSDFWVDUHQRWDVOLNHO\EXWFRXOGRFFXUXQGHUH[FHSWLRQDOFLUFXPVWDQFHV

such as if other Federal or non-Federal actions, such as intense fishing pressure or changes in 

aquatic habitats from climate change, had overlapping impacts with the continued storage of 

ZDVWHWKDWGHVWDELOL]HGDTXDWLFUHVRXUFHV$WVWRUDJHIDFLOLWLHVZKHUHWKHFXPXODWLYHLPSDFWV

would be MODERATE or LARGE from other Federal or non-Federal activities, the NRC 

determined that the cumulative impacts would likely remain MODERATE or LARGE whether or 

not continued storage occurred because the incremental impacts from continued storage would 

be minor, especially in comparison to other general trenGVVXFKDVFOLPDWHFKDQJHRUILVKLQJ

6.4.11 Historic and Cultural Resources 

This section evaluates the effects of continued storage on historic and cultural resources when 

added to the aggregate effects of other past, present, and reasonably foreseeable future 

DFWLRQV$VGHVFULEHGLQ6HFWLRQVDQGWKHLQFUHPHQWDOLPSDFWVIURPFRQWLQXHG

storage on historic and cultural resources would be SMALL (no impacts on historic and cultural 

resources) during short-term storage for at-UHDFWRU,6)6,V'XULQJVKRUt-term for away-from 

UHDFWRU,6)6,VDQGGXULQJORQJ-term and indefinite storage timeframes at away-from-reactor and 

at-UHDFWRU,6)6,VWKHLPSDFWVFRXOGUDQJHIURPSMALL to LARGE

The geographic area considered in the cumulative historic and cultural resources analysis 

includes the area of potential effect that may be affected by land-disturbing or other operational 

activities associated with continued storage of spent fuHOLQFOXGLQJWKHYLHZVKHG7KLV

GHWHUPLQDWLRQLVPDGHLUUHVSHFWLYHRIODQGRZQHUVKLSRUFRQWURO&XPXODWLYHLPSDFWVRQKLVWRULF

DQGFXOWXUDOUHVRXUFHVUHODWHWRWKHGDPDJHRUGHVWUXFWLRQRIWKHVHUHVRXUFHVLH

archaeological sites, historic structureVDQGWUDGLWLRQDOFXOWXUDOSURSHUWLHVRUWKHLUFRQWH[W

,PSDFWV to KLVWRULFDQGFXOWXUDOUHVRXUFHVHJDUFKDHRORJLFDOVLWHVRUKLVWRULFVWUXFWXUHVZRXOG

RFFXULIWKHVHUHVRXUFHVLQWKHDUHDRISRWHQWLDOHIIHFWDUHSK\VLFDOO\UHPRYHGRUGLVWXUEHG,Q

this regard, potential cumulative impacts for this resource area are localized and limited to the 

DUHDRISK\VLFDOGLVWXUEDQFH,PSDFWVcould occur if a licensing action results in the introduction 

RIVLJQLILFDQWYLVXDOLQWUXVLRQVZLWKLQWKHYLHZVKHG+LVWRULFDQGFXOWXUDOUHVRXUFHVDre 

nonrenewable resources that are affected by natural and man-PDGHDFWLRQV2QFHWKHVH

UHVRXUFHVDUHUHPRYHGRUGHVWUR\HGWKH\FDQQRWEHUHVWRUHGUHEXLOWRUUHSDLUHGWKHUHIRUHWKH

impact of destruction of historic and cultural resources is a cumulatLYHLPSDFW
&XPXODWLYH,PSDFWV

185(*௅ 6- September 2014 

6.4.11.1 Potential Cumulative Impacts from General Trends and Activities 

Cumulative impacts on historic and cultural resources typically result from ground-disturbing 

DFWLYLWLHVHJHDUWKPRYLQJEODVWLQJJUDGLQJDQGH[FDYDWLRQZLWKLQWKHDUHDRISotential effect 

and are site-VSHFLILF,PSDFWVFRXOGRFFXUIURPDFWLYLWLHVDVVRFLDWHGZLWKQHZHQHUJ\SURMHFWV

HJ replacement power facilities) or potential industrial, commercial, agricultural, and 

transportation if development occurs within the area RISRWHQWLDOHIIHFW15&D)RU

H[DPSOHLIDQHZHQHUJ\SURMHFWLVFR-ORFDWHGZLWKWKHH[LVWLQJDW-reactor or away-from-reactor 

,6)6,WKHUHFRXOGEHDGYHUVHLPSDFWVRQKLVWRULFSURSHUWLHVRUKLVWRULFDQGFXOWXUDOUHVRXUFHV

associated with the consWUXFWLRQDQGRSHUDWLRQRIWKHQHZIDFLOLW\6XFKDFWLYLWLHVPD\GLUHFWO\

GDPDJHRUGHVWUR\FXOWXUDODUWLIDFWVRULQFUHDVHWKHSRWHQWLDOIRUWKHLUH[SRVXUHE\DFFHOHUDWLQJ

HURVLRQOHDYLQJWKHPYXOQHUDEOHWRWKHIWDQGYDQGDOLVP

The magnitude of cumulative impacts resulting from general trends taking place within and 

surrounding the area of potential effect would depend on the nature and location of the actions 

IDFLOLWLHVRUSURMHFWVZKDWUHVRXUFHVDUHSUHVHQWWKHH[WHQWRIODQGGLVWXUEDQFHZKHWKHU

culWXUDOUHVRXUFHVXUYH\VDUHFRQGXFWHGDQGWKHH[WHQWWRZKLFKWKHVHDFWLRQVHPSOR\

PLWLJDWLRQPHDVXUHV$GGLWLRQDOO\RQO\)HGHUDOXQGHUWDNLQJVUHTXLUHFRPSOLDQFHZLWKWKH

1DWLRQDO+LVWRULF3UHVHUYDWLRQ$FW1+3$6HFWLRQSURFHGXUDOUHTXLUHPHQWV+RZever, 

some States have similar SURFHGXUDORUHQYLURQPHQWDOUHYLHZUHTXLUHPHQWV&XPXODWLYH

impacts can UDQJHIURPPLQLPDOHJQRLPSDFWVRQKLVWRULFDQGFXOWXUDOUHVRXUFHV, see NRC 

2011g) to noticeable HJFRQVWUXFWLRQDQGRSHUDWLRQRIDQHZFRDO-fired power plant or new 

transmission lines would result in a noticeable impact on historic and cultural resources, see 

15&FWRGHVWDELOL]LQJHJLPSDFWVRQ three National Register listed/eligible historic 

properties including two historic buildings/structures—%DOWLPRUH	'UXP3RLQW5DLOURDG

[CT–@ and Camp Conoy [CT–1312]—DQGRQHDUFKDHRORJLFDOVLWH>&94] that may be 

the remnants of a residence associated with the lives of slaves and/or tenants, sharecroppers, 

RUIUHHG$IULFDQ$PHULFDQVVHH15&G

6.4.11.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

Activities 

Cumulative impacts on historic and cultural resources could result from other NRC-regulated or 

spent fuel-related activities, such as decommissioning of the reactor power block (including the 

VSHQWIXHOSRRO,6)6,DQG'76

The environmental impacts associated with reactor decommissioning were assessed in the 

'HFRPPLVVLRQLQJ*(,615&$FWLYLWLHVDVVRFLDWHGZLWKGHFRPPLVVLRQLQJRIWKHUHDFWRU

power block (including the spent fuel pool) that could affect historic and cultural resources 

LQFOXGHDGGLWLRQDQGH[Sansion of staging and laydown areas for equipment, (2) construction 

of temporary buildings and parking areas, (3) stabilization, (4) decontamination and 

GLVPDQWOHPHQWDQGUHPRYDORIODUJHUHDFWRUFRPSRQHQWV15&D7KHVH
&XPXODWLYH,PSDFWV

September 2014 6-39 185(*௅

activities could affect cultural resources primarily via land disturbance, which could damage or 

GHVWUR\WKHUHVRXUFHRUDOWHUWKHFRQWH[WXDOVHWWLQJRIKLVWRULFDQGFXOWXUDOUHVRXUFHV

(NRC 'HFRPPLVVLRQLQJDFWLYLWLHVFRQGXFWHGZLWKLQWKHRSHUDWLRQDODUHDVLHWKe 

power EORFNDUHQRWH[SHFWHGWRDIIHFWKLVWRULFDQGFXOWXUDOUHVRXUFHVEHFDXVHPXFKRIWKHODQG

ZLWKLQDQGLPPHGLDWHO\VXUURXQGLQJWKHSRZHUEORFNZDVH[WHQVLYHO\GLVWXUEHGGXULQJLQLWLDO

QXFOHDUSRZHUSODQWFRQVWUXFWLRQ7KHUHIRUHLIJURXQG-disturbing activities are limited to 

RSHUDWLRQDODUHDVLPSDFWVRQKLVWRULFDQGFXOWXUDOUHVRXUFHVZRXOGEH60$//15&

Should ground-disturbing activities occur outside of power block, some impacts could be 

QRWLFHDEOHRUGHVWDELOL]LQJWKHUHFRXOGEHimpacts on historic and cultural resources (NRC 

3ULRUWRJURXQG-disturbing activities commencing in areas outside the power block area, 

cultural resource surveys should be conducted to identify and protect any historic properties and 

RWKHUKLVWRULFDQGFXOWXUDOUHVRXUFHVLHDGKHUHQFHWRPDQDJHPHQWSODQVDQGSURFHGXUHV

$FWLYLWLHVDVVRFLDWHGZLWKGHFRPPLVVLRQLQJRI,6)6,VLQFOXGHGLVPDQWOLQJDQGUHPRYLQJWKH

concrete storage casks, concrete pads, and support facilities, including the DTS, and removing 

DQ\FRQWDPLQDWHGVRLOVLGHQWLILHGGXULQJWKHILQDOUDGLRORJLFDOVLWHVXUYH\$UHYLHZRI15&($V

DQG(,6VIRUVSHFLILFDOO\OLFHQVHGDW-reactor and away-from-UHDFWRU,6)6,VGLGQRWLGHQWLI\DQ\

significant impacts RQKLVWRULFDQGFXOWXUDOUHVRXUFHVGXULQJGHFRPPLVVLRQLQJHJ15&D

Díc, E+RZHYHU, prior to decommissioning activities commencing, a 

final decommissioning plan must be submitted to the NRC for review and approval in 

accordanFHZLWK&)5JíGDQGL,PSDFWVDVVRFLDWHGZLWK

eventual decommissioning of the generally OLFHQVHG,6)6,ZRXOGEHFRQVLGHUHGZKHQDOLFHQVHH

submits its post-shutdown decommissioning activities report for review under 

10 CFR DRU&)5GDQGLWVOLFHQVHWHUPLQDWLRQSODQIRUUHYLHZ

and DSSURYDOSHU&)5DRU&)5LNRC authorization of a final 

decommissioning plan or license termination plan would constitute Federal actions under NEPA 

and would be undertakings XQGHUWKH1+3$7KHVLWH-specific environmental review and 

FRPSOLDQFHZLWKWKH1+3$SURFHVVFRXOGLGHQWLI\KLVWRULFSURSHUWLHVDGYHUVHHIIHFWVDQG

potentially resolve adverse effects to historic properties and impacts on other historic and 

FXOWXUDOUHVRXUFHV$IWHUGHFRPPLVVLRQLQJLVFRPSOHWHGWKHDUHDSUHYLRXVO\RFFXSLHGE\WKHDWreactor or away-from-UHDFWRU,6)6,ZRXOGW\SLFDOO\EHFRYHUHGZLWKWRSVRLOFRQWRXUHGDQG

UHSODQWHGZLWKQDWLYHYHJHWDWLRQ15&D Should ground-disturbing activities occur 

outside RIWKH,6)6,IRRWSULQWVRPHLPSDFWVFRXOGEHQRWLFHDEOHRUGHVWDELOL]LQJ7KH

PDJQLWXGHRILPSDFWODUJHO\GHSHQGVRQZKDWUHVRXUFHVDUHSUHVHQWWKHH[WHQWRISURSRVHG

land disturbance, if the area has been previously surveyed, and if the licensee has management 

SODQVDQGSURFHGXUHVWKDWDUHSURWHFWLYHRIKLVWRULFDQGFXOWXUDOUHVRXUFHV

6.4.11.3 Conclusion 

Cumulative impacts on historic and cultural resources include the incremental effects from 

continued storage when added to the aggregate effects of other past, present, and reasonably 
&XPXODWLYH,PSDFWV

185(*௅ 6-40 September 2014 

IRUHVHHDEOHIXWXUHDFWLRQV$VGHVFULEHGLQ6HFWLRQVDQGWKH incremental impacts 

from continued storage on historic and cultural resources would be SMALL for the short-term 

timeframe for an at-UHDFWRU,6)6,during the short-term for away-from-UHDFWRU,6)6,VDQG

during long-term and indefinite storage timeframes at away-from-reactor and at-UHDFWRU,6)6,V

the impacts could range from SMALL to LARGEThis range takes into consideration routine 

PDLQWHQDQFHDQGPRQLWRULQJLHQRJURXQG-disturbing activities), the absence or avoidance of 

historic and cultural resources, and potential ground-disturbing activities that could affect historic 

DQGFXOWXUDOUHVRXUFHV,QDGGLWLRQWKH analysis also considers uncertainties inherent in 

analyzing this resource area over long timefraPHV7KHVHXQFHUWDLQWLHVLQFOXGHDQ\IXWXUH

GLVFRYHU\RISUHYLRXVO\XQNQRZQKLVWRULFDQGFXOWXUDOUHVRXUFHVUHVRXUFHVWKDWJDLQVLJQLILFDQFH

ZLWKLQWKHYLFLQLW\DQGWKHYLHZVKHGHJQRPLQDWLRQRIDKLVWRULFGLVWULFWGXHWRLPSURYHPHQWV

in knowledge, WHFKQRORJ\DQGH[FDYDWLRQWHFKQLTXHVDQGFKDQJHVDVVRFLDWHGZLWKSUHGLFWLQJ

resources that might be significant to IXWXUHJHQHUDWLRQV ,QDGGLWLRQSDVWSUHVHQWDQG

reasonably foreseeable activities take place in the area of potential effect that could also 

FRQWULEXWHWRFXPXODWLYHHIIHFWVWRKLVWRULFDQGFXOWXUDOUHVRXUFHV7KHFXPXODWLYHLPSDFWVRQ

historic and cultural resources from continued storage when added to other past, present, and 

reasonably foreseeable Federal and non-Federal activities could be SMALL to LARGE which 

FRXOGLQFOXGHUHVRXUFHVWKDWDUHSUHVHQWWKHH[WHQWRISURSRVHGODQGGLVWXUEDQFHSUHYLRXV

surveys, and management plans and procedures that are protective of historic and cultural 

UHVRXUFHV7KHHIIHFWRIWKHDFtions would be a SMALL impact at sites where continued storage 

and no other actions occur that have overlapping, noticeable effects on historic and cultural 

resourceVZLWKLQWKHDUHDRISRWHQWLDOHIIHFW02'(5$7(WR/$5*(LPSDFWV could occur at 

sites where NRC, or other Federal or non-FHGHUDODFWLRQVVXFKDVQHZHQHUJ\SURMHFWVDQG

other forms of potential development within and surrounding the area of potential effect), have 

overlapping impacts with the continued storage of waste that noticeably affect or destabilize 

KLVWRULFDQGFXOWXUDOUHVRXUFHV

6.4.12 Noise 

This section evaluates the effects of continued storage on noise when added to the aggregate 

HIIHFWVRIRWKHUSDVWSUHVHQWDQGUHDVRQDEO\IRUHVHHDEOHIXWXUHDFWLRQV$VGHVFULEHGLQ

6HFWLRQVDQGWKHLQFUHPHQWDOLPSDFWVIURPFRQWLQXHGVWRUDJHRQQRLVHLV60$//

overall for all timeframes for both at-reactor and away-from-UHDFWRUVWRUDJHIDFLOLWLHV

7KHJHRJUDSKLFDUHDFRQVLGHUHGLQWKHFXPXODWLYHQRLVHDQDO\VLVH[WHQGVLQDUDGLXVRIDERXW

 NPPLIURPWKHQRLVHVRXUFHVRULJLQDWLQJIURPDQDW-reactor or away-from-reactor 

VWRUDJHIDFLOLW\VLWH$WDGLVWDQFHRIDERXWNPPLIURPDQRLVHVRXUFHPRVWVRXQG

OHYHOVZRXOGEHUHGXFHGWROHVVWKDQWKH-G%$(3$-recommended threshold for protection 

DJDLQVWRXWGRRUDFWLYLW\LQWHUIHUHQFHDQGDQQR\DQFH$UHFHStor can be affected by noise 

sources from the at-reactor and away-from-UHDFWRU,6)6,VXSWRDERXWNPPLDZD\

7KHUHIRUHWKH15&FRQVLGHUHGRWKHUQRLVHVRXUFHVZLWKLQDNPPLUDGLXVRIWKH
&XPXODWLYH,PSDFWV

September 2014 6-41 185(*௅

UHFHSWRUIRUSRWHQWLDOFXPXODWLYHHIIHFWV7Kis effectively creates a cumulative geographic area 

RILQWHUHVWZLWKLQD NPPLUDGLXVIURPWKHVSHQWIXHOQRLVHVRXUFHV

6.4.12.1 Potential Cumulative Impacts from General Trends and Activities 

Noise levels in the vicinity of a storage facility could be tKHUHVXOWRIDFWLYLWLHVHJWUDIILF

associated with urban, industrial, and commercial development (including transportation 

GHYHORSPHQWDQGZDWHUSURMHFWVHJ15&D–e, 2012a, 2013a–F7KHPDJQLWXGH

of cumulative impacts resulting from all general trends would depend on the plant’s 

SUR[LPLW\ to WKHVHDFWLYLWLHV%HFDXVHQRLVHLPSDFWVFHDVHRQFHDQDFWLYLW\VWRSVWKH

noise would need to occur at the same time as continued storage in order for the 

impacts to be RYHUODSSLQJRUFXPXODWLYH

The magnitude of cumulative impacts resulting from all general trends taking place within the 

cumulative geographic area of interest would (1) be dominated by the loudest audible source 

because noise does not add linearly and (2) depend on the sound level generated by the noise 

VRXUFHVDQGWKHSUR[LPLW\RIWKHUHFHSWRUWRWKHQRLVHVRXUFHV7KHFXPXODWLYHLPSDFWVIURP

JHQHUDOWUHQGVDQGDFWLYLWLHVZRXOGUDQJHIURPPLQLPDOHJWKHVRXQGOHYHOVJHQHUDWHGE\WKH

QRLVHVRXUFHVDQGSUR[LPLW\RIWKHVHVRXUFHVWRUHceptors only produce minor impacts, see 

15&GWRQRWLFHDEOHHJSRWHQWLDOQRLVHOHYHOVIURPFRROLQJ-water system pumps 

associated with the operation of co-ORFDWHGQXFOHDUUHDFWRUXQLWVVHH15&H7KH15&

also acknowledges that the noise impacts from operation of a fossil-fuel power plant near a 

VWRUDJHIDFLOLW\FRXOGUHVXOWLQQRWLFHDEOHLPSDFWVHJGHOLYHU\RIFRDODQGOLPHVWRQHE\WUDLQ

VHH15&H

6.4.12.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

Activities 

Cumulative noise impacts could result from other NRC-regulated or spent fuel-related activities, 

VXFKDVGHFRPPLVVLRQLQJRIWKHUHDFWRUSRZHUEORFNLQFOXGLQJWKHVSHQWIXHOSRRO,6)6,

DQG'76 (2) loading of packages for transportation tRDUHSRVLWRU\DQGORQJ-range 

WUDQVSRUWDWLRQRIVSHQWIXHO

The primary noise source associated with decommissioning of the power reactor block is the 

XVHRIFRQVWUXFWLRQHTXLSPHQWWRGLVPDQWOHDQGUHPRYHEXLOGLQJVDQGVWUXFWXUHV7KH

Decommissioning *(,615&DQDO\]HGQRLVHLPSDFWVIRUGHFRPPLVVLRQLQJDUHDFWRU

(including the spent fuel pools) and determined that the noise impacts would not be noticeable 

HQRXJKWRURXWLQHO\GLVUXSWKXPDQDFWLYLW\+RZHYHUWKLVDQDO\VLVZDVEDVHGRQWKH

implemHQWDWLRQRIVRPHPLWLJDWLRQPHDVXUHVHJUHVWULFWLRQVRQZKHQQRLVHSURGXFLQJ

DFWLYLWLHVFRXOGEHFRQGXFWHG8QPLWLJDWHGLPSDFWVKRZHYHUFRXOGEHGLVUXSWLYHWRKXPDQ

DFWLYLW\6XFKPLWLJDWLRQPHDVXUHVPD\QRWEHUHTXLUHGE\)HGHUDOUHJXODWLRQVEXW may be 

UHTXLUHGE\ORFDORUGLQDQFHV*LYHQWKDWWKHLPSDFWVIURPGHFRPPLVVLRQLQJUHDFWRUVDQGVSHQW
&XPXODWLYH,PSDFWV

185(*௅ 6-42 September 2014 

fuel pools considered in this *(,6 would be similar to that described in the Decommissioning 

*(,6WKHLPSDFWVRQDW-reactor facilities during decommissioQLQJDUHH[SHFWHGWREHPLQLPDO

7KHSULPDU\QRLVHVRXUFHDVVRFLDWHGZLWKGHFRPPLVVLRQLQJRIDQ,6)6,DQG'76LVWKHXVHRI

construction equipment to dismantle and remove concrete storage casks, concrete pads, and 

VXSSRUWIDFLOLWLHV$OWKRXJK,6)6,GHFRPPissioning was not addressed in the Decommissioning 

*(,6LWZDVDGGUHVVHGLQWKH3)6)(,615&D7KH3)6)(,6FRQFOXGHGWKDWWKH

LPSDFWVRYHUDOOZHUH60$//+RZHYHUWKHFRQFOXVLRQZDVEDVHGRQWKHIDFWWKDWWKHGLVWDQFH

between the noise source anGQHDUHVWUHVLGHQWZDVNPPLDQGWKHG%$VRXQGOHYHOV

DWWKHVRXUFHZRXOGEHUHGXFHGWRDPELHQWFRQGLWLRQVDWWKRVHGLVWDQFHV,QDEURDGHU

application for other locations, the distance between noise source and receptor is important 

when assessLQJZKHWKHUWKHVRXQGOHYHOVDOWHUQRWLFHDEO\LPSRUWDQWDWWULEXWHVRIWKHVRXUFH

The loading of packages for transportation to a repository would have similar noise sources, 

noise levels, and impact magnitude as the receiving of spent fuel at an away-from-reactor 

facility from at-UHDFWRUORFDWLRQVDVGHVFULEHGLQ6HFWLRQ7KHUHIRUHFORVHWRWKHVRXUFH

QRLVHOHYHOVZRXOGH[FHHGWKHG%$(3$-recommended level for protection against outdoor 

DFWLYLW\DQGLQWHUIHUHQFHDQGDQQR\DQFH$WGLVWDQFHVJUHDWHUWKDQDERXWNPPLWKH

QRLVHOHYHORIG%$DWWKHVRXUFHZRXOGEHUHGXFHGWREHORZWKLV(3$-recommended 

SURWHFWLRQOHYHO

Disposal of spent fuel requires long-UDQJHWUDQVSRUWDWLRQIURPWKHVWRUDJHVLWHWRDUHSRVLWRU\

The at-reactor VWRUDJHRSHUDWLRQH[DPLQHVWKHLPSDFWVRIDIDFLOLW\ZLWKD-MTU capacity, 

whereas the away-from-UHDFWRUVWRUDJHRSHUDWLRQH[DPLQHVWKHLPSDFWVRIDIDFLOLW\ZLWKD

40,000-078FDSDFLW\7KH<XFFD0RXQWDLQ(,6'2(DVVHVVHGWKHQRLVHLPSDFWVDWthe 

national and state levels for long-UDQJHWUDQVSRUWRI07+0RIVSHQWIXHOWRWKH

UHSRVLWRU\7KH<XFFD0RXQWDLQ(,6FRQFOXGHGWKDWWKHQRLVHLPSDFWVZRXOGEHVPDOODWWKH

national level in comparison with the impacts of other nationwide transporWDWLRQDFWLYLWLHV$WWKH

state level, noise could be noticeable in situations where receptors were near transportation 

URXWHV%HFDXVHWKHDPRXQWRIVSHQWIXHODQGWKHDVVRFLDWHGQXPEHURIVKLSPHQWVLHWKH

frequency at which the source generates noise) considered in the transportation analyses for an 

at-reactor or away-from-UHDFWRUVWRUDJHVLWHLVOHVVWKDQWKDWFRQVLGHUHGLQWKH<XFFD0RXQWDLQ

analyses, the NRC concludes that the transportation noise impacts for an at-reactor or awayfrom-reactor site would not be greater than the impact magnitude defined LQWKH<XFFD

Mountain (,6

6.4.12.3 Conclusion 

Cumulative noise impacts include the incremental effects from continued storage when added to 

the aggregate effects of other past, present, and reasonably foresHHDEOHIXWXUHDFWLRQV$V

GHVFULEHGLQ6HFWLRQVDQGWKHLQFUHPHQWDOLPSDFWVIURPFRQWLQXHGVWRUDJHRQQRLVH

is overall SMALL for all timeframes at both at-reactor and away-from-UHDFWRUVWRUDJHIDFLOLWLHV
&XPXODWLYH,PSDFWV

September 2014 6-43 185(*௅

,QDGGLWLRQSast, present, and reasonably foreseeable activities take place in the geographic 

DUHDRILQWHUHVWWKDWWKDWFRXOGFRQWULEXWHWRFXPXODWLYHHIIHFWVWRQRLVH7KHFXPXODWLYHLPSDFWV

from continued storage when added to other past, present, and reasonably foreseeable Federal 

and non-Federal activities, such as activities from industrial and commercial development, are 

60$//WR02'(5$7(GHSHQGLQJRQWKHQRLVHVRXUFHVDQGSUR[LPLW\WRUHFHSWRUV,QPRVW

FDVHVD60$//FXPXODWLYHLPSDFWZRXOGEHH[SHFWHGDQGZRXOGRFFXULIQRRWKHUDFtions had 

RYHUODSSLQJQRWLFHDEOHHIIHFWVWKDWDOWHUHGLPSRUWDQWDWWULEXWHVRIWKHQRLVH$02'(5$7(

impact could occur if other actions occur that did have overlapping and noticeable impacts that 

altered important noise attributes such as operation of a nearby fossil-fuel-ILUHGSRZHUSODQW$W

storage facilities where the cumulative impacts would be MODERATE from other Federal or 

non-Federal activities, the NRC determined that the cumulative impacts would likely remain 

MODERATE whether or not continued storage occurred because the incremental impacts from 

continued storage would be minor, especially in comparison to other general trends, such as 

operation of a fossil-fuel-ILUHGSRZHUSODQW

6.4.13 Aesthetics 

This section evaluates the effects of continued storage on aesthetic resources when added to 

WKHDJJUHJDWHHIIHFWVRIRWKHUSDVWSUHVHQWDQGUHDVRQDEO\IRUHVHHDEOHIXWXUHDFWLRQVAs 

GHVFULEHGLQ6HFWLRQVDQGWKHLQFUHPHQWDOLPSDFWVIURPFRQWLQXHGVWRUDJHRQ

aesthetics is SMALL for all timeframes for an at-reactor storage facility, and SMALL to 

MODERATE for an away-from-UHDFWRUVWRUDJHIDFLOLW\The geographic area considered in the 

cumulative aesthetic resources analysis includes the area from which the at-reactor or awayfrom-reactor storage facility LVYLVLEOH

6.4.13.1 Potential Cumulative Impacts from General Trends and Activities 

Cumulative impacts on aesthetic resources come from changes to the visual appeal of a tract of 

ODQG7KHPDJQLWXGHRIFXPXODWLYHLPSDFWVRQDHVWKHWLFUHVRXUFHVGHSHQGVRQ the degree to 

ZKLFKWKHIDFLOLW\FRQWUDVWVDGYHUVHO\ZLWKWKHH[LVWLQJODQGVFDSHDQGLVDIXQFWLRQRIWKHYLVLELOLW\

of dry storage pads, canisters, and handling facilities from neighborhoods or roads, across 

waterbodies, or from higher topographic elevatLRQV7KHYLVLELOLW\RIDW-UHDFWRU,6)6,VLV

JHQHUDOO\ORZHUWKDQWKHQXFOHDUSRZHUSODQWEHFDXVHRIWKHORZHUSURILOHRIWKHVWRUDJHIDFLOLW\

Cumulative impacts also depends in part on the degree of public interest and concern over 

potential changes to WKHH[LVWLQJVFHQLFTXDOLW\

The continuation of general trends occurring at or near nuclear power plants and storage 

IDFLOLWLHVFRXOGUHVXOWLQRYHUODSSLQJDHVWKHWLFLPSDFWVGXULQJFRQWLQXHGVWRUDJH)RUH[DPSOH

the construction and operation of energy DQGLQIUDVWUXFWXUHSURMHFWVVXFKDVWUDQVPLVVLRQOLQHV

DQGOLTXHILHGQDWXUDOJDVWHUPLQDOVFRXOGUHVXOWLQQRWLFHDEO\DGYHUVHLPSDFWVRQWKHDUHD

Also, increased population growth in the surrounding area could lead to an increase in the 

number of viewHUVWKHIUHTXHQF\DQGGXUDWLRQRIYLHZVDQGLQWKHSHUFHLYHGLPSDFWOHYHO
&XPXODWLYH,PSDFWV

185(*௅ 6-44 September 2014 

The magnitude of cumulative impacts resulting from all general trends taking place within the 

region in which a storage facility is located would depend on the number of structures affecting 

the landscape, the degree of contrast, the degree of visibility (which, in turn, depends on the 

distance and angle from which the landscape is viewed), the value of the landscape, the 

number of viewers, the frequency and duration of views, and viewer perception of the impact 

OHYHOThe cumulative impacts from general trends and activities would range from minimal 

HJOLPLWHGGHYHORSPHQWUHVXOWHGLQPLQRUFKDQJHVZLWKLQWKHYLHZVKHG>15&F@WR

QRWLFHDEOHHJFRQVWUXFWLRQRIDQHZSRZer plant or storage would noticeably alter the scenic 

quality of the area by introducing an industrial presence into a largely undeveloped landscape, 

VHH15&DDQGD

6.4.13.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

Activities 

Cumulative impacts on aesthetic resources could result from other NRC-regulated or spent fuelUHODWHGDFWLYLWLHVVXFKDVFKDQJHVWRRSHUDWLRQDOFKDUDFWHULVWLFVRIWKHIDFLOLW\HJWKH

condensation plume from a cooling tower) during shutdown and dismantlement, demolition, and 

UHPRYDORIVWUXFWXUHVGXULQJGHFRPPLVVLRQLQJFRXOGKDYHGLUHFWDHVWKHWLFLPSDFWV$HVWKHWLF

impacts from the removal of structures would be a long-term change, and are generally 

considered beneficial to the visual appeal of DVLWH

,QWKH'HFRPPLVVLRQLQJ*(,6IRUSRZHUUHDFWRUVLQFOXGLQJVSHQWIXHOSRROVWKHNRC (2002) 

determined that the impacts on aesthetic resources during decommissioning would be SMALL 

and that any impact would be temporary and would serve to reduce the aesthetic impact of the 

VLWH7KHLPSDFWVIURPGHFRPPLVVLRQLQJ,6)6,VZHUHQRWFRQVLGHUHGLQWKH'HFRPPLVVLRQLQJ

*(,6$HVWKHWLFLPSDFWVIURPGHFRPPLVVLRQLQJWKHVPDOOHUVWUXFWXUHRIDQ,6)6,ZRXOGEHQR

greater than that for decommissioning a nuclear power plant because of the smaller size of the 

,6)6,The 15&¶V($VIRUWKH&DOYHUW&OLIIV6XUU\DQG'LDEOR&DQ\RQ,6)6,VDQGWKH3)6)

,6)6,(,6GLGQRWLGHQWLI\DQ\VLJQLILFDQWLPSDFWVRQDHVWKHWLFUHVRXUFHVGXULQJGHFRPPLVVLRQLQJ

of an at-reactor or away-from-UHDFWRU,6)6,15&DDE7KH15&

DVVXPHVWKDWWKHW\SHVDQGPDJQLWXGHRILPSDFWVIURPGHFRPPLVVLRQLQJDQ,6)6,DWRWKHUVLWHV

would be similar to that described in the Calvert Cliffs, Surry, and Diablo Canyon EAs and the 

PF6)(,6EHFDXVHWKHDFWLYLWLHVWKDWWDNHSODFHGXULQJGHFRPPLVVLRQLQJDQGWKHFKDQJHLQ

visual characteristics that would occur at other sites would be similar to those evaluated in the 

&DOYHUW&OLIIV6XUU\DQG'LDEOR&DQ\RQ($VDQGWKH3)6)(,6

Given thDWWKHLPSDFWVIURPGHFRPPLVVLRQLQJUHDFWRUVVSHQWIXHOSRROVDQG,6)6,VZRXOGEH

VLPLODUWRWKHLPSDFWVGHVFULEHGLQWKH'HFRPPLVVLRQLQJ*(,6IRUUHDFWRUVDQGVLWH-specific 

,6)6,($VDQG(,6VLPSDFWVRQDHVWKHWLFUHVRXUFHVIURPGHFRPPLVVLRQLQJDUHH[SHcted to be 

PLQLPDODQGDQ\LPSDFWZRXOGEHWHPSRUDU\
&XPXODWLYH,PSDFWV

September 2014 6- 185(*௅

6.4.13.3 Conclusions 

Cumulative impacts on aesthetic resources include the incremental effects from continued 

storage when added to the aggregate effects of other past, present, and reasonably foreseeable 

future DFWLRQV$VGHVFULEHGLQ6HFWLRQVDQGWKHLQFUHPHQWDOLPSDFWVIURPFRQWLQXHG

storage on aesthetic resources is SMALL for all timeframes for at-reactor storage facilities and 

SMALL to MODERATE for away-from-UHDFWRUVWRUDJHIDFLOLWLHV,QDGGLWion, past, present, and 

reasonably foreseeable activities take place in the geographic area of interest that could 

FRQWULEXWHWRFXPXODWLYHHIIHFWVWRDHVWKHWLFUHVRXUFHV7KHFXPXODWLYHLPSDFWVIURPFRQWLQXHG

storage and other past, present, and reasonably foreseeable Federal and non-Federal activities 

range from SMALL to MODERATE depending on the incremental impact from the storage 

IDFLOLW\DQGWKHFRQGLWLRQVDQGDFWLYLWLHVVXUURXQGLQJWKHVLWH$60$//LPSDFWZRXOGRFFXUDW

sites where storage facilities have minimal impacts on the viewshed and no other actions occur 

WKDWKDGRYHUODSSLQJQRWLFHDEOHHIIHFWVRQDHVWKHWLFUHVRXUFHV$02'(5$7(LPSDFWZRXOG

occur if the storage facility has a noticeable impact on the viewshed, or if other Federal or nonFederal actions, such as the construction and operation of other nearby power plants or future 

urbanization, had overlapping impacts with the continued storage of waste that noticeably 

DOWHUHGDHVWKHWLFUHVRXUFHV$WVWRUDJHIDFLOLWLHVZKHUHWKHLQFUHPHQWDl impacts are SMALL and 

cumulative impacts are MODERATE from other Federal or non-Federal activities, the NRC 

determined that the cumulative impacts would likely remain MODERATE whether or not 

continued storage occurred because the incremental impacts from continued storage would be 

PLQRUHVSHFLDOO\LQFRPSDULVRQWRRWKHUJHQHUDOWUHQGVVXFKDVFRQVWUXFWLQJQHZSRZHUSODQWV

6.4.14 Waste Management 

This section evaluates the effects of continued storage on the capacity and operating lifespan of 

waste-management facilities when added to the aggregate effects of other past, present, and 

UHDVRQDEO\IRUHVHHDEOHIXWXUHDFWLRQVThe incremental impacts from continued storage on 

ZDVWHPDQDJHPHQWDUHGHVFULEHGLQ6HFWLRQVDQGDQGVXPPDUL]HGLQTable 6-3,Q

addition to the incremental impacts from continued storage, this cumulative impacts analysis 

also considers other past, present, and reasonably foreseeaEOHSURMHFWVWKDWFRXOGDIIHFWZDVWH

PDQDJHPHQW7KHJHRJUDSKLFDUHDFRQVLGHUHGLQWKHFXPXODWLYH//:DQGPL[HG-wastePDQDJHPHQWUHVRXUFHVDQDO\VLVLQFOXGHVWKHFRQWLQHQWDO8QLWHG6WDWHVEHFDXVH//:GLVSRVDO

facilities handle waste generated on a national VFDOH7KHJHRJUDSKLFDUHDFRQVLGHUHGLQWKH

FXPXODWLYHQRQUDGLRDFWLYHZDVWHLHKD]DUGRXVDQGQRQKD]DUGRXVZDVWHVPDQDJHPHQW

resources analysis includes the area where the continued storage of spent fuel occurs and 

nonradioactive waste is sent for dLVSRVDO
&XPXODWLYH,PSDFWV

185(*௅ 6-46 September 2014 

Table 6-36XPPDU\RI,QFUHPHQWDO,PSDFWVIURP&RQWLQXHG6WRUDJHRQ:DVWH0DQDJHPHQW

Storage 

Timeframe 

At-Reactor Storage 

(Section 4.15) 

Away-From-Reactor Storage 

(Section 5.15) 

Short-Term //:

0L[HG:DVWH

Nonradioactive(a)

SMALL 

SMALL 

SMALL 

//:

0L[HG:DVWH

Nonradioactive(a)

SMALL 

SMALL 

SMALL 

Long-Term //:

0L[HG:DVWH

Nonradioactive(a)

SMALL 

SMALL 

SMALL 

//:

0L[HG:DVWH

Nonradioactive(a)

SMALL 

SMALL 

SMALL 

,QGHILQLWH //:

0L[HG:DVWH

Nonradioactive(a)

SMALL 

SMALL 

SMALL to MODERATE 

//:

0L[HG:DVWH

Nonradioactive(a)

SMALL 

SMALL 

SMALL to MODERATE 

(a) 1RQUDGLRDFWLYHZDVWHLQFOXGHVKD]DUGRXVDQGQRQKD]DUGRXVZDVWHV

6.4.14.1 Potential Cumulative Impacts from General Trends and Activities 

Cumulative impacts on waste management could include reduction in landfill capacity needed 

IRUWKHSURSHUGLVSRVDORIWKHWRWDODPRXQWRI//:PL[HGZDVWHDQGQRQUDGLRDFWLYHZDVWH

resulting from all reasonably foreseeable Federal and non-Federal activitieV7KHVHLPSDFWV

result from waste-generating activities associated with residential, commercial, industrial, and 

PLOLWDU\GHYHORSPHQW7KHSRWHQWLDOFXPXODWLYHLPSDFWVDVVRFLDWHGZLWKWKHPDQDJHPHQWRI

HDFKZDVWHW\SHDUHGLVFXVVHGEHORZ

Low-Level Waste and Mixed Waste 

,QDGGLWLRQWR//:JHQHUDWHGDWRSHUDWLQJUHDFWRUVDQGRWKHUXUDQLXPIXHOF\FOHIDFLOLWLHVRWKHU

radioactive waste-generating activities that can occur in the same regions as operating reactors 

LQFOXGLQJDFWLYLWLHVDW'2(DQG86'HSDUWment of Defense installations as well as industrial 

facilities and hospitals where radioisotopes are used for industrial or medical purposes 

(NRC D7KHVHVDPHDFWLYLWLHVDUHSRWHQWLDOJHQHUDWRUVRIERWK//:DQGPL[HGZDVWH

The magnitude of cumulative waste-management impacts resulting from general trends would 

depend on current radioactive waste-generating activities, generation rates, potential changes in 

waste-JHQHUDWLQJDFWLYLWLHVDQGUDWHVDQGWKHH[WHQWWRZKLFKWKHVHZDVWHJHQHUDWRUVHPSOR\

mLWLJDWLRQPHDVXUHVWRUHGXFHVXFKLPSDFWV//:DQGPL[HGZDVWHFDQRQO\EHGLVSRVHGRILQ

DOLPLWHGQXPEHURIGLVSRVDOIDFLOLWLHVDVGHVFULEHGLQ6HFWLRQ'epending on the locations 

of the radioactive waste generators and the locations of available treatment and disposal 

facilities, there could be cumulative impacts resulting from the transportation, treatment, and 

GLVSRVDORIUDGLRDFWLYHZDVWH15&DThe cumulative impacts from general trends and 

DFWLYLWLHVZRXOGUDQJHIURPPLQLPDOHJPLnor changes in available disposal capacity and 

limited development of new governmental, industrial, and medical radioactive waste-generating 
&XPXODWLYH,PSDFWV

September 2014 6- 185(*௅

activities, see NRC 2013a,b) WRQRWLFHDEOHHJORVVLQDYDLODEOHGLVSRVDOFDSDFLW\DQG

H[SDQGHGRUQHZJRYHUQPHQtal, industrial, and medical radioactive waste-JHQHUDWLQJDFWLYLWLHV

Nonradioactive Waste 

,QDGGLWLRQWRQXFOHDUUHDFWRURSHUDWLRQVUHVLGHQWLDOFRPPHUFLDODQGLQGXVWULDODFWLYLWLHVDOVR

JHQHUDWHQRQUDGLRDFWLYHZDVWH1RQUDGLRDFWLYHZDVWHLQFOXGHVKD]ardous and nonhazardous 

ZDVWHVDQGLVW\SLFDOO\GLVSRVHGRILQORFDORUUHJLRQDOWUHDWPHQWIDFLOLWLHVDQGODQGILOOV

+D]DUGRXVZDVWHWUHDWPHQWVWRUDJHDQGGLVSRVDOIDFLOLWLHVRUQRQKD]DUGRXVZDVWHODQGILOOVDUH

constructed and operated by local or regioQDOXQLWVRIJRYHUQPHQWRUSULYDWHFRPSDQLHV7KH

IDFLOLW\VL]HRUODQGILOOFDSDFLW\LVEDVHGRQWKHSURMHFWHGZDVWHGLVSRVDOQHHGVIRUWKH

JHRJUDSKLFDUHDRUUHJLRQWKDWWKHIDFLOLW\RUODQGILOOVHUYHV0XQLFLSDOVROLGZDVWHODQGILOOVLQWKH

United States typically have capacities ranging from 1,200,000 m3 (1,600,000 yd3) to more than 

P3 \G3RIFRPSDFWHGVROLGZDVWH(5()

The magnitude of cumulative impacts from the management of nonradioactive wastes resulting 

from all waste-generating actions taking place in the area in which a storage facility is located 

ZRXOGOLNHO\EHPLQLPDOHJminor changes in available facility or landfill capacity and limited 

increase of waste generation by new residential, commercial, and industrial development, see 

15&DEWRQRWLFHDEOHHJminor changes or decrease in available capacity and PDMRU

increase in waste generation by new residential, commercial, and industrial GHYHORSPHQW

6.4.14.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

Activities 

Cumulative impacts on waste-management resources could result from other NRC-regulated or 

spent fuel-related activities, such as decommissioning of a nuclear power plant (including the 

VSHQWIXHOSRRO,6)6,DQG'767KHVHDFWLYLWLHVZRXOGJHQHUDWH//:PL[HGZDVWHDQG

QRQUDGLRDFWLYHZDVWH$OWKRXJKLWZRXOGQRWDIIHFWQRQUDGLRDFWLYHZDVWHGLVSRVDORQDUHJLRQDO

level because of the local availability of nonradiological disposal facilities, construction and 

operation RIDUHSRVLWRU\IRUVSHQWIXHOGLVSRVDOZRXOGFRQWULEXWHDGGLWLRQDO//:DQGPL[HG

ZDVWHDGGLQJWRWKHFXPXODWLYHLPSDFWVIURP//:DQGPL[HGZDVWHGLVSRVDORQWKHOLPLWHG

QXPEHURIWUHDWPHQWDQGGLVSRVDOIDFLOLWLHVDYDLODEOHWKURXJKRXWWKH8QLWHG6WDWHV

Low-Level Waste and Mixed Waste 

7KH//:DQGPL[HG-waste-management impacts from reactor decommissioning, including a 

VSHQWIXHOSRROZRXOGGHSHQGRQWKHVL]HRIWKHUHDFWRUDQGSRRO7KHHVWLPDWHGYROXPHRI

//:JHQHUDWHGE\UHDFWRUGHFRPPLVVLRQLQJUDQJHV IURPP3 \G3WRP3

(42,900 yd315&7KLVTXDQWLW\RI//:ZRXOGEHJHQHUDWHGRYHUDSHULRGUDQJLQJIURP

DERXWWR\HDUVGHSHQGLQJRQWKHGHFRPPLVVLRQLQJRSWLRQXQGHUWDNHQ15&$

FRQVHUYDWLYHHVWLPDWHRIWKH//:JHQHUDWHGDQQXDOO\XVLQJWKHPD[LPXPYROXPHRI//:RI
&XPXODWLYH,PSDFWV

185(*௅ 6- September 2014 

P3 (42,900 yd3LVP3 \G3IRUDUHDFWRUGHFRPPLVVLRQLQJODVWLQJ\HDUVWR

2,340 m3 (3,060 yd3IRUDUHDFWRUGHFRPPLVVLRQLQJODVWLQJ\HDUV7KLVUDQJHRIDQQXDO

TXDQWLWLHVRI//:LVPXFKODUJHUWKDQWKHDYHUDJHDQQXDOTXDQWLW\RI//:SURGXFHGGXULQJ

reactor operation, which is about 300 m3 (392 yd3) for a pressurized water reactor and about 

600 m3 \G3) for a boiling water reactor (NRC 2013a,QWKH/LFHQVH5HQHZDO*(,6WKH

NRC FRQVLGHUHGWKH//:WKDWZRXOGEHJHQHUDWHGE\GHFRPPLVVLRQLQJDQGFRQFOXGHGWKDW

WKHUHLVUHDVRQDEOHDVVXUDQFHWKDWVXIILFLHQW//:GLVSRVDOFDSDFLW\ZLOOEHPDGHDYDLODEOHZKHQ

needed for facilities to be decommissioned consistent with NRC requirements (N5&D

0L[HGZDVWHZRXOGDOVREHJHQHUDWHGDWDQLQFUHDVHGUDWHGXULQJUHDFWRUGHFRPPLVVLRQLQJ

UHODWLYHWRUHDFWRURSHUDWLRQ7KHTXDQWLW\RIPL[HGZDVWHJHQHUDWHGGXULQJUHDFWRURSHUDWLRQLV

DVPDOOIUDFWLRQRIWKHTXDQWLW\RI//:15&D%HFDXVHRIVLPLODULWLHVLQZDVWHJHQHUDWLQJDFWLYLWLHVGXULQJUHDFWRURSHUDWLRQDQGGHFRPPLVVLRQLQJWKHTXDQWLW\RIPL[HGZDVWH

JHQHUDWHGGXULQJUHDFWRUGHFRPPLVVLRQLQJLVH[SHFWHGWRFRQWLQXHWREHDVPDOOIUDFWLRQRIWKH

TXDQWLW\RI//:'HVSLWHDQLQFUHDVHLQWKHJHQHUDWLRQUDWHRIPL[HGZDVWHGXULQJ

GHFRPPLVVLRQLQJWKHTXDQWLW\RIPL[HGZDVWHSURGXFHGLVH[SHFWHGWRUHPDLQVPDOOUHODWLYHWR

DYDLODEOHGLVSRVDOFDSDFLW\

7KHGHFRPPLVVLRQLQJRIGU\VSHQWIXHOVWRUDJHIDFLOLWLHVZRXOGDOVRJHQHUDWH//:DQGPL[HG

ZDVWH7KHW\SHVDQGTXDQWLWLHVRI//:DQGPL[HGZDVWHJHQHUDWHGGXULQJGHFRPPLVVLRQLQJ

ZRXOGEHVLPLODUWRIDFLOLW\UHSODFHPHQWDVGHVFULEHGLQ6HFWLRQVDQG7KH15&KDV

GHWHUPLQHGDVGHVFULEHGLQ6HFWLRQVDQGWKDWWKHLQcremental impacts from the 

PDQDJHPHQWDQGGLVSRVDORI//:DQGPL[HGZDVWHDVVRFLDWHGZLWKIDFLOLW\UHSODFHPHQWZRXOG

EH60$//IRU//:DQGPL[HGZDVWH

7KHFRQVWUXFWLRQDQGRSHUDWLRQRIDUHSRVLWRU\IRUVSHQWIXHOGLVSRVDOZRXOGDOVRJHQHUDWH//:

The finaO(,6IRUWKHSURSRVHGUHSRVLWRU\DW<XFFD0RXQWDLQ1HYDGDSURMHFWHGWKDWP3

\G3RI//:ZRXOGEHJHQHUDWHGIURPWKHFRQVWUXFWLRQDQGRSHUDWLRQRIWKDWIDFLOLW\

'2(7KHSHULRGRIFRQVWUXFWLRQDQGRSHUDWLRQRIWKHSURSRVHGUHSRVLWRry was 

HVWLPDWHGWREHJUHDWHUWKDQ\HDUV7KH'2(GHWHUPLQHGWKDWWKHHQYLURQPHQWDOLPSDFWV

IURPPDQDJHPHQWDQGGLVSRVDORI//:ZRXOGEH60$//EHFDXVHWKHWUHDWPHQWDQGGLVSRVDO

FDSDFLW\H[FHHGVWKHGHPDQGFUHDWHGE\WKHTXDQWLWLHVRI//:JHQHUDWHG The DOE indicated 

WKDWQRPL[HGZDVWHZRXOGEHJHQHUDWHGGXULQJWKHFRQVWUXFWLRQDQGRSHUDWLRQRIWKHUHSRVLWRU\

'2(

The magnitude of cumulative waste-management impacts resulting from management and 

GLVSRVDORI//:DQGPL[HGZDVWHJHQHUDWHGIURP decommissioning of nuclear facilities and 

construction and operation of a repository for spent fuel disposal would depend on current 

radioactive waste-generating activities and generation rates and potential changes in wasteJHQHUDWLQJDFWLYLWLHVDQGUDWHV,WZRXOGDOVRGHSHQGRQWKHH[WHQWWRZKLFKWKHVHZDVWH

JHQHUDWRUVHPSOR\PLWLJDWLRQPHDVXUHVWRUHGXFHVXFKLPSDFWVThe cumulative impacts from 

JHQHUDOWUHQGVDQGDFWLYLWLHVZRXOGUDQJHIURPPLQLPDOHJPLQRUFKDnges in available 
&XPXODWLYH,PSDFWV

September 2014 6-49 185(*௅

disposal capacity and limited or no increases in other NRC-regulated or spent fuel-related 

radioactive waste-generating activities,) WRQRWLFHDEOHHJORVVLQDYDLODEOHGLVSRVDOFDSDFLW\

and increases in other NRC-regulated or spent fuel-related activities that produce radioactive 

ZDVWH/DUJHFXPXODWLYHZDVWH-management impacts could occur in the unlikely event that 

available disposal capacity decreases and radioactive waste generation increases as a result of 

multiple other NRC-regulated or spent fuel-UHODWHGDFWLYLWLHVRFFXUULQJFRQFXUUHQWO\

Nonradioactive Waste 

The nonradioactive waste-management impacts from reactor decommissioning, including a 

VSHQWIXHOSRROZRXOGGHSHQGRQWKHVL]HRIWKHUHDFWRUDQGSRRO6LPLODUWR//:DQG PL[HG

waste, reactor decommissioning generates nonradioactive waste at an increased rate relative to 

RSHUDWLRQRYHUDSHULRGUDQJLQJIURPDERXWWR\HDUVGHSHQGLQJRQWKHGHFRPPLVVLRQLQJ

RSWLRQXQGHUWDNHQ%HFDXVHWKHLQFUHDVHGZDVWHJHQHUDWLRQGXULng decommissioning occurs 

for a relatively short period of time and decommissioned reactors must continue to comply with 

Federal and State regulations in terms of storage, treatment, and disposal of waste, the NRC 

GHWHUPLQHGLQWKH/LFHQVH5HQHZDO*(,615C 2013a) that the cumulative impacts resulting 

from the management of nonradioactive wastes resulting from all waste-generating actions 

WDNLQJSODFHZLWKLQWKHUHJLRQLQZKLFKDQRSHUDWLQJUHDFWRULVORFDWHGZRXOGEH60$//

The decommissioning of dry spent fuel storage facilities would also generate nonradioactive 

waste, primarily nonhazardous ZDVWH7KHW\SHVDQGTXDQWLWLHVRIQRQUDGLRDFWLYHZDVWH

generated during decommissioning would be similar to facility replacement, as described in 

6HFWLRQVDQG7KH15&KDVGHWHUPLQHGDVGHVFULEHGLQ6HFWLRQVDQGWKDW

the incremental impacts from management and disposal of nonradioactive waste associated 

with dry storage facility replacement would be SMALL for short-term and long-term storage and 

60$//WR02'(5$7(IRULQGHILQLWHVWRUDJH

The magnitude of cumulative waste-management impacts resulting from management and 

disposal of nonradioactive waste generated during decommissioning of nuclear facilities would 

depend on current nonradioactive waste-generating activities and generation rates, potential 

changes in waste-JHQHUDWLQJDFWLYLWLHVDQGUDWHVLQDQDUHDDQGWKHH[WHQWWRZKLFKZDVWH

generators in an area employ mitigation measures to reduce such imSDFWVThe cumulative 

LPSDFWVIURPJHQHUDOWUHQGVDQGDFWLYLWLHVZRXOGUDQJHIURPPLQLPDOHJPLQRUFKDQJHVLQ

available landfill capacity and limited or no increases in other NRC-regulated or spent fuelrelated radioactive waste-generating activities,) WRQRWLFHDEOHHJORVVLQDYDLODEOHODQGILOO

capacity and increases in other NRC-regulated or spent fuel-related activities that produce 

QRQUDGLRDFWLYHZDVWH/DUJHFXPXODWLYHZDVWH-management impacts could occur in the 

unlikely event that available landfill capacity decreases and nonradioactive nonhazardous waste 

generation increases as a result of multiple other NRC-regulated or spent fuel-related activities 

RFFXUULQJFRQFXUUHQWO\
&XPXODWLYH,PSDFWV

185(*௅ 6- September 2014 

6.4.14.3 Conclusion 

Cumulative impacts on waste-management resources include the incremental effects from 

continued storage when added to the aggregate effects of other past, present, and reasonably 

IRUHVHHDEOHIXWXUHDFWLRQV7KHLQFUHPHQWDOLPSDFWVIURPFRQWLQXHGVWRUDJHRQZDVWHmanagement resources are described in Sections 4DQGDQGVXPPDUL]HGLQTable 6-3

,QDGGLWLRQSast, present, and reasonably foreseeable Federal and non-Federal activities 

GHVFULEHGLQ6HFWLRQVDQGVSUHDGDFURVVWKHJHRJUDSKLFDUHDRILQWHUHVWQDWLRQDO

scale), DUH60$//WR/$5*(IRU//:DQGPL[HGZDVWHEHFDXVHORFDOUHJLRQDORUQDWLRQDO

waste-PDQDJHPHQWUHVRXUFHVPLJKWH[SHULHQFHPLQRUWRGHVWDELOL]LQJGHFUHDVHVLQWKHLU

FDSDFLW\)RUQRQUDGLRDFWLYHZDVWHWKHFXPXODWLYHLPSDFWVIURPRWKHUSDVWSUHVHQWand 

reasonably foreseeable Federal and non-Federal activities spread across the geographic area 

of interest (area surrounding an at-reactor or away-from-reactor spent fuel storage facility) 

ZRXOGEH60$//WR/$5*($60$//LPSDFWZRXOGRFFXULIORFDOUHJional, or national wastePDQDJHPHQWIDFLOLWLHVH[SHULHQFHQRQRWLFHDEOHGHFUHDVHVLQWKHLUFDSDFLW\RURSHUDWLQJOLIHVSDQ

from continued storage or other Federal or non-FHGHUDODFWLYLWLHV$02'(5$7(LPSDFWZRXOG

occur if local, regional, or national waste-PDQDJHPHQWIDFLOLWLHVH[SHULHQFHQRWLFHDEOH

GHFUHDVHVLQWKHLUFDSDFLW\RURSHUDWLQJOLIHVSDQ$/$5*(LPSDFWZRXOGRFFXULQWKHXQOLNHO\

HYHQWWKDWDYDLODEOH//:RUQRQUDGLRDFWLYHnonhazardous waste disposal capacity decreases 

DQG//:RUQRQUDGLRDFWLYH nonhazardous waste generation increases as a result of multiple 

other NRC-regulated or spent fuel-UHODWHGDFWLYLWLHVRFFXUULQJFRQFXUUHQWO\7KH15&

determined that these cumulative impacts (ranging from SMALL to LARGE) could increase as a 

result of continued storage of spent fuel because the incremental impacts from continued 

storage would range from minor to noticeable, which could increase a SMALL cumulative 

impact to a MODERATE cumulative impact or a MODERATE cumulative impact to a LARGE 

cumulative imSDFW

6.4.15 Transportation 

This section evaluates the effects of continued storage on transportation when added to the 

DJJUHJDWHHIIHFWVRIRWKHUSDVWSUHVHQWDQGUHDVRQDEO\IRUHVHHDEOHIXWXUHDFWLRQVAs 

GHVFULEHGLQ6HFWLRQVDQGWKHLQFUHPHQWDOLmpacts from continued storage on 

nonradiological transportation are SMALL for all timeframes at at-reactor facilities and SMALL to 

MODERATE at away-from-UHDFWRU,6)6,V7KHUDGLRORJLFDOWUDQVSRUWDWLRQLPSDFWVIRUDW-reactor 

and away-from-reactor continued VWRUDJHDFWLYLWLHVDUH60$//

The geographic area considered in the cumulative transportation analysis includes the site of 

the power plant and at-UHDFWRU,6)6,WKHVLWHRIDQDZD\-from-UHDFWRU,6)6,DQGWKHORFDO

regional, and national transportation networks and populations that use or live along these 

networks.
&XPXODWLYH,PSDFWV

September 2014 6- 185(*௅

6.4.15.1 Potential Cumulative Impacts from General Trends and Activities 

Cumulative transportation impacts involve (1) nonradiological impacts, such as increased traffic 

HJFRPPXWLQJZRUNHUVDQGFRnstruction materials) and associated increases in accident 

ULVNVLQMXULHVDQGIDWDOLWLHVDQGUDGLRORJLFDOLPSDFWVVXFKDVUDGLDWLRQGRVHVIURPWKH

shipment of radioactive materials including unirradiated fuel, spent fuel, and waste materials 

(NRC 2011a–HDDETraffic impacts can accumulate from multiple actions 

RFFXUULQJGXULQJWKHVDPHWLPHSHULRGHJRYHUODSSLQJFRQVWUXFWLRQSURMHFWV3ULQFLSDO

contributors to localized traffic that could overlap with storage facility construction and 

RSHUDWLRQVLQFOXGHWKHFRQVWUXFWLRQRIRWKHUHQHUJ\ZDWHUPLOLWDU\RUXUEDQL]DWLRQSURMHFWV

Radiation dose impacts can accumulate from multiple shipping activities that overlap during the 

same time period or from single or multiple shipping actions that occur over time on the same 

URXWHV$FWLRQVLQYROYLQJVKLSPHQWRIUDGLRDFWLYHPDWHULDOVIRUPHGLFDOLQGXVWULDOUHVHDUFKRU

RWKHUHQHUJ\SURMHFWV(NRC 2011a,c,d) could also overlap with continued storage radioactive 

material shipment imSDFWV

The magnitude of cumulative impacts resulting from general trends taking place within the 

region in which a storage facility is located would depend on the nature and location of the 

DFWLRQVUHODWLYHWRWKHVWRUDJHIDFLOLW\WUDQVSRUWDWLRQDFWLYLWLHVFor nonradiological transportation 

impacts, the cumulative impacts from general trends and activities would range from minimal 

HJQRRYHUODSLQWUDIILFZLWKDQ\RWKHUGHYHORSPHQWSURMHFWVHHFXPXODWLYHRSHUDWLRQDOWUDIILF

impacts in NRC 2011d) to noticeabOHHJWUDIILFFRQJHVWLRQDWVSHFLILFVLWHVDQGRQURDGVZLWK

limited available capacity to accommodate the increased demand from proposed power plant 

activitiesVHH15&DFor radiological transportation impacts, the cumulative impacts 

would likely be minimal based on factors such as low dose, prior generic impact assessment in 

&)5VSHQWIXHO//:XSGDWHGVXSSOHPHQWDODQDO\VHVDGGUHVVLQJXQLTXHVLWHspecific plant characteristics, and the low volume of other regional radioactive materials 

transportation activities that could overlap with continued storage (NRC 2011a–HG

6.4.15.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

Activities 

Cumulative impacts on transportation could result from other NRC-regulated or spent fuelrelated activities, such as increases in traffic from workers during final reactor shutdown 

DFWLYLWLHVGHFRPPLVVLRQLQJRIWKHUHDFWRUSRZHUEORFNLQFOXGLQJWKHVSHQWIXHOSRRO,6)6,V

DQG'76DQGWUDQVSRUWDWLRQRIVSHQWIXHOIURPDQDW-reactor or away-from-UHDFWRU,6)6,WRD

UHSRVLWRU\IRUGLVSRVDO

Nonradiological traffic impacts from reactor shutdown activities would result from a temporary 

LQFUHDVHLQWKHUHDFWRUZRUNIRUFHKRZHYHUWKHQXPEHURIZRUNHUVZRXOGQRWEHH[SHFWHGWR

H[FHHGWKHWHPSRUDU\ZRUNIRUFHXVHGIRUUHIXHOLQJRXWDJHV7KHUHIRUHWKHWUDIILFLPSDFWV

GXULQJVKXWGRZQZRXOGEHVLPLODUWRWKHWUDIILFLPSDFWVGXULQJUHDFWRURSHUDWLRQV7UDIILF
&XPXODWLYH,PSDFWV

185(*௅ 6- September 2014 

LPSDFWVGXULQJVKXWGRZQZHUHHYDOXDWHGLQWKH/LFHQVH5HQHZDO*(,6LQZKLFKWKe NRC 

DGHWHUPLQHGWUDIILFLPSDFWVWREH60$//IRURSHUDWLQJSODQWV&RPELQHGQRQUDGLRORJLFDO

and radiological traffic impacts from reactor decommissioning were previously evaluated by the 

15&LQWKH'HFRPPLVVLRQLQJ*(,6IRUQXFOHDUUHDFWRUV15&,QWKDWDQDO\VLVWKH15&

evaluated the number of shipments of dismantled equipment, material, and debris from 

GHFRPPLVVLRQLQJ$OWKRXJKWKHQXPEHURIVKLSPHQWVFDQEHUHODWLYHO\ODUJHWKH

GHFRPPLVVLRQLQJSHULRGH[WHQGVRYHUVHYHUDO\HDUV$VDUHVXOWWKHQXPEHURI//:VKLSPHQWV

SHUGD\LVORZZLWKDQDYHUDJHRIOHVVWKDQRQHVKLSPHQWSHUGD\IURPWKHSODQW15&

7KHPDWHULDOVWUDQVSRUWHGRIIVLWHZRXOGLQFOXGHDOOZDVWHVJHQHUDWHGRQVLWH1RQUDGLRORJLFDO

impacts would include increased traffic volume, additional wear and tear on roadways, and 

SRWHQWLDOWUDIILFDFFLGHQWV15&7KLVLQIRUPDWLRQVXSSRUWHGDFRQFOXVLRQWKDWWKH

transportation impacts from nuclear power plant decommissioning would not be detectable 

15&

Additional radiological impacts would occur from transportation of (1) spent fuel to a repository 

IRUGLVSRVDODQG//:IURPGHFRPPLVVLRQLQJWKHUHDFWRUVSHQWIXHOSRRODQG,6)6,

5DGLRORJLFDOLPSDFWVZRXOGLQFOXGHH[SRVXUHRIWUDQVSRUWDWLRQZRUNHUVDQGWKHJHneral public 

DORQJWKHWUDQVSRUWDWLRQURXWHV7KH15&SUHYLRXVO\GHWHUPLQHGWKDWUDGLRORJLFDOLPSDFWVRQ

the public and workers of spent fuel and waste shipments from a reactor are SMALL in several 

HYDOXDWLRQV)RUH[DPSOHWKH15&PDGHDJHQHULFLPSDFWdetermination in Table S–4 in 

10 &)5DQGWKHVXSSRUWLQJDQDO\VLV$(&WKDWWKHHQYLURQPHQWDOLPSDFWVRI

transportation of fuel and waste to and from a 1,000- WR-0:HOLJKWZDWHUUHDFWRUZRXOG

be SMALL under incident-free and accident conGLWLRQV7KHUHVXOWVRIVXEVHTXHQWDQDO\VHVRI

transportation impacts in Final Environmental Statement on Transportation of Radioactive 

Material by Air and Other Modes 15&DQGReexamination of Spent Fuel Shipment Risk 

Estimates 6SUXQJHWDO FRQILUPHGVSHQWIXHOWUDQVSRUWDWLRQLPSDFWVDUHVPDOOAdditional 

site-specific analyses of transportation impacts for power plants that did not meet the conditions 

RI&)5DOVRFRQFOXGHGWKHWUDQVSRUWDWLRQUDGLRORJLFDOLPSDFWVZRXOGEH60$//1RC 

D–HF,QWKH/LFHQVH5HQHZDO*(,615&DWKH15&DOVR

concluded that impacts from uranium fuel cycle transportation, including transportation of spent 

IXHOWRDUHSRVLWRU\IRUGLVSRVDODUH60$//IRUDOOQXFOHDUSODQWV0Rre recently, the NRC 

calculated spent fuel transportation risks for individual shipments in Spent Fuel Transportation 

Risk Assessment: Final Report 15&EDVHGRQFXUUHQWPRGHOVGDWDDQGDVVXPSWLRQV

The analysis modeled responses of transportation packages to accident conditions such as 

impact force and fire, and calculated risks considering a range of truck and rail accidents of 

different severities including those involving no release or loss of shielding, loss of shielding 

only, or loss of shielding and UHOHDVH7KDWDQDO\VLVUHFRQILUPHGWKDWWKHUDGLRORJLFDOLPSDFWV

IURPVSHQWIXHOWUDQVSRUWDWLRQFRQGXFWHGLQFRPSOLDQFHZLWK15&UHJXODWLRQVDUHORZ7KH15&

also concluded that the regulations for transportation of radioactive material were adequate to 

SURWHFWWKHSXEOLFDJDLQVWXQUHDVRQDEOHULVN15&%DVHGRQWKHJHQHULFGHWHUPLQDWLRQ

in Table S–4 of 10 CFR DQGWKHVXEVHTXHQWVSHQWIXHOWUDQVSRUWDWLRQLPSDFWDQDO\VHV
&XPXODWLYH,Ppacts 

September 2014 6- 185(*௅

and risk assessments cited above, the NRC concludes the radiological impacts for incident-free 

and accident transportation of spent fuel from a single at-reactor storage facility to a repository 

ZRXOGEHVPDOO

Radiological impacts may accumulate along the transportation route for an away-from-reactor 

,6)6,EHFDXVHWKHVDPHRYHrall transportation route would be used to transfer the entire 

inventory of spent fuel from an away-from-UHDFWRU,6)6,WRDUHSRVLWRU\7RHYDOXDWHWKHVH

impacts from an away-from-UHDFWRU,6)6,WKH15&UHYLHZHGRWKHUSDVWHYDOXDWLRQVRI

transportation of spent fuel from an away-from-UHDFWRU,6)6,WRDUHSRVLWRU\)RUH[DPSOHWKH

NRC previously evaluated the radiological and nonradiological impacts from a comparable (full 

inventory) transportation scenario for PFSF and concluded that the impacts would be SMALL 

15&D7KDWDQDO\VLVFDOFXODWHGLQFLGHQW-free and accident risks from 4,000 shipments of 

spent fuel from Maine to Utah over a 20-\HDUSHULRG7KHUHVXOWLQJFXPXODWLYHGRVHWRWKH

PD[LPDOO\H[SRVHGLQGLYLGXDODQindividual that is assumed for the purpose of performing a 

bounding analysis of incident-IUHHWUDQVSRUWDWLRQWREHH[SRVHGWRWKHUDGLDWLRQIURPDOO

shipments) at the end of the 20-\HDUSHULRGZDVP6YPUHP)RUFRPSDULVRQWKH

annual NRC publiFGRVHOLPLWLQ&)53DUWLVP6YPUHP7KH15&DDOVR

concluded that the radiological impacts from transportation of a single reactor’s spent fuel from 

an away-from-UHDFWRU,6)6,WRDUHSRVLWRU\ZRXOGEHERXQGHGE\RUFRPSDUDEOHWRLPpacts 

evaluated in Table S–LQ&)5%DVHGRQWKHVHDQDO\VHVWKH NRC concludes that 

the additional accumulated impacts from transportation of the entire inventory of spent fuel from 

an away-from-UHDFWRU,6)6,WRDUHSRVLWRU\ZRXOGEHPLQRU

6.4.15.3 Conclusion 

Cumulative impacts on transportation include the incremental effects from continued storage 

when added to the aggregate effects of other past, present, and reasonably foreseeable future 

DFWLRQV$VGHVFULEHGLQ6HFWLRQVDQGWKHLQFUHPHQWal impacts from continued 

storage on transportation is SMALL for all timeframes at an at-UHDFWRU,6)6,DQG60$//WR

MODERATE for all timeframes at an away-from-UHDFWRU,6)6,,QDGGLWLRQSast, present, and 

reasonably foreseeable activities take place in the geographic area of interest that could 

FRQWULEXWHWRFXPXODWLYHHIIHFWVWRWUDQVSRUWDWLRQ7KHFXPXODWLYHLPSDFWVIURPFRQWLQXHG

storage when added to other past, present, and reasonably foreseeable Federal and nonFederal activities (such as construction of HQHUJ\ZDWHUPLOLWDU\RUXUEDQL]DWLRQSURMHFWV

would range from SMALL to MODERATE for nonradiological transportation and SMALL for 

UDGLRORJLFDOWUDQVSRUWDWLRQ

6.4.16 Public and Occupational Health 

This section evaluates the effects of continued storage on public and occupational health when 

added to the aggregate effects of other past, present, and reasonably foreseeable future 

DFWLRQV$VGHVFULEHGLQ6HFWLRQVDQGWKHLQFUHPHQWDOLPSDFWVIURPFRQWLQXHG
&XPXODWLYH,PSDFWV

185(*௅ 6- September 2014 

storage on public and occupational health are SMALL for all timeframes at both at-reactor and 

away-from-UHDFWRUVWRUDJHIDFLOLWLHV

For this analysis, the geographic area considered in the cumulative public and occupational 

health resources analysis is the area within an -NP-mi) radius of the at-reactor or awayfrom-reactor storage facility site+LVWRULFDOO\WKH15&KDVXVHGWKH-NP-mi) radius as a 

standard geographic area to evaluate population doses from routine releases from nuclear 

SRZHUSODQWV7KH-NP-mi) radius was selected to encompass potential impact overlaps 

IURPWZRRUPRUHQXFOHDUIDFLOLWLHV7KLVFRQFHSWLVGLVFXVVHGLQGHWDLOLQWKHVLWH-VSHFLILF(,6V

IRUQHZUHDFWRUVDQG,6)6,($VRU(,6VUHYLHZHGIRUWKLV*(,6 DQDO\VLVVHHHJ15&G

6HFWLRQ

6.4.16.1 Potential Cumulative Impacts from General Trends and Activities 

&XPXODWLYHKXPDQKHDOWKLPSDFWVUHODWHWRSXEOLFH[SRVXUHWRUDGLRORJLFDOFKHPLFDODQG

microbiological hazards and the potentially chronic effects of electromagnetic field (EMF) 

H[SRVXUH3XEOLFH[SRVXUHVPD\RFFXUDVDUHVXOWRIHQYLURQPHQWDODFFXPXODWLRQVRIKDUPIXO

constituents released from various facilities associated with urban, agricultural, industrial, and 

FRPPHUFLDOGHYHORSPHQW7KHSRWHQWLDOFXPXODWLYHLPSDFWVRI(0)H[SRVXUHZhile uncertain, 

ZRXOGUHODWHWRDFWLYLWLHVHJ transmission lines and substations) associated with urban, 

LQGXVWULDODQGFRPPHUFLDOGHYHORSPHQW7KH15&DFNQRZOHGJHVWKDWWKHUHLVQRFRQFOXVLYH

OLQNEHWZHHQ(0)H[SRVXUHDQGKXPDQKHDOWKLPSDFWV15&D

The magnitude of cumulative impacts resulting from general trends taking place within the 

region in which a storage facility is located would depend on the nature and location of the 

DFWLRQVWKHQXPEHURIDFWLRQVIDFLOLWLHVRUSURMHFWVWKHOHYHO RIWKHSXEOLF¶VH[SRVXUHDQG

ZKHWKHUIDFLOLWLHVFRPSO\ZLWKUHJXODWLQJDJHQF\UHTXLUHPHQWVHJ SHUPLWWHGGLVFKDUJHOLPLWV

)RUSXEOLFDQGRFFXSDWLRQDOKHDOWKWKHFXPXODWLYHLPSDFWZRXOGEHPLQLPDOHJ, 

NRC 2011a–e, 2012a, 2013a–c) because reactors and other industrial buildings would be 

UHTXLUHGWRPHHWUHJXODWLRQVVXFKDVWKH2FFXSDWLRQDO6DIHW\DQG+HDOWK$GPLQLVWUDWLRQ¶V

*HQHUDO,QGXVWU\6WDQGDUGV&)53DUWDQG&RQVWUXFWLRQ,QGXVWU\6WDQGDUGV

(29 CFR Part 1926) and, as applicable, operated under NRC regulations such as 

10 CFR Part DQG CFR Part )RUH[DPSOHHYHQWKRXJKLQFUHDVHGXUEDQL]DWLRQPLJKW

VXJJHVWDQLQFUHDVHGSXEOLFH[SRVXUHEHFDXVHRIDODUJHUUHFHSWRUJURXSWKH15&ZRXOGVWLOO

require the regulated nuclear facilities in the area of interest to prove through monitoring and as 

low as is reasonably achievable (ALARA) programs that they were meeting the public and 

RFFXSDWLRQDOKHDOWKUHJXODWLRQV
&XPXODWLYH,PSDFWV

September 2014 6- 185(*௅

6.4.16.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

Activities 

Cumulative impacts on public and occupational health could result from other NRC-regulated or 

spent fuel-related activities, such as reactor plant shutdown activities prior to decommissioning, 

decommissioning activities, construction of infrastructure to support away-from-UHDFWRU,6)6,V

DQGSUHSDUDWLRQDFWLYLWLHVWRHQDEOHWUDQVSRUWDWLRQRIZDVWHWRDUHSRVLWRU\The NRC has 

HYDOXDWHGHQYLURQPHQWDOLPSDFWVIURPWKHVHDFWLYLWLHVLQWKH'HFRPPLVVLRQLQJ*(,6

(NRC IRUUHDFWRUGHFRPPLVVLRQLQJDQGWKH3)6)(,615& DIRU,6)6,

GHFRPPLVVLRQLQJDQGIRXQGWKHSXEOLFDQGRFFXSDWLRQDOKHDOWKLPSDFWVWREH60$//7KH

NRC also evaluated environmental impacts from infrastructure to support away-from-reactor 

,6)6,VLQWKH3)6)(,615&DDQGIRXQGWKHSXEOLFDQGRccupational health impacts to 

EH60$//)RUDFWLYLWLHVUHODWHGWRVSHQWIXHOWUDQVSRUWDWLRQWRDUHSRVLWRU\VXFKDVVSHQWIXHO

storage maintenance activities that involve bare fuel handling in a postulated DTS at nearby 

facilities, as noted in Sections 4DQGWKHSXEOLFDQGRFFXSDWLRQDOKHDOWKLPSDFWVZRXOG

be SMALL and would not aggregate to more significant impacts, given the limited number of 

IDFLOLWLHVZLWKLQ km ( PLH[SHFWHGWREHLQWKHGHFRPPLVVLRQLQJSKDVHRIWKHLUOLIHF\FOH

6.4.16.3 Conclusion 

Cumulative impacts on public and occupational health include the incremental effects from 

continued storage when added to the aggregate effects of other past, present, and reasonably 

IRUHVHHDEOHIXWXUHDFWLRQV$VGHVFULEHGLQ6HFWLRQVDQGthe incremental impacts 

from continued storage on public and occupational health is SMALL for all timeframes at both 

at-reactor and away-from-UHDFWRUVWRUDJHIDFLOLWLHV7KHFXPXODWLYHLPSDFWVIURPFRQWLQXHG

storage when added to other past, present, and reasonably foreseeable Federal and nonFHGHUDODFWLYLWLHVDUHH[SHFWHGWREH60$//EHFDXVHVWRUDJHIDFLOLWLHVUHDFWRUVDQGRWKHU

proposed industrial buildings would be required to meet regulations such as the Occupational 

6DIHW\DQG+HDOWK$GPLQLVWUDWLRQ¶V*HQHUDO,QGXVWU\6WDQGDUGV&)53DUWDQG

&RQVWUXFWLRQ,QGXVWU\6WDQGDUGV&)53DUWDQGDVDSSOLFDEOHRSHUDWHGXQGHU15&

UHJXODWLRQVVXFKDV&)53DUWDQG CFR Part 

6.4.17 Environmental Impacts of Postulated Accidents 

This section evaluates the effects of continued storage on accident risk when added to the 

DJJUHJDWHHIIHFWVRIRWKHUSDVWSUHVHQWDQGUHDVRQDEO\IRUHVHHDEOHIXWXUHDFWLRQVAs 

GHVFULEHGLQ6HFWLRQVDQGWKHLQFUHPHQWDOLPSDFWVIURPFRQWLQXHGVWRUDJHRQ

environmental impacts of postulated accidents is SMALL for all timeframes at both at-reactor 

and away-from-UHDFWRUVWRUDJHIDFLOLWLHV

7KHJHRJUDSKLFDUHDFRQVLGHUHGLQWKHFXPXODWLYHDFFLGHQWULVNDVVHVVPHQWLVDQ-NP-mi) 

radius from an at-reactor or away-from-UHDFWRUVWRUDJHIDFLOLW\7KHFXPXODWLYHDQDO\VLV
&XPXODWLYH,PSDFWV

185(*௅ 6- September 2014 

considers risk from potential accidents from other nuclear plants or storage facilities that have 

WKHSRWHQWLDOWRLQFUHDVHULVNVDWDQ\ORFDWLRQZLWKLQNPPLRIWKHVKXWGRZQUHDFWRURU

VWRUDJHIDFLOLW\,WLVSRVVLEOHWKDWRQHRUPRUHRWKHUW\SHVRIQXFOHDUIDFLOLWLHVWKDWVXSSRUWWKH

QXFOHDUIXHOF\FOHPD\EHORFDWHGZLWKLQDQ-NP-mi) radius, but these facilities generally 

LQYROYHYHU\ORZDFFLGHQWULVN)57KHUHIRUH the analysis below focuses on the 

FXPXODWLYHULVNIURPUHDFWRUVDQGVWRUDJHIDFLOLWLHV

6.4.17.1 Potential Cumulative Impacts from General Trends and Activities 

%DVHGRQDUHYLHZRIWKHRWKHUDFWLYLWLHVWKDWFDQRFFXUQHDUSURSRVHGQHZDW-reactor storage 

facilities, there are two scales of cumulative impacts on accident risk, including (1) cumulative 

impacts due to the various impacts from an individual power plant and storage facility over time 

HJDQQXDOGHVLJQEDVLVDQGVHYHUHDFFLGHQWULVNVDWDUHDFWRUDQd (2) cumulative impacts 

GXHWRFORVHO\VLWHGRSHUDWLQJRUGHFRPPLVVLRQLQJUHDFWRUVHJGHVLJQEDVLVDQGVHYHUH

DFFLGHQWULVNVDWRWKHUUHDFWRUVORFDWHGZLWKLQNP>-PL@RURWKHUUDGLRDFWLYHIDFLOLWLHV,Q

addition, climate change can impact accident risk due to higher or lower intensity or frequency 

RIQDWXUDOSKHQRPHQDKD]DUGVHJSUHFLSLWDWLRQWRUQDGRHVKXUULFDQHVWKDWcould result in 

UDGLRORJLFDODFFLGHQWV

The magnitude of cumulative accident impacts resulting from all general trends taking place 

ZLWKLQWKH-NP-mi) region of a power plant and storage facility would likely be limited 

because: 

 Estimates of average individual early fatality and latent cancer fatality risks are well below 

WKH&RPPLVVLRQ¶VVDIHW\JRDOVDWDOOSODQWV)5

 The Commission has determined that the probability-weighted consequences of severe 

DFFLGHQWVRIDQXFOHDUSRZHUSODQWDUH60$//&)53DUW$SSHQGL[%7DEOH%-

 The severe accident risk due to any particular nuclear power plant gets smaller as the 

GLVWDQFHIURPWKDWSODQWLQFUHDVHV+RZHYHUWKHFRPELQHGULVNDWDQ\ORFDWLRQZLWKLQNP

 mi) of a reactor site would be bounded by the sum of risks for all of these operating and 

SURSRVHGQXFOHDUSRZHUSODQWV(YHQWKRXJKVHYHUDOSODQWV and other nuclear facilities 

FRXOGSRWHQWLDOO\EHLQFOXGHGLQWKHFRPELQDWLRQWKLVFRPELQHGULVNZRXOGVWLOOEHORZ

%HFDXVHGHVLJQEDVLVDFFLGHQWVDWQHDUE\SRZHUSODQWVDQGVWRUDJHIDFLOLWLHVDUHLQGLYLGXDOO\

unlikely to occur more than once over the life of a facility, and licensees must show that accident 

consequences of design basis accidents are mitigated to acceptable levels of dose offsite, the 

FXPXODWLYHLPSDFWRIGHVLJQEDVLVDFFLGHQWVLVYHU\VPDOO%DVHGRQWKHDERYHGLVFXVVLRQWKH

NRC conclXGHGWKDWLQDOOQHZUHDFWRU(,6VSXEOLVKHGWKURXJK)HEUXDU\HJ

NRC 2011a–e, 2013c), the cumulative risks from design basis and severe accidents at any 

location within  NPPLRIDUHDFWRUZRXOGEH60$//
&XPXODWLYH,PSDFWV

September 2014 6- 185(*௅

Potential cumulative impacts from an at-UHDFWRU,6)6,or an away-from-reactor ,6)6, would be 

PLQLPDOEHFDXVHRISDVVLYHQDWXUHRIWKH,6)6, there is no routine release of gaseous or liquid 

radiological effluents GXULQJRSHUDWLRQ,QDGGLWLRQEHFDXVHlicensees are required to maintain 

doses as low as is reasonably achievable in accordance with NRC radiation protection 

UHJXODWLRQVERWKDQ,6)6,DQGDQDZD\-from-reactor facility are designed to minimize 

UDGLRORJLFDOGRVHVWRZRUNHUVDQGSXEOLF$GGLWLRnally, the severe accident risk from a spent fuel 

VWRUDJHIDFLOLW\DOVRGHFUHDVHVDVWKHGLVWDQFHIURPWKDWIDFLOLW\LQFUHDVHV2QWKLVEDVLVWKH

NRC concluded that the cumulative risk of continued storage from design basis and severe 

DFFLGHQWVDWDQ,6)6,RUDQDZD\-from-UHDFWRUVWRUDJHIDFLOLW\ZRXOGEH60$//

6.4.17.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

Activities 

Cumulative impacts of postulated accidents could result from other NRC-regulated or spent fuelrelated activiWLHVVXFKDVVSHQWIXHOVWRUDJHPDLQWHQDQFHDFWLYLWLHV$FWLYLWLHVWKDWLQYROYHEDUH

fuel handling in a postulated dry transfer facility at nearby facilities could involve additional 

DFFLGHQWULVN+RZHYHUDVQRWHGLQ6HFWLRQVDQGWKHVHLPSDcts would be SMALL, 

and would not aggregate to more significant impacts, given the limited number of facilities within 

NPPLH[SHFWHGWREHLQWKLVSDUWRIWKHLUOLIHF\FOH

%HIRUHVSHQWIXHOVWRUDJHIDFLOLWLHVFDQEHJLQILQDOGHFRPPLVVLRQLQJDQGOicense termination, the 

VSHQWIXHOPXVWEHUHPRYHGIURPWKHVLWHDQGVWRUHGRUGLVSRVHGRIRIIVLWH2QFHWKHVSHQWIXHO

is removed from the site, the residual radioactive material at a reactor poses very little accident 

ULVN7KHUHIRUHLPSDFWVRQDFFLGHQWULVNIURPGHFRPPLVVLRQLQJDUHH[SHFWHGWREH60$//

15&

6.4.17.3 Conclusion 

Cumulative impacts of postulated accidents include the incremental effects from continued 

storage when added to the aggregate effects of other past, present, and reasonably foreseeable 

IXWXUHDFWLRQV$VGHVFULEHGLQ6HFWLRQVDQGWKHLQFUHPHQWDOLPSDFWVIURPFRQWLQXHG

storage on environmental impacts of postulated accidents is SMALL for all timeframes at both 

at-reactor and away-from-UHDFWRUVWRUDJHIDFLOLWLHV,QDGGLtion, past, present, and reasonably 

foreseeable activities take place in the geographic area of interest that could contribute to 

FXPXODWLYHHIIHFWVWRDFFLGHQWULVN

The NRC determined that the cumulative impacts from a reactor, a spent fuel pool, and an 

,6)6,ZRXOGEHPLQLPDOEHFDXVHDFFLGHQWULVNUHPDLQV60$//7KHFXPXODWLYHLPSDFWVIURP

other past, present, and reasonably foreseeable Federal and non-Federal activities described in 

6HFWLRQVDQGDUH60$//*LYHQWKDWHVWLPDWHVRIDYHUDJHLQdividual early fatality 

and latent cancer fatality risks are well below the Commission’s safety goals at all nuclear power 

SODQWV)5WKH&RPPLVVLRQGHWHUPLQDWLRQWKDWWKHSUREDELOLW\-weighted 
&XPXODWLYH,PSDFWV

185(*௅ 6- September 2014 

consequences of severe accidents of a nuclear power SODQWDUH60$//&)53DUW

$SSHQGL[ %7DEOH%-1), and that the combined risk from several plants and other nuclear 

facilities would be low, the NRC concludes that the cumulative impacts at all storage sites would 

EH60$//

6.5 Summary 

The impact levels determined by the NRC in the previous chapters from at-reactor storage 

(Chapter 4), away-from-UHDFWRUVWRUDJH&KDSWHUDQGFXPXODWLYHLPSDFWVIURPFRQWLQXHG

storage when added to other past, present, and reasonably foreseeable activities (Chapter 6) 

are summarized in Table 6-47KHLPSDFWOHYHOVDUHGHQRWHGDV60$//02'(5$7(DQG

/$5*(DVDPHDVXUHRIWKHLUH[SHFWHGDGYHUVHHQYLURQPHQWDOLPSDFWV For some resource 

DUHDVWKHLPSDFWGHWHUPLQDWLRQODQJXDJHLVVSHFLILFWRWKHDXWKRUL]LQJUHJXODWLRQH[HFXWLYH

RUGHURUJXLGDQFH ,PSDFWGHWHUPLQDWLRQVWKDWLQFOXGHDUDQJHRILPSDFWVUHIOHFWXQFHUWDLQW\

related to both geographic variDELOLW\DQGWKHWHPSRUDOVFDOHRIWKHDQDO\VLVAs a result, based 

on DQDO\VHVSHUIRUPHGLQWKLV*(,6WKH15&H[SHFWVWKDWIXUWKHUVLWH-specific analysis would 

be unlikely to result in impact conclusions with different ranges 

Table 6-4 6XPPDU\RIWKH&XPXODWLYH,PSDFWVIURP&RQWLQXHG6WRUDJH:KHQ$GGHGWR2WKHU

Federal and Non-Federal Activities

Resource Area 

Incremental 

Impact from 

At-Reactor 

Storage 

Incremental Impact 

from Away-FromReactor Storage 

Cumulative Impact 

from Continued 

Storage and other 

Federal and NonFederal Activities 

Land Use SMALL SMALL SMALL to MODERATE 

Socioeconomics SMALL SMALL (adverse) to 

LARGE (beneficial) 

SMALL to LARGE 

Environmental Justice Disproportionately high and adverse impacts DUHQRWH[SHFWHG

Air Quality SMALL SMALL to MODERATE SMALL to MODERATE 

Climate Change SMALL SMALL MODERATE 

Geology and Soils SMALL SMALL SMALL to MODERATE 

Surface-:DWHU4XDOLW\DQG8VH SMALL SMALL SMALL to LARGE 

Groundwater Quality and Use SMALL SMALL SMALL to LARGE 

Terrestrial Resources(a) SMALL SMALL to MODERATE SMALL to MODERATE 

Aquatic Ecology(a) SMALL SMALL SMALL to LARGE 

+LVWRULFDQG&XOWXUDO5HVRXUFHV SMALL to LARGE SMALL to LARGE SMALL to LARGE 

Noise SMALL SMALL SMALL to MODERATE 

Aesthetics SMALL SMALL to MODERATE SMALL to MODERATE 

:DVWH0DQDJHPHQW SMALL to 

MODERATE 

SMALL to MODERATE SMALL to LARGE 
&XPXODWLYH,PSDFWV

September 2014 6- 185(*௅

Table 6-4 6XPPDU\RIWKH&XPXODWLYH,PSDFWVIURP&RQWLQXHG6WRUDJH:KHQ$GGHGWR2WKHU

Federal and Non-Federal Activities (cont’d) 

Resource Area 

Incremental 

Impact from 

At-Reactor 

Storage 

Incremental Impact 

from Away-FromReactor Storage 

Cumulative Impact 

from Continued 

Storage and other 

Federal and NonFederal Activities 

Transportation SMALL SMALL to MODERATE SMALL to MODERATE 

3XEOLFDQG2FFXSDWLRQDO+HDOWK SMALL SMALL SMALL 

Accidents SMALL SMALL SMALL 

(a) Cumulative impacts for Federally listed WKUHDWHQHGDQGHQGDQJHUHGVSHFLHVDQG(VVHQWLDO)LVK+DELWDWZRXOGEH

determined as part of consultations for the Endangered Species Act and the Magnuson–Stevens Fishery 

Conservation and 0DQDJHPHQW$FW

6.6 References 

&)53DUWCode of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

3URWHFWLRQ$JDLQVW5DGLDWLRQ ́ :DVKLQJWRQ'&

&)53DUWCode of Federal Regulations, Title 10, Energy, 3DUW3'RPHVWLFLicensing of 

3URGXFWLRQDQG8WLOL]DWLRQ)DFLOLWLHV ́:DVKLQJWRQ'&

&)53DUWCode of Federal Regulations, Title 10, Energy3DUW3(QYLURQPHQWDO

3URWHFWLRQ5HJXODWLRQVIRU'RPHVWLF/LFHQVLQJDQG5HODWHG5HJXODWRU\)XQFWLRQV ́ 

:DVKLQJWRQ'&

&)53DUWCode of Federal Regulations, Title 10, Energy, 3DUW3/LFHQVHV

&HUWLILFDWLRQVDQG$SSURYDOVIRU1XFOHDU3RZHU3ODQWV ́:DVKLQJWRQ'&

&)53DUWCode of Federal Regulations, Title 10, Energy3DUW33DFNDJLQJDQG

TranspoUWDWLRQRI5DGLRDFWLYH0DWHULDO ́ :DVKLQJWRQ'&

&)53DUWCode of Federal Regulations, Title 10, Energy, 3DUW3/LFHQVLQJ

5HTXLUHPHQWVIRUWKH,QGHSHQGHQW6WRUDJHRI6SHQW1XFOHDU)XHO+LJK-Level Radioactive 

:DVWHDQG5HDFWRU-Related *UHDWHU7KDQ&ODVV&:DVWH ́ :DVKLQJWRQ'&

&)53DUWCode of Federal Regulations, Title 29, Standards, Part 1910, “Occupational 

6DIHW\DQG+HDOWK6WDQGDUGV ́ :DVKLQJWRQ'&

&)53DUWCode of Federal Regulations, Title 29, Standards, Part 1926, “Safety and 

+HDOWK5HJXODWLRQVIRU&RQVWUXFWLRQ ́ :DVKLQJWRQ'&
&XPXODWLYH,PSDFWV

185(*௅ 6-60 September 2014 

&)53DUWCode of Federal Regulations, Title 40, Protection of Environment, 

Part 37HUPLQRORJ\DQG,QGH[ ́ :DVKLQJWRQ'&

&)53DUWV–Code of Federal Regulations, Title 49, Transportation3DUWVí, 

3+D]DUGRXV0DWHULDOV5HJXODWLRQV” :DVKLQJWRQ'&

&)53DUWCode of Federal Regulations7LWOHWildlife and Fisheries, Part 402, 

3,QWHUDJHQF\&RRSHUDWLRQ—(QGDQJHUHG6SHFLHV$FWRIDV$PHQGHG ́:DVKLQJWRQ'&

)5$XJXVW36DIHW\*RDOVIRUWKH2SHUDWLRQVRI1XFOHDU3RZHU3ODQWV

3ROLF\6WDWHPHQW5HSXEOLFDWLRQ ́Federal Register, 861XFOHDU5HJXODWRU\&RPPLVVLRQ

:DVKLQJWRQ'&

)5$XJXVW33ROLF\6WDWHPHQWRQWKH7UHDWPHQWRI(QYLURQPHQWDO-XVWLFH

0DWWHUVLQ15&5HJXODWRU\DQG/LFHQVLQJ$FWLRQV ́Federal Register, 861XFOHDU5HJXODWRU\

Commission, :DVKLQJWRQ'&

)5'HFHPEHU3(QGDQJHUPHQWDQG&DXVHRU&RQWULEXte Findings for 

*UHHQKRXVH*DVHV8QGHU6HFWLRQDRIWKH&OHDQ$LU$FW ́Federal Register, 

86 Environmental Protection Agency, :DVKLQJWRQ'&

)5 -XQH33UHYHQWLRQRI6LJQLILFDQW'HWHULRUDWLRQDQG7LWOH9

Greenhouse *DV7DLORULQJ5XOH ́Federal Register, 86Environmental Protection Agency, 

:DVKLQJWRQ'&

)5$SULO36+,1(0HGLFDO7HFKQRORJLHV,QF([HPSWLRQ ́Federal 

Register, 861XFOHDU5HJXODWRU\&RPPLVVLRQ :DVKLQJWRQ'&

)5$SULO3)LQGLQJRI1R6LJQLILFDQW,PSDFWDQG)LQDO3URJUDPPDWLF

(QYLURQPHQWDO$VVHVVPHQWIRU$UP\)RUFH6WUXFWXUH5HDOLJQPHQW ́Federal Register, 

86Department of the Army, :DVKLQJWRQ'&

$(&86$WRPLF(QHUJ\&RPPLVVLRQEnvironmental Survey of Transportation of 

Radioactive Materials to and From Nuclear Power Plants:$6+–:DVKLQJWRQ'&

Available at KWWSZZZRVWLJRYHQHUJ\FLWDWLRQVSURGXFWELEOLRMVS"RVWLBLG  

%5& %OXH5LEERQ&RPPLVVLRQRQ$PHULFD¶V1XFOHDU)XWXUH35HSRUWWRWKH6HFUHWDU\

RI(QHUJ\ ́:DVKLQJWRQ'& $FFHVVLRQ1R0/

&OHDQ:DWHU$FW (See )HGHUDO:DWHU3ROOXWLRQ&RQWURl Act RI)

&(4&RXQFLORQ(QYLURQPHQWDO4XDOLW\ Considering Cumulative Effects under the 

National Environmental Policy Act:DVKLQJWRQ'&$FFHVVLRQ1R0/$
&XPXODWLYH,PSDFWV

September 2014 6-61 185(*௅

&(4&RXQFLORQ(QYLURQPHQWDO4XDOLW\The NEPA Task Force Report to the Council 

on Environmental Quality—Modernizing NEPA Implementation. :DVKLQJWRQ'&$FFHVVLRQ

1R0/

&(4&RXQFLORQ(QYLURQPHQWDO4XDOLW\  Draft NEPA Guidance on Consideration of the 

Effects of Climate Change and Greenhouse Gas Emissions:DVKLQJWRQ'& $FFHVVLRQ1R

0/$

&<$3&&RQQHFWLFXW<DQNHH$WRPLF3RZHU&RPSDQ\Haddam Neck Plant 

Independent Spent Fuel Storage Installation Decommissioning Study(DVW+DPSWRQ

&RQQHFWLFXW$FFHVVLRQ1RML12363

'2(86'HSDUWPHQWRI(QHUJ\Dry Transfer System Topical Safety Analysis Report. 

9ROXPH:DVKLQJWRQ'&$FFHVVLRQ1R0/

'2(86'HSDUWPHQWRI(QHUJ\Final Supplemental Environmental Impact Statement 

for a Geologic Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive 

Waste at Yucca Mountain, Nye County, Nevada'2((,6–)–S1, Office of Civilian 

5DGLRDFWLYH:DVWH0DQDJHPHQW/DV9HJDV1HYDGD$FFHVVLRQ1R0/

'2(86'HSDUWPHQWRI(QHUJ\Strategy for the Management and Disposal of Used 

Nuclear Fuel and High-Level Radioactive Waste:DVKLQJWRQ'&$FFHVVLRQ

1R 0/$

(QGDQJHUHG6SHFLHV$FWRI (ESA), as amended 86& et seq

(,$(QHUJ\,QIRUPDWLRQ$GPLQLVWUDWLRQElectric Power Annual 2010:DVKLQJWRQ'&

Available at KWWSZZZHLDJRYHOHFWULFLW\DQQXDODUFKLYHSGI

(,$(QHUJ\,QIRUPDWLRQ$GPLQLVWUDWLRQDAnnual Energy Outlook 2013 Early Release 

Overview:DVKLQJWRQ'&Available at KWWSZZZHLDJRYIRUHFDVWVDUFKLYHDHRHU

(,$(QHUJ\,QIRUPDWLRQ$GPLQLVWUDWLRQEAnnual Energy Outlook 2012 With Projections 

to 2035'2((,$-:DVKLQJWRQ'&Available at 

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(,$(QHUJ\,QIRUPDWLRQ$GPLQLVWUDWLRQFNumber and Capacity of Petroleum 

Refineries:DVKLQJWRQ'&Available at 

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(,$(QHUJ\,QIRUPDWLRQ$GPLQLVWUDWLRQG2011 Uranium Marketing Annual Report

:DVKLQJWRQ'&Available at KWWSZZZHLDJRYXUDQLXPPDUNHWLQJSGIXPDUSGI
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185(*௅ 6-62 September 2014 

(3$86(QYLURQPHQWDO3URWHFWLRQ$JHQF\Consideration of Cumulative Impacts in 

EPA Review of NEPA Documents(3$–R–99–:DVKLQJWRQ'&$FFHVVLRQ

1R 0/

(3$86(QYLURQPHQWDO3URWHFWLRQ$JHQF\DInventory of U.S. Greenhouse Gas 

Emissions and Sinks: 1990–2011(3$-R-13-:DVKLQJWRQ'&$FFHVVLRQ1R

0/$

(3$86Environmental ProteFWLRQ$JHQF\EClean Energy: Calculations and 

References:DVKLQJWRQ'&$FFHVVLRQ1R0/$

(5()(QYLURQPHQWDO5HVHDUFKDQG(GXFDWLRQ)RXQGDWLRQ Lifecycle Inventory of a 

Modern Municipal Solid Waste Landfill. :DVKLQJWRQ'&Available at 

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)HGHUDO:DWHU3ROOXWLRQ&RQWURO$FWRIDVDPHQGHGDOVRUHIHUUHGWRDVWKH&OHDQ:DWHU

$FW86&et seq. 

*&5386*OREDO&KDQJH5HVHDUFK3URJUDP  Highlights of Climate Change Impacts 

in the United States: The Third National Climate Assessment -00HOLOOR7&5LFKPRQGDQG

*:<RKHHGV 86*RYHUQPHQW3ULQWLQJ2IILFH:DVKLQJWRQ'& $FFHVVLRQ1R

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,1*$$,QWHUVWDWH1DWXUDO*DV$VVRFLDWLRQRI$PHULFDNorth American Midstream 

Infrastructure Through 2035—$6HFXUH(QHUJ\)XWXUH:DVKLQJWRQ'&$YDLODEOHDW

KWWSZZZLQJDDRUJ)LOHDVS["LG 

Magnuson–Stevens Fishery Conservation and Management Act RI, as amended86&

 et seq

0<$3&0DLQH<DQNHH$WRPLF3RZHU&RPSDQ\Maine Yankee Independent Spent 

Fuel Storage Installation Decommissioning Funding Plan:LVFDVVHW0DLQH$FFHVVLRQ

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National Environmental Policy Act of 1969 (NEPA), as amended86& et seq

1DWLRQDO+LVWRULF3UHVHUYDWLRQ$FW 1+3$, as amended 86& et seq 

1DWLRQDO5HVHDUFK&RXQFLODriving and the Built Environment: The Effects of Compact 

Development on Motorized Travel, Energy Use, and CO2 Emissions6SHFLDO5HSRUW 

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13&1DWLRQDO3HWUROHXP&RXQFLOTopic Paper #16: Refining and Manufacturing

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13&1DWLRQDO3HWUROHXP&RXQFLOPaper #1.9: Natural Gas Infrastructure

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136&&1DWLRQDO3DUNV6HFRQG&HQWXU\&RPPLVVLRQ Advancing the National Park 

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15&861XFOHDU5HJXODWRU\&RPPLVVLRQFinal Environmental Statement on 

Transportation of Radioactive Material by Air and Other Modes185(*í9ROXPH

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15&861XFOHDU5HJXODWRU\&RPPLVVLRQConsolidated Guidance About Materials 

Licenses: Guidance About Administrative Licensing Procedures185(*í9ROXPH 20, 

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15&861XFOHDU5HJXODWRU\&RPPLVVLRQDFinal Environmental Impact Statement for 

the Construction and Operation of an Independent Spent Fuel Storage Installation on the 

Reservation of the Skull Valley Band of Goshute Indians and the Related Transportation Facility 

in Tooele County, Utah185(*í9ROXPH:DVKLQJWRQ'&$FFHVVLRQ

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15&861XFOHDU5HJXODWRU\&RPPLVVLRQETechnical Study of Spent Nuclear Fuel 

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15&861XFOHDU5HJXODWRU\&RPPLVVLRQFinal Generic Environmental Impact 

Statement on Decommissioning of Nuclear Facilities, Supplement 1 Regarding the 

Decommissioning of Nuclear Power Reactors185(*í9ROXPH:DVKLQJWRQ, '&

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15&861XFOHDU5HJXODWRU\&RPPLVVLRQEnvironmental Assessment Related to the 

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15&861XFOHDU5HJXODWRU\&RPPLVVLRQDEnvironmental Assessment Related to 

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15&861XFOHDU5HJXODWRU\&RPPLVVLRQEEnvironmental Assessment Related to 

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15&861XFOHDU5HJXODWRU\&RPPLVVLRQFEnvironmental Assessment Related to 

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15&861XFOHDU5HJXODWRU\&RPPLVVLRQGGeneric Environmental Impact Statement 

for License Renewal of Nuclear Plants, Supplement 23 Regarding Point Beach Nuclear Plant 

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15&861XFOHDU5HJXODWRU\&RPPLVVLRQFinal Environmental Statement for an 

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15&861XFOHDU5HJXODWRU\&RPPLVVLRQFinal Environmental Statement for an 

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15&861XFOHDU5HJXODWRU\&RPPLVVLRQEnvironmental Assessment for the 

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15&861XFOHDU5HJXODWRU\&RPPLVVLRQDFinal Environmental Impact Statement for 

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15&861XFOHDU5HJXODWRU\&RPPLVVLRQFFinal Environmental Impact Statement for 

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15&861XFOHDU5HJXODWRU\&RPPLVVLRQHFinal Environmental Impact Statement for 

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7.0 Cost-Benefit Analysis 

In this chapter, the U.S. Nuclear Regulatory Commission (NRC) analyzes and compares the 

benefits and costs associated with the proposed action and the benefits and costs of NRC’s 

potential options in case of no action (“options”). This chapter, along with the rest of this 

Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel (GEIS), 

informs the NRC’s decision regarding whether to implement the proposed action. Only the 

proposed action—WKHDGRSWLRQRIDUHYLVLRQWR&)5WRFRGLI\WKHDQDO\VLVLQWKH*(,6

of the environmental impacts of continued storage of spent fuel—satisfies the purpose for the 

proposed action, which is to preserve the efficiency of the NRC’s licensing processes with 

regard to the environmental impacts of continued storage. Nonetheless, as discussed in 

Section 1.6.1 of this GEIS, the NRC has multiple options that it could implement if it chose not to 

DGRSWDUHYLVLRQWR&)5WRFRGLI\WKHanalysis in the GEIS of the environmental 

impacts of continued storage of spent fuel. 

In Chapters 4 DQGRIWKLVGEIS, the NRC discusses the potential impacts of continued atreactor and away-from-reactor storage, respectively, that may occur under three different 

continued-storage timeframes. In Chapter 6, the NRC addresses the potential cumulative 

impacts of continued storage. The proposed action and the NRC’s options in case of no action 

do not alter the NRC’s assessment of environmental impacts from continued storage that the 

15&DGGUHVVHGLQ&KDSWHUVDQG7KHproposed action and the options considered in 

this chapter instead provide different approaches that the NRC could apply to future licensing 

activities that can satisfy the need for the proposed action: they provide processes for use in 

NRC licensing to address the environmental impacts of continued storage. As a result, the 

costs and benefits shown in this chapter include the specific costs and benefits of the proposed 

action and NRC’s options in case of no action. The costs and benefits do not include the 

environmental impacts of continued storage, an activity that may occur regardless of the 

process that the NRC selects to consider the environmental impacts of continued storage. 

In addition, the costs and benefits addressed in this chapter do not include the potential financial 

costs of continued storage, which the NRC addresses throughout Chapter 2. 

Section 7.1 of this chapter contains the assumptions underlying the NRC’s cost-benefit analysis. 

Section 7.2 contains the costs and benefits of the proposed action (described in Section 1.4), 

ZKLOH6HFWLRQFRQWDLQVWKHFRVWVDQGEHQHILWVRIWKHsite-specific review option (described in 

Section 1.6.1.1). Section 7.4 contains the costs and benefits of the GEIS-only option (described 

in Section 1.6.1.2)DQG6HFWLRQFRQWDLQVWKHFRVWVDQGEHQHILWVRIWKHSROLF\-statement 

option (described in SHFWLRQ. Finally, Section 7.6 contains a summary and comparison 

of these costs and benefits. Additional details about the NRC’s estimated cost calculations are 

available in Appendix H, Estimated Cost of Alternatives. 
Cost-Benefit Analysis 

185(*௅ 7-2 September 2014 

7.1 Assumptions 

Throughout this chapter, the NRC projects the estimated costs and benefits of various ways the 

agency can consider the environmental impacts of continued storage. To the extent that the 

NRC considers cost information, the NRC presents figures in constant 2014 dollars and by 

DSSO\LQJSHUFHQWDQGSHUFHQWGLVFRXQWUDWHVDVSURYLGHGLQ2IILFHRI0DQDJHPHQWDQG

%XGJHW20%&LUFXODU$–20%DQG185(*%5í5HYLVLRQRegulatory 

Analysis Guidelines for the U.S. Nuclear Regulatory Commission (NRC 2004).1

In this analysis, the NRC projects the costs of future environmental reviews conducted from 

ILVFDO\HDU2FWREHUWKURXJK6HSWHPEHUWKURXJKILVFDO\HDU2FWREHU

WKURXJK6HSWHPEHU7KH15&DGRSWHGWKLV-year time period based on the 

H[DPSOHSURYLGHGLQ20%&LUFXODU$–4 and based on the approximate cumulative time period 

for which previous versions of the Waste Confidence rule (Title 10 of the Code of Federal 

Regulations 6HFWLRQ>&)5@KDYHH[LVWHG7KH-year time period allows the 

NRC to make meaningful comparisons between the proposed action and the NRC’s options in 

case of no action7KH-year time period begins in the month after the rulemaking is currently 

scheduled for completion. 

In contrast, the NRC estimates the costs of GEIS development and rulemaking activities that 

occur in fiscal yHDUVDQG because that is when the NRC incurred those costs. As a 

result, these costs are technically past, or “sunk” costs, but the NRC discloses them in its 

analysis to provide a complete and transparent analysis of the costs of the proposed action and 

NRC’s potential options in case of no action. In the absence of this cost information, the 

 

1 The estimated costs provided in this chapter differ from those provided in Chapter 7 of the draft GEIS for 

several reasons. First, the NRC has updated costs in this chapter to reflect the agency’s latest full-time 

equivalent (FTE) cost estimate, which is 4 percent lower than the 2012 estimate used to calculate staff 

costs for the draft GEIS. In additionZKHUHDSSOLFDEOHWKH15&KDVDGMXVWHGFRVWVLQFXUUHGLQWR

2014 dollars using the same formula presented in Chapter 2 (this effect tends to be relatively minor and 

DIIHFWVRQO\WKH*(,6DQGUXOHPDNLQJFRVWVLQFXUUHGLQ,QDGGLWLRQDOOIXWXUHFRVWVDUHGLIIHUHQW

EHFDXVHWKHEDVHOLQH\HDULVQRZLQVWHDGRIwhich was used in the draft. As a result, there is 

one less year of discounting. Finally, site-specific review costs for two new reactor applications are higher 

than they were in the draft GEIS because the NRC now estimates that environmental impact statements 

(EISs) for these two reviews would require supplementation if the NRC decides to pursue one of the noaction options. The combined effect of these differences is that the costs of the NRC’s options in the 

case of no action are higher than they were in the draft GEIS because the increased costs of new reactor 

reviews plus the loss of one year of discounting is larger than the effect of the NRC’s lower FTE rates. At 

the same time, the cost of the proposed action is lower in the constant-GROODUVDQGSHUFHQWGLVFRXQWLQJ

cases than it was for the same cases in the draft GEIS because the effect of the reduced FTE rate is 

larger than the effects of lost discounting and the Consumer Price Index (CPI) adjustment; however, in 

the 7 percent discounting case the cost of the proposed action is higher than it was in the draft GEIS 

because the lost discounting plus the CPI adjustment has a larger effect than the NRC’s reduced FTE 

rates. 
Cost-Benefit Analysis 

September 2014 7- 185(*௅

proposed action would appear to have no costs, and the GEIS-only and policy-statement 

options would entail fewer costs. Because approximately half of the costs of the GEIS 

development DQGUXOHPDNLQJDUHHVWLPDWHGWRKDYHRFFXUUHGLQWKH15&KDVDGMXVWHG

FRVWVLQWDEOHs throughout this chapter to constant 2014 dollars using the Bureau of Labor 

Statistics’ (BLS’) Consumer Price Index (CPI) as described in Section 2.1 of this GEIS (CPI data 

from BLS 2014). Although the costs of GEIS development and rulemaking activities have been 

incurred, the NRC does not include these costs for options that do not require their completion 

(e.g., the estimated cost of the site-specific review option does not include GEIS or rulemaking 

costs). 

The NRC made reasonable assumptions for current and future licensing reviews that inform the 

NRC’s cost estimates. This analysis considers site-VSHFLILFOLFHQVLQJUHYLHZVRYHU\HDUVWKDW

would rely RQ&)5WRDGGUHVVWKHHQYLURQPHQWDOLPSDFWVRIFRQWLQXHGVWRUDJH$OO

assumptions related to NRC costs for continued storage include costs associated with the 

additional NRC efforts on National Environmental Policy Act of 1969, as amended (NEPA) 

reviews as well as NRC participation in adjudicatory hearings, as appropriate. 

The GEIS assumptions are based in part on NRC projections of current and likely licensing 

reviews (see, for example, SECY–12–IRUDOLVWRIDSSOLFDWLRQVFXUUHQWO\XQGHUUHYLHZRU

projected to begin before the end of fiscal year >15&@7KHDVVXPSWLRQVDGGUHVV

three categories of licensing actions: new reactor applications, reactor license renewal 

applications, and site-specific independent spent fuel storage installations (ISFSI) applications. 

The NRC assumes that applicants for new or renewed licenses affected by &)5 would 

incur costs in the absence of an updated Rule equal to those the NRC incurs in addressing the 

impacts of continued storage. As a result, the total costs for site-specific reviews are double the 

NRC’s costs discussed in this chapter. Quantified totals in the tables in this chapter include 

industry costs. The NRC assumes that applicants will incur additional costs by developing 

applications that address the environmental impacts of continued storage, responding to the 

NRC’s requests for additional information related to continued storage, and participating in any 

adjudicatory proceedings related to continued storage. 

The NRC may potentially incur some unquantified costs when implementing either the proposed 

action or any of the NRC’s potential options in case of no action because all of these 

approaches to addressing the environmental impacts of continued storage differ, in some 

aspects, from the NRC’s long-HVWDEOLVKHGDSSURDFKRIUHO\LQJRQ&)5VXSSRUWHGE\DQ

environmental assessment (EA). These implementation costs are likely to be similar in 

magnitude for whichever approach the NRC implements. 

The NRC calculated its estimated costs based in part on anticipated staff time—measured in 

full-time equivalents (FTEs)—and anticipated contractor effort, where applicable, measured in 

contract dollars. The average cost for one NRC staff FTE is $166,000 per year (based on data 
Cost-Benefit Analysis 

185(*௅ 7-4 September 2014 

FROOHFWHGIURPILVFDO\HDU, which is based on the methodology provided in 

185(*&5í4627, Generic Cost Estimates (Sciacca 1992). The NRC’s estimates of potential 

licensing actions and associated cost calculations are available in Appendix H, Estimated Costs 

of Alternatives. 

7.1.1 New Reactor Applications 

The NRC is currently reviewing nine combined license (COL) applications and one early site 

permit (ESP) application (see Appendix H, Table H-1, for a list of applications).2 In reviewing 

each COL and ESP application, the NRC develops a site-specific environmental impact 

statement (EIS) that addresses the potential environmental impacts of the proposed facility. 

If the NRC takes no action WRDGRSWDUHYLVHG&)5WKHQWKH15&ZRXOGQHHGWR

separately address the environmental impacts of continued storage in the course of each 

ongoing and future new-reactor licensing review. The NRC assumes that the first site-specific 

review of the environmental impacts of continued storage would require more time and effort 

than subsequent reviews because the first application would be developed with a general 

approach that could then be used in subsequent application reviews. 

In general, COL and ESP application reviews take longer and require more staff effort to 

complete than other NRC reviews that relied on &)5. Among other factors, COL and 

ESP applications frequently include cooperating agencies, while COL proceedings additionally 

require mandatory hearings prior to a Commission decision on an application. The NRC 

estimates that the first site-specific review of continued storage in a COL EIS supplement

ZRXOGUHTXLUHDSSUR[LPDWHO\)7(VRU647,000, and $1 million in contractor support (total of 

$1.6 million), based on staff experience supplementing COL EISs. The NRC estimates that 

 

2 2QHRIWKH&2/DSSOLFDWLRQVFXUUHQWO\XQGHUUHYLHZ&DOYHUW&OLIIV8QLWLVVXEMHFWWRVXEVWDQWLDO

uncertainty. An NRC Atomic Safety and Licensing Board (ASLB) found that the applicants are ineligible 

to receive a COL because they are wholly owned by a foreign company, in violation of Commission policy 

EDVHGRQ6HFWLRQd of the Atomic Energy Act (LBP-12-2Q0DUFK WKH&RPPLVVLRQ

denied the applicants’ appeal of the ASLB’s decision (CLI––04) 15&D. The applicants have 

stated that they intend to find a domestic co-owner for the proposed facility. For the purposes of this 

analysis, however, the NRC has included WKH&DOYHUW&OLIIV8QLW&2/DSSOLFDWLRQ

 Under &)5DWKHNRC prepares a supplement to a final EIS when a proposed action has not 

yet been taken, but there are either substantial changes in the proposed action that are relevant to 

environmental concerns or there are new and significant circumstances or information relevant to 

environmental concerns and bearing on the proposed action or its impacts. For the first three newreactor reviews, the NRC anticipates that it would supplement final EISs. The supplementation process 

includes development of a draft supplemental EIS, publication of the draft supplemental EIS, an 

opportunity for public comments on the draft, NRC efforts to consider and resolve comments, and 

publication of a final supplemental EIS. This process generally duplicates costs already incurred in a 

standard EIS process. During the supplementation process, applicants may incur expenses when they 

develop supplements to existing applications, when they respond to NRC requests for additional 

information, and when they participate in adjudicatory proceedings related to issues raised during the 

supplemental EIS process. 
Cost-Benefit Analysis 

September 2014 7- 185(*௅

the next seven reviews (i.e., six COLs and one ESP) will require supplementation of existing 

EISs at a cost of approximately 2.9 FTEs, or $DQGLQFRQWUDFWVXSSRUWDWRWDO

of $) each. The NRC estimates that two remaining new reactor reviews, which do not 

UHTXLUHVXSSOHPHQWDWLRQZLOOUHTXLUH)7(RU49,00.4 See Appendix H, Table H-1, for new 

reactor cost calculations. 

As noted in Chapter 2 of this GEIS, the NRC is currently engaged in preapplication activities 

with several applicants for light water small modular reactors. Because the light water reactor 

fuel that would be used in iPWR (integral pressurized water reactors; a type of small modular 

reactor) designs is substantially similar to existing light water reactor fuel (i.e., zircaloy clad, lowenriched uranium oxide pellets in square cross-section fuel rod arrays), iPWR fuel is within the 

scope of the GEIS analysis. The NRC expected to receive applications for NRC review and 

DSSURYDORIVPDOOPRGXODUGHVLJQVSXUVXDQWWR&)53DUWDVHDUO\DV15&E

but there is no current plan for the NRC to receive or begin review of applications for specific 

small modular reactor power plants. 

Design certification reviews for iPWRs would not require assessments of the impacts of 

continued storage, but licensing reviews for specific sites would require these assessments. At 

the time of this GEIS publication, only one licensee, the Tennessee Valley Authority (TVA), has 

expressed an interest in applying for FRQVWUXFWLRQSHUPLWVSXUVXDQWWR&)53DUWIRUWZRWR

six small modular reactors, with potential subsequent units licensed pursuant to 10 CFR Part 

15&F,Q1, TVA informed the NRC of its intent to submit a construction permit 

application (TVA 2011), but TVA has not submitted an application as of the GEIS publication 

date. 

As a result of the substantial uncertainties associated with future small modular reactor licensing 

reviews, the NRC has not included any small modular reactors in its cost projections. Beyond 

the uncertainty related to applications, there is some uncertainty about review costs for small 

modular reactor applications. It is reasonable to assume, however, that the effort necessary to 

address the environmental impacts of continued storage for small modular reactors will be similar 

to the effort necessary to address the environmental impacts of continued storage for other new 

reactor applications. If applicants develop and submit applications for small modular reactors to 

WKH15&WKHQHDFKDGGLWLRQDOUHYLHZDFWLYLW\ZRXOGUHTXLUHDQHVWLPDWHG)7(RU49,00. 

 

4 An additional facility, Watts Bar Nuclear Plant, Unit 2, is a proposed new reactor currently undergoing an 

operating license review under &)53DUW7KH15&SURMHFWVWKDWWatts Bar Nuclear Plant, Unit 2, 

would require approximately 1.4 FTEs and no contractor support for a review of environmental impacts of 

continued storage, for a total cost of $22,000. The approach and format for the Watts Bar Nuclear Plant, 

Unit 2 EIS (NRC 2011) is substantially similar to EISs developed for reactor license renewal, so the cost 

projection is the same as the projection applied to plants undergoing license renewal reviews that require 

EIS supplementation. 
Cost-Benefit Analysis 

185(*௅ 7-6 September 2014 

7.1.2 Reactor License Renewal 

The NRC currently has ten reactor license renewals under review (see Appendix H, Table H-2, 

for a list of applications). An approved license renewal may add up to 20 years of additional 

RSHUDWLRQWRDQH[LVWLQJFRPPHUFLDOSRZHUUHDFWRUOLFHQVH&)5E

In the course of reviewing a license renewal application, the NRC prepares a site-specific 

supplement to the GEIS for License Renewal of Nuclear Plants (License Renewal GEIS, or 

NUREGí$VXSSOHPHQWDO(,6IRUOLFHQVHUHQHZDOUHTXLUHVOHVVWLPHDQGHIIRUWWKDQD

COL or ESP EIS because the License Renewal GEIS has already addressed many 

environmental issues, the plant under review has typically been operating at the site for at least 

20 years (avoiding the need for a review of alternative sites for the proposed renewal) and its 

effects on the environment tend to be well understood, and because license renewal typically 

involves no new construction. In addition, license renewal supplemental EISs typically do not 

include cooperating agencies and do not require mandatory hearings. If the NRC takes no 

DFWLRQWRDGRSWDUHYLVHG&)5WKHQWKH15&ZRXOGQHHGWRVHSDUDWHO\DGGUHVVWKH

environmental impacts of continued storage in the course of each ongoing and future reactorlicense-renewal review. 

The NRC projects that the first site-specific review of continued storage in a supplemental EIS 

for license renewal would require more time and effort than subsequent reviews in order to 

develop a general approach that subsequent reviews would then use. The first review would 

UHTXLUHDQHVWLPDWHG)7(VRU4,000 based on NRC experience supplementing license 

renewal EISs. The NRC further projects that some reviews would require supplementation of 

existing EISs, and these reviews would require approximately 1.4 FTEs, or $22,000. Reviews 

that have already begun but that do not require supplementation would require approximately 

1.1 FTEs, or $1,000. Reviews of applications that have not yet been submitted would require 

DSSUR[LPDWHO\)7(RU49,00, or the same amount of effort as new reactor reviews that do 

not require supplementation. In addition to reviews already received, the NRC projects that all 

plants that have yet to apply for license renewal would apply for renewal by 2020 for purposes 

of WKLVDQDO\VLV15&G See Appendix H, Table H-2, for license renewal cost 

calculations. 

Further, the NRC assumes that approximately half of the existing reactor fleet will apply for 

subsequent license renewal (which could allow plants to operate for a total of XSWR\HDUV

EHJLQQLQJLQ7KH15&HVWLPDWHVWKDWLWZLOOUHYLHZDWRWDORIDSSOLFDWLRQV—or one 

 

 Watts Bar Nuclear Plant, Unit 1 is the only unit licensed under &)53DUWWKDWis not eligible to 

request license renewal at the time of GEIS publication. The NRC assumes that this facility will 

eventually seek a license renewal for purposes of this analysis. 
Cost-Benefit Analysis 

September 2014 7-7 185(*௅

application per year—from 2017 through the end of 2044.6 The NRC assumes that the 

continued storage portion of these NEPA reviews will be substantially similar to the reviews 

performed during the initial license renewal review. The NRC estimates that subsequent license 

UHQHZDOUHYLHZVZLOOUHTXLUHDQHVWLPDWHG)7(RU49,00. 

7.1.3 ISFSI Licensing 

&XUUHQWO\VLWHVSRVVHVVVLWH-specific ISFSI licenses (NRC 201e), and one potential 

applicant has expressed an interest in licensing a new away-from-UHDFWRU,6)6,(/($7 

The majority of existing ISFSIs, however, are generally licensed. The NRC does not perform a 

site-specific review for generally licensed ISFSIs; rather, historically, the NRC has performed an 

($ZLWKDILQGLQJRIQRVLJQLILFDQWLPSDFW>)216,@IRUHDFKDYDLODEOHFDVNGHVLJQDQGa 

facility’s ability to possess nuclear materials is subject to its 10 &)53DUWor 3DUW license. 

As a result, the NRC assumes, for purposes of this analysis, that there are no costs associated 

with general ISFSI licensing related to considering the environmental impacts of continued 

VWRUDJHGXULQJWKH-year analysis period. 

The term for a site-specific ISFSI license must not exceed 40 years (10 CFR 72.42(a)). During 

site-specific ISFSI licensing (new licenses and license renewals), the NRC typically develops an 

EA that concludes with a FONSI. To date, every at-reactor site-specific ISFSI EA has reached 

a FONSI. ,IWKH15&WDNHVQRDFWLRQWRDGRSWDUHYLVHG&)5WKHQWKH15&ZRXOG

need to separately address the environmental impacts of continued storage in the course of 

each ongoing and future site-specific ISFSI review. 

7KH15&HVWLPDWHVWKDWDSSUR[LPDWHO\)7(, or $,000, is necessary to support sitespecific considerations of continued storage matters in the first two ISFSI EAs, both of which 

 

6 Commercial nuclear power plant licensees typically apply for license renewal for all reactors at a site at 

the same time. There are currently 61 sites (Salem and Hope Creek share a site) that host operational 

commercial power reactors with &)53DUWoperating licenses or both &)53DUWoperating 

licenses and &)53DUWcombined licenses. Licensees have announced plans to cease nuclear 

power plant operations at two of these sites, Vermont Yankee and Oyster Creek. Of the remaining 9 

sites, licensees at three sites could apply for subsequent license renewal after 2044 (beyond the period of 

this analysis) and still potentially meet the timely renewal provisions of 10 CFR 2.109 (Comanche Peak 

Units 1 and 2; Seabrook; and Watts Bar Nuclear Plant, Unit 1). Removing from the analysis the plants 

whose operators have announced their intent to shut down prior to seeking subsequent renewal leaves a 

PD[LPXPRIWR currently operating sites whose operators may apply for subsequent license 

renewal during the analysis period. Because the NRC assumes that operators will apply for subsequent 

license renewal for approximately half of the operational sites, WKH15&LQFOXGHV KDOIRI

subsequent-renewal reviews in this analysis. The inclusion of any particular licensing action in this 

analysis does not prejudge the outcome of any pending or future license renewal review; rather it 

addresses the potential cost implications of potential subsequent renewals. 

7 Private Fuel Storage (PFS)—an away-from-reactor ISFSI licensee—applied for and received a sitespecific license, but its facility has not been constructed, nor has it taken delivery of spent fuel. 
Cost-Benefit Analysis 

185(*௅ 7- September 2014 

DUHFXUUHQWO\XQGHUUHYLHZ7KH15&HVWLPDWHVWKDWODWHU,6)6,($VZLOOUHTXLUH)7(RU

$41,00. See Appendix H, Table H-, for ISFSI-related cost calculations and a list of affected 

actions. 

7.2 Estimated Costs and Benefits of the Proposed Action 

In the proposed action, the NRC adopts an updatHG5XOH&)5ZKLFKFRGLILHVRU

adopts into regulation, the analysis in the GEIS of the environmental impacts of continued 

storage of spent fuel. The update would clarify that, because the impacts of continued storage 

have been generically assessed in a GEIS and codified in a Rule, the NEPA analyses for future 

reactor and spent fuel storage facility licensing actions will incorporate or consider, respectively, 

the impact determinations in the GEIS regarding the environmental impacts of continued 

storage. The effect of the adoption of the analysis into the Rule means that the NRC will 

conclusively use the environmental impact determinations from the analysis in individual license 

proceedings, unless a petitioner VDWLVILHVWKHUHTXLUHPHQWVRI&)5LQFOXGLQJD

showing of special circumstances, to waive the application of 10 CFR LQDSDUWLFXODU

proceeding. 

The primary benefit of the proposed action is that it eliminates from site-specific licensing 

reviews the costs associated with identifying the environmental impacts of continued storage. 

In addition, this approach is generally consistent with Council on Environmental Quality (CEQ) 

JXLGDQFHUHJDUGLQJHIILFLHQF\DQGWLPHOLQHVVXQGHU1(3$)5, as well as the 

NRC’s longstanding preference for resolving generic issues generically (see, for example, 

 FR . 

As shown in Table 7-1, preparation of the GEIS and Rule incurs costs. The NRC estimates that 

the proposed action requires DSSUR[LPDWHO\ FTEs (RU million) LQHDFKRIDQG

2014, or $7.64 million total (unadjusted). In addition, the proposed action requires an estimated 

$6 million (unadjustedRIFRQWUDFWVXSSRUWVSUHDGDFURVVWKH\HDUV0RVWRIWKHH[SHQGLWXUHV

associated with the proposed action will occur as a result of the GEIS development. The NRC 

estimates that approximately 6 FTE, or $1.04 million, of the total expenditure is a result of the 

rulemaking portion of the proposed action. See Appendix H, Table H-4, for more information 

regarding GEIS and rulemaking costs. 

As noted in Section 7.1, the NRC has adjusted GEIS and rulemaking costs to 2014 dollars using 

the CPI. In addition, because NRC’s costs for the GEIS and rulemaking do not occur in the 

future, GEIS and rulemaking costs are not affected by discounting. As also noted in 

Section 7.1, while GEIS and rulemaking costs are technically past, or “sunk” costs, the NRC 

discloses them in Table 7-1 as costs of the proposed action to provide a complete and 

transparent analysis of the costs of the proposed action and the NRC’s potential options in case 

of no action. 
Cost-Benefit Analysis 

September 2014 7-9 185(*௅

Table 7-1. Estimated Costs of the Proposed Action 

Components 

Estimated Costs (millions of 2014 dollars) 

Constant Dollars 3% Discount Case 7% Discount Case 

Site-Specific Review Costs(a) - - - 

GEIS Costs $12.7 $12.7 $12.7 

Rulemaking Costs $1.00 $1.00 $1.00 

Policy Statement Costs - - - 

Estimated Total Cost(b) $13.7 $13.7 $13.7 

(a) Table 7-1, Table 7-2, Table 7-, and Table 7-4 contain line items for site-specific review costs, GEIS costs, 

rulemaking costs, and policy statement costs, respectively. The NRC populates each table according to the 

components necessary for the action considered in each respective section. Here, the proposed action does 

not require a policy statement, so the NRC includes no costs for that component in Table 7-1. 

(b) Due to rounding, costs may not appear to sum correctly. All costs are rounded to three significant figures. 

7.3 Estimated Costs and Benefits of the Site-Specific 

Review Option 

Under the site-specific review option, the NRC would not adopt an updated &)5, nor 

would it implement any of the other approaches considered in this GEIS. The NRC would not 

rely on this GEIS, but it may, however, attempt to make use of some of the work already 

performed during the development of the GEIS. The NRC would review the generic 

environmental impacts from continued storage in licensing-specific NEPA reviews that the NRC 

performs for new reactor licensing, reactor license renewal, ISFSI licensing, and ISFSI license 

renewal (see Appendix H, Table H-1, Table H-2, and Table H-IRUDIIHFWHGDFWLRQVDQGWKHLU

respective estimated costs). The NRC and license applicants incur the majority of the costs 

from the site-specific review option. Costs also accrue through NRC adjudicatory activities, 

which affect the NRC, license applicants, and petitioners or interveners. In general, expenses 

to petitioners are case-specific and difficult to quantify, so the NRC has not quantified them 

here. Table 7-2 contains cost estimates for the site-specific review option based on the detailed 

information presented in Appendix H. 

Table 7-2. Constant and Discounted Estimated Costs of the Site-Specific Review Option 

Components 

Estimated Costs (millions of 2014 dollars) 

Constant Dollars 3% Discount Case 7% Discount Case 

Site-Specific Review Costs $27. $24.7 $22.

GEIS Costs - - - 

Rulemaking Costs - - - 

Policy Statement Costs - - - 

Estimated Total Cost(a) $27.3 $24.7 $22.3 

(a) Due to rounding, costs may not appear to sum correctly. All figures are rounded to three significant figures. 
Cost-Benefit Analysis 

185(*௅ 7-10 September 2014 

The primary quantifiable benefit of the site-specific review option is that the NRC would not need 

to prepare a GEIS and Rule or a policy statement (consequently, the past costs of GEIS 

development and rulemaking, while already incurred, are not included in Table 7-2). Perceptions 

vary among stakeholders regarding whether reviewing the environmental impacts of continued 

storage in site-specific licensing actions or being able to challenge the consideration of these 

impacts in litigation without a waiver is classified as a cost or a benefit. In a site-specific NEPA 

analysis, the NRC would describe location-specific conditions, address the site-specific impacts 

of a potential licensing action, and address the impacts of continued storage. The value of 

reviewing continued storage in site-specific NEPA analyses is difficult to quantify. 

Another cost of the site-specific review option relates to increased scheduling uncertainties in 

licensing due to additional environmental reviews and potential increased litigation associated 

with continued storage. The effects of schedule uncertainties are likely to be most significant for 

new reactor or new site-specific ISFSI applicants. Delays can be more costly for new reactor 

applicants, which could incur billions of dollars of additional expenses if a project is delayed. 

These costs can include increased financing costs, longer-term accumulation of interest on 

debt, replacement-power costs, and contractual penalties. Because these costs are highly 

case-specific, the NRC has not attempted to quantify them. 

Applicants for renewed reactor and site-specific ISFSI licenses that submit timely and sufficient 

renewal applications are protected from schedule uncertainty, at least insofar as continued 

operations are concerned, by 10 CFR 2.109. Specifically, 10 CFR 2.109 allows for operations 

of reactors and ISFSIs until the applications have been finally determined, even if final 

determinations take place after the license expiration dates. Nonetheless, delays may affect 

applicants’ plans to commence activities that may depend upon renewed licenses. Because 

these types of expenses vary significantly and are case-specific, the NRC has not attempted to 

quantify them. 

7.4 Estimated Costs and Benefits of the GEIS-Only Option 

The GEIS-only option is similar to the proposed action insofar as the NRC develops and relies 

upon this GEIS. It differs because the Commission does not DGRSWDQXSGDWHG&)5

that codifies the GEIS findings. Because the Commission does not codify the GEIS findings in 

this no-action option, the environmental impacts of continued storage remain open to sitespecific consideration by the NRC. Petitioners may also challenge an applicant’s or the NRC’s 

consideration of the impacts of continued storage without a waiver petition pursuant to 

10 CFR 5HOLDQFHRQD*(,6WRDGGUHVVJHQHULFLVVXHV, however, is consistent with 

CEQ guidance regaUGLQJHIILFLHQF\DQGWLPHOLQHVVXQGHU1(3$)5

The primary benefit of the GEIS-only option relative to the site-specific review option is that it 

reduces NRC and applicant costs in conducting NEPA reviews. The NRC assumes that 
Cost-Benefit Analysis 

September 2014 7-11 185(*௅

applicants will refer to GEIS findings in environmental reports, and the NRC will incorporate 

GEIS findings and analyses by reference into NEPA documents for new reactor licensing, 

reactor license renewals, ISFSI licensing, and ISFSI license renewals. The NRC assumes that 

reliance on the GEIS in site-specific reviews may resolve concerns for some issues related to 

continued storage, while other issues may require additional effort to resolve comments, 

address site-specific litigation, or to establish that the GEIS findings are applicable to a specific 

licensing proceeding. As a result, the NRC assumes that the GEIS-only option will decrease the 

cost to the NRC DQGDSSOLFDQWVE\SHUFHQWFRPSDUHGWRWKHsite-specific review option at 

best, and at worst will not reduce the NRC and applicant effort compared to the site-specific 

review option. Therefore, the NRC presents the costs of the GEIS-only option as a range in 

Table 7-. 

Table 7-3. Constant and Discounted Estimated Costs of the GEIS-Only Option 

Components 

Estimated Costs (millions of 2014 dollars) 

Constant Dollars 3% Discount Case 7% Discount Case 

Site-Specific Review Costs $1.6 to $27. $12.4 to $24.7 $11.2 to $22.

GEIS Costs $12.7 $12.7 $12.7 

Rulemaking Costs - - - 

Policy Statement Costs - - - 

Estimated Total Cost(a) $26.4 to $40.0 $25.1 to $37.5 $23.9 to $35.1 

(a) Due to rounding, costs may appear not to sum correctly. All costs are rounded to three significant figures. 

As was the case in the site-specific review option, perceptions vary among stakeholders 

regarding whether reviewing the environmental impacts of continued storage in site-specific 

licensing actions as part of the GEIS-only option or being able to challenge the consideration of 

these impacts without a waiver is classified as a cost or a benefit. In a site-specific NEPA 

analysis, the NRC would describe location-specific conditions, address the site-specific impacts 

of a potential licensing action, and address the impacts of continued storage. 

Preparation of the GEIS, however, requires costs not necessary under the site-specific review 

alternative, as shown in Table 7-. GEIS preparation requires an estimated 20 FTEs (or 

 million) LQHDFKRIDQGRU6.64 million total (unadjusted). In addition, GEIS 

preparation requires an estimated $6 million of contract support spread across the 2 years. 

See Appendix H, Table H-4, for more information regarding GEIS costs. 

As noted in Section 7.1, the NRC has adjusted GEIS costs in Table 7- to 2014 dollars using 

the CPI. In addition, because NRC’s costs for the GEIS do not occur in the future, GEIS costs 

are not affected by discounting. As also noted in Section 7.1, while GEIS costs are technically 

past, or “sunk” costs, the NRC discloses them in Table 7- as costs of the GEIS-only option to 

provide a complete and transparent analysis of this potential option in the case of no action. 
Cost-Benefit Analysis 

185(*௅ 7-12 September 2014 

The NRC does not include the past costs of rulemaking in Table 7- because rulemaking is not 

a necessary component of the GEIS-only option. 

Similar to the site-specific review option, another cost of the GEIS-only option relates to 

increased scheduling uncertainties in licensing due to additional environmental reviews and 

potential increased litigation associated with continued storage. The effects of schedule 

uncertainties are likely to be most significant for new reactor or new site-specific ISFSI 

applicants. Delays can be more costly for new reactor applicants, which could incur billions of 

dollars of additional expenses if a project is delayed. These costs can include increased 

financing costs, longer-term accumulation of interest on debt, replacement-power costs, and 

contractual penalties. Because these costs vary significantly and are case-specific, the NRC 

has not attempted to quantify them. 

Applicants for renewed reactor and site-specific ISFSI licenses that submit timely and sufficient 

renewal applications are protected from schedule uncertainty, at least insofar as continued 

operations are concerned, by provisions of 10 CFR 2.109. Specifically, 10 CFR 2.109 allows for 

operations of reactors and ISFSIs until the applications have been finally determined, even if 

final determination takes place after the license expiration date. Nonetheless, delays may affect 

applicants’ plans to commence activities that may depend upon renewed licenses. Because 

these types of expenses are case-specific, the NRC has not attempted to quantify them. 

7.5 Estimated Costs and Benefits of the Policy-Statement 

Option 

The policy-statement option in case of no action is similar to the GEIS-only option. As in the 

GEIS-only option, the policy-statement option would rely on this GEIS to address the 

environmental impacts of continued storage. In addition, the Commission would develop a 

policy statement to address specific issues and to bind the NRC in its approach to addressing 

the environmental impacts of continued storage in site-specific environmental reviews. 

As in the GEIS-only option, the Commission does not DGRSWDQXSGDWHG&)5WKDW

codifies the GEIS findings. Because the Commission does not codify the GEIS findings in this 

option, the environmental impacts of continued storage remain open to site-specific 

consideration by the NRC, within the constraints imposed by the Commission’s policy 

statement. Petitioners may challenge an applicant’s or the NRC’s consideration of the impacts 

RIFRQWLQXHGVWRUDJHZLWKRXWDZDLYHUSHWLWLRQSXUVXDQWWR&)5DQGZRXOGQRWEH

constrained by the Commission’s policy statement on continued storage. Reliance on a GEIS, 

however, to address generic issues is consistent with CEQ guidance regarding efficiency and 

timeliness under NEPA (77 FR 
Cost-Benefit Analysis 

September 2014 7- 185(*௅

In application, the policy-statement option is substantially similar to the GEIS-only option. The 

primary benefit is that it reduces NRC and applicant effort in conducting reviews, thereby 

increasing efficiency and thus decreasing cost. The NRC assumes that applicants will refer to 

GEIS findings in environmental reports, and the NRC will incorporate GEIS findings and 

analyses by reference into site-specific EISs for new reactors, reactor license renewals, and 

ISFSI licensing. As in the GEIS-only option, the NRC assumes that reliance on the GEIS in 

site-specific reviews may resolve concerns for some issues related to continued storage, while 

other issues may require additional effort to resolve comments, address site-specific litigation, 

or to establish that the GEIS findings are applicable to a specific licensing proceeding. The 

NRC assumes that the decreased cost in conducting site-specific reviews under the policystatement option relative to the site-specific review option is likely to be similar to the decreased 

effort from the GEIS-only option relative to the site-specific review option. The NRC assumes 

that the policy-statement option will decrease the cost to the NRC and applicants by an 

HVWLPDWHGSHUFHQWUHODWLYHWRWKHsite-specific review option, at best, and at worst will not 

reduce the NRC and applicant effort compared to the site-specific review option. The NRC 

therefore presents the cost of the policy-statement option as a range in Table 7-4. 

Table 7-4. Constant and Discounted Estimated Costs of the Policy-Statement Option 

Components 

Estimated Costs (millions of 2014 dollars) 

Constant Dollars 3% Discount Case 7% Discount Case 

Site-Specific Review Costs $.6 to $27. $12.4 to $24.7 $11.2 to $22.

GEIS Costs $12.7 $12.7 $12.7 

Rulemaking Costs - - - 

Policy Statement Costs $0. $0.476 $0.

Estimated Total Cost(a) $26.9 to $40.5 $25.6 to $38.0 $24.3 to $35.5 

(a) Due to rounding, costs may appear not to sum correctly. All costs are rounded to three significant figures. 

Preparation of the GEIS and policy statement contribute to the costs of this option. The NRC 

HVWLPDWHVWKDWDSROLF\VWDWHPHQWDGGV)7(VRU,000 (undiscounted), to the cost estimate 

for the policy-statement option. GEIS preparation requires an estimated 20 FTEs, or 

 PLOOLRQLQHDFKRIDQGRU6.44 million total (unadjusted). In addition, GEIS 

preparation requires an estimated $6 million (unadjusted) of contract support spread across the 

2 years. As a result of the effort expended in creating the GEIS and policy statement in addition 

to the effort expended in performing site-specific reviews, the policy-statement option provides 

a negative net benefit when compared to the site-specific review option. See Appendix H, 

Table H-4, for more information regarding GEIS and policy-statement costs. 

As noted in Section 7.1, the NRC has adjusted GEIS costs in Table 7-4 to 2014 dollars using 

the CPI. In addition, because NRC’s costs for the GEIS do not occur in the future, GEIS costs 

are not affected by discounting. Costs of the policy statement, however, are estimated to occur 
Cost-Benefit Analysis 

185(*௅ 7-14 September 2014 

LQDQGDQGVRDUHSUHVHQWHGLQGLVFRXQWHGILJXUHVZKHUHDSSURSULDWHAlso, while 

GEIS development costs are technically past, or “sunk” costs, the NRC discloses them in 

Table 7-4 as costs of the policy-statement option to provide a complete and transparent analysis 

of this potential option in the case of no action. The NRC does not include the past costs of 

rulemaking in Table 7-4 because rulemaking is not a necessary component of the policystatement option. 

Similar to the site-specific review and GEIS-only options, another cost of the policy-statement 

option relates to increased scheduling uncertainties in licensing due to additional environmental 

reviews and potential increased litigation associated with continued storage. The effects of 

schedule uncertainties are likely to be most significant for new reactor or new site-specific ISFSI 

applicants. Delays can be more costly for new reactor applicants, which could incur billions of 

dollars of additional expenses if a project is delayed. These costs can include increased 

financing costs, longer-term accumulation of interest on debt, replacement-power costs, and 

contractual penalties. Because these costs vary significantly and are case-specific, the NRC 

has not attempted to quantify them. 

As was the case in the site-specific review option and the GEIS-only option, perceptions vary 

among stakeholders regarding whether reviewing the environmental impacts of continued 

storage in site-specific licensing actions as part of the policy-statement option or being able to 

challenge the consideration of these impacts without a waiver is classified as a cost or a benefit. 

In a site-specific NEPA analysis, the NRC would describe location-specific conditions, address 

the site-specific impacts of a potential licensing action, and address the impacts of continued 

storage. 

Applicants for renewed reactor and site-specific ISFSI licenses that submit timely and sufficient 

renewal applications are protected from schedule uncertainty, where continued operations are 

concerned, by provisions of 10 CFR 2.109. Specifically, 10 CFR 2.109 allows for operations of 

reactors and ISFSIs until the applications have been finally determined, even if final 

determination takes place after the license expiration date. Nonetheless, delays may affect 

applicants’ plans to commence activities that may depend upon renewed licenses. Because 

these types of expenses vary significantly and are case-specific, the NRC has not attempted to 

quantify them. 

7.6 Comparison of Alternatives 

Table 7- summarizes the estimated quantified costs for the proposed action and NRC’s 

potential options under the no-action alternative. The analysis indicates that the quantified cost 

for the proposed action is significantly lower than the cost for any of the options under the noaction alternative (see Table 7-; this disparity would have been even greater if the NRC had 

not included the past, or “sunk” costs of the GEIS and rulemaking). This occurs primarily 
Cost-Benefit Analysis 

September 2014 7-1 185(*௅

because the NRC does not undertake site-specific reviews of continued storage in the course of 

individual licensing proceedings as part of the proposed action. For additional detail, see 

Appendix H, Table H-. 

Table 7-5. Summary of Constant and Discounted Estimated Costs for the Proposed Action 

and NRC’s Potential Options in the Case of No Action (in millions of 2014 dollars) 

Estimated Cost Proposed Action GEIS-Only Policy-Statement Site-Specific Review 

Constant 2014 Dollars $1.7 $26.4 to $40.0 $26.9 to $40. $27.

'LVFRXQW&DVH 7 $2.1 to $7. $6 to $.0 $24.7 

'LVFRXQW&DVH 7 $2.9 to $.1 $24. to $. $22.

(a) Due to rounding, some costs may appear not to sum correctly. All costs are rounded to three significant figures. 

While the site-specific review option does not require the costs associated with GEIS 

development and rulemaking, site-specific review costs are significantly higher than the costs of 

the GEIS development and rulemaking. Also, the GEIS-only and policy-statement options do 

not require rulemaking, but they result in higher overall costs than the site-specific review option 

because of their respective up-front costs. 

In addition to quantified financial differences between the proposed action and NRC’s options in 

case of no action, unquantified (qualified) differences also exist. Table 7-6 contains a summary 

of unquantified costs and benefits of the approaches. First, all of the NRC’s options in case of 

no action create schedule uncertainties that result from site-specific litigation of generic 

continued storage issues. While costs that result from these uncertainties may be large, they 

are difficult to quantify because they vary significantly, and they are case- and fact-dependent. 

Perceptions vary among stakeholders regarding whether reviewing the environmental impacts 

of continued storage in site-specific licensing actions or being able to litigate site-specific issues 

without a waiver purVXDQWWR&)5is classified as a cost or a benefit. 

As noted in the introduction to this chapter, the proposed action and each of NRC’s potential 

options in case of no action provides a means of addressing the environmental impacts of 

continued storage. The proposed action and NRC’s options in case of no action do not alter the 

NRC’s assessment of environmental impacts from continued storage presented in Chapters 4, 

DQGVRWKHHQYLURQPHQWDOLPSDFWVLGHQWLILHGLQWKRVHFKDSWHUVDUHDSSOLFDEOHUHJDUGOess of 

which approach NRC chooses to pursue. 
Cost-Benefit Analysis 

185(*௅ 7-16 September 2014 

Table 7-6. Summary of Unquantified Costs and Benefits of the Proposed Action and NRC’s 

Potential Options in Case of No Action 

Proposed Action 

Benefits Costs 

x Generically resolves a generic issue; avoids 

unnecessary, repetitive reviews 

x Removes potential for lengthy, site-specific 

litigation and resulting delays, except in cases 

with special circumstances 

x Consistent with CEQ guidance on efficiency 

and timeliness, as well as with NRC’s longstanding preference for resolving generic 

issues generically 

x Avoids potential additional costs from small 

modular reactor applications 

x Public-perception cost from precluding continued storage 

from site-specific review(a)

x Public-perception cost from being unable to challenge 

NRC findings without a waiver petition(a)

Site-Specific Review Option 

Benefits Costs 

x Public-perception benefit from site-specific 

reviews(a)

x Public-perception benefit from the ability to 

challenge NRC findings without a waiver 

petition(a)

x Potential for additional delays due to site-specific litigation, 

which may incur substantial additional costs 

x Repetitive consideration of a generic issue 

x Not consistent with CEQ guidance on efficiency and 

timeliness or with NRC’s long-standing preference for 

resolving generic issues generically 

x Potential additional costs from small modular reactor 

applications 

GEIS-Only Option 

Benefits Costs 

x Public-perception benefit from site-specific 

reviews(a)

x Public-perception benefit from the ability to 

challenge NRC findings without a waiver 

petition(a)

x Consistent with CEQ guidance on efficiency 

and timeliness 

x Potential for additional delays due to site-specific litigation, 

which may incur substantial additional costs 

x Repetitive consideration of a generic issue 

x Potential additional costs from small modular reactor 

applications 

Policy-Statement Option 

Benefits Costs 

x Public-perception benefit from site-specific 

reviews(a)

x Public-perception benefit from the ability to 

challenge NRC findings without a waiver 

petition(a)

x Consistent with CEQ guidance on efficiency 

and timeliness 

x Potential for additional delays due to site-specific litigation, 

which may incur substantial additional costs 

x Repetitive consideration of a generic issue 

x Potential additional costs from small modular reactor 

applications 

(a) The NRC recognizes that perceptions vary among stakeholders regarding whether reviewing environmental impacts of 

continued storage in site-specific licensing actions or being able to challenge the consideration of these impacts without 

a waiver is classified as a cost or a benefit. The NRC includes perceptual issues as costs and benefits in this table 

because there is a record of public interest and concern in scoping and in comments on the draft GEIS regarding how 

site-specific reviews are (or are not) addressed as part of this rulemaking (see Response D. and responses in 

Section ' of Appendix D for additional information). 
Cost-Benefit Analysis 

September 2014 7-17 185(*௅

7.7 Final Analysis and Final Recommendation 

TKHSURSRVHGDFWLRQDGRSWLRQRIDUHYLVLRQWR&)5WKDWFRGLILHVWKHFRQFOXVLRQVLQWKLV

*(,6KDVQRVLJQLILFDQWHQYLURQPHQWDOLPSDFWVDVDGGUHVVHGLQ6HFWLRQ In addition, the 

proposed action requires only minimal commitments of resources, and only insofar as the NRC 

consumed materials—like paper—to develop and publish the draft and final GEIS and proposed 

and final Rule, and to facilitate public involvement and comment at various stages of the project. 

Finally, the proposed action is an administrative approach to considering the environmental 

impacts of continued storage in the NRC’s environmental documents, and therefore does not 

affect the balance between short-term uses of the environment and the maintenance and 

enhancement of long-term productivity. These findings are consistent with the categorical 

H[FOXVLRQFRQWDLQHGLQ&)5FL

The NRC recommendation is to select the proposed action—adopting a revision to 

10 CFR WKDWFRGLILHVWKHLPSDFWGHWHUPLQDWLRQVIURPWKH*(,6—as the preferred 

alternative. In making its recommendation, the NRC has determined that the proposed action is 

superior to the NRC’s options in the case of no action in terms of both costs and benefits. The 

NRC recommendation is based on (1) the NRC’s analysis of the cost-benefit balance of the 

proposed action and its options in the case of no action as presented in this chapter; (2) the 

NRC’s consideration of public-scoping and draft-stage comments in the development of the 

GEIS;  the lack of environmental impacts associated with either the proposed action or the 

15&¶VRSWLRQVLQWKHFDVHRIQRDFWLRQDVDGGUHVVHGLQ6HFWLRQDQGWKH NRC's 

determination that the environmental impacts of continued storage analyzed elsewhere in this 

GEIS are unaffected by the NRC’s choice of a particular administrative approach for considering 

the environmental impacts of continued storage in NRC licensing processes. 

7.8 References 

10 CFR Part 2. Code of Federal Regulations, Title 10, Energy, Part 2, “Agency Rules of 

Practice and Procedure.” Washington, D.C. 

&)53DUWCode of Federal Regulations, Title 10, Energy3DUW3'RPHVWLF/LFHQVLQJRI

Production and Utilization Facilities.” Washington, D.C. 

&)53DUWCode of Federal Regulations, Title 10, Energy3DUW3(QYLURQPHQWDO

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

Washington, D.C. 

&)53DUWCode of Federal Regulations, Title 10, Energy3DUW3/LFHQVHV

Certifications, and Approvals for Nuclear Power Plants.” Washington, D.C. 
Cost-Benefit Analysis 

185(*௅ 7- September 2014 

&)53DUWCode of Federal Regulations. Title 10. Energy, 3DUW3Requirements For 

Renewal Of Operating Licenses For Nuclear Power Plants.” Washington, D.C.

10 CFR Part 72. Code of Federal Regulations, Title 10, Energy, Part 72, “Licensing 

Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive 

Waste, and Reactor-Related Greater than Class C Waste.” Washington, D.C. 

)5-XO\3Restructuring of Facility License Application Review and Hearing 

Process.” Federal Register, Atomic Energy Commission, Washington, D.C. 

)50DUFK3)LQDO*XLGDQFHRQ,PSURYLQJWKH3URFHVVIRU3UHSDULQJ

Efficient and Timely Environmental Reviews Under the National Environmental Policy Act.” 

Federal Register, Council on Environmental Quality, Washington, D.C. 

Atomic EnerJ\$FWRIDVDPHQGHG42 USC 2011 et seq. 

BLS (U.S. Bureau of Labor Statistics). 2014. “CPI Detailed Report—Data fRU0DUFK” 

Washington, D.C. $YDLODEOHDWKWWSZZZEOVJRYFSLFSLGSGI. 

ELEA (Eddy-/HD(QHUJ\$OOLDQFH/HWWHUIURP-00DGGR[WR&+DQH\, dated 

)HEUXDU\UHJDUGLQJ31RWLFHRI,QWHQWWR6XEPLWD/LFHQVH$SSOLFDWLRQIRU&RQVROLGDWH

8VHG1XFOHDU)XHO)DFLOLW\ ́+REEV1HZ0H[LFR$FFHVVLRQ1R 0/$

National Environmental Policy Act of 1969 (NEPA)DVDPHQGHG86& et seq. 

NRC (U.S. Nuclear Regulatory Commission). 2004. Regulatory Analysis Guidelines of the 

U.S. Nuclear Regulatory Commission185(*%5–5HYLVLRQ, Washington, D.C. 

$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 2011. Draft Supplemental Environmental Impact 

Statement Related to the Operation of Watts Bar Nuclear Plant, Unit 2. NUREGí, 

Supplement 2, Washington, D.C. Accession Nos. 0/$0/$

NRC (U.S. Nuclear Regulatory Commission). 0HPRUDQGXPIURP&+DQH\WR7KH

&RPPLVVLRQHUVGDWHG2FWREHUUHJDUGLQJ3,PSOHPHQWDWLRQRI&RPPLVVLRQ

0HPRUDQGXPDQG2UGHU&/,–12–16 Regarding Waste Confidence Decision and Rule with 

Enclosure: Licensing Actions Affected by Waste Confidence Remand.” Washington, D.C. 

Accession No. 0/$

NRC (U.S. Nuclear Regulatory Commission). DMemorandum and Order in the Matter of 

Calvert Cliffs 3 Nuclear Project, LLC and Unistar Nuclear Operating Services, LLC. CLI––04. 

5RFNYLOOH0DU\ODQG. Accession No. 0/0A117. 
Cost-Benefit Analysis 

September 2014 7-19 185(*௅

NRC (U.S. Nuclear Regulatory Commission). E3$GYDQFHG5HDFWRUV ́Washington, D.C. 

Available at KWWSZZZQUFJRYUHDFWRUVDGYDQFHGKWPO. 

NRC (U.S. Nuclear Regulatory Commission). F37HQQHVVHH9DOOH\$XWKRULW\79$&OLQFK

River Site.” Washington, D.C. Available at KWWSZZZQUFJRYUHDFWRUVDGYDQFHGFOLQFKriver.html. 

NRC (U.S. Nuclear Regulatory Commission). G36WDWXVRI/LFHQVH5HQHZDO$SSOLFDWLRQV

and Industry Activities.” Washington, D.C. Available at 

KWWSZZZQUFJRYUHDFWRUVRSHUDWLQJOLFHQVLQJUHQHZDODSSOLFDWLRQVKWPO. 

NRC (U.S. Nuclear Regulatory Commission). e. 2013–2014 Information Digest. NUREG–

 9ROXPH:DVKLQJWRQ'&$FFHVVLRQ1R0/$

20%2IILFHRI0DQDJHPHQWDQG%XGJHWCircular A–4: Regulatory Analysis. 

15&:DVKLQJWRQ'&$FFHVVLRQ1R0/$

PFS (3ULYDWH)XHO6WRUDJH/HWWHUIURP503DOPEHUg to NRC, dated December 20, 

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La &URVVH:LVFRQVLQ$FFHVVLRQ1R0/$

Sciacca, F. 1992. Generic Cost Estimates: Abstracts from Generic Studies for Use in 

Preparing Regulatory Impact Analyses185(*&5í4627, Revision 2, Science and 

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8.0 Summary of Environmental Impacts 

of Continued Storage 

The environmental impact determinations in this generic environmental impact statement 

(GEIS) will be incorporated in the environmental reviews performed by the U.S. Nuclear 

Regulatory Commission (NRC) for future license applications, as appropriate. Doing so will 

provide the decisionmaker with a complete picture of the environmental impacts of a proposed 

licensing action. The analysis in this chapter, therefore, addresses requirements of the National 

Environmental Policy Act of 1969, as amended (NEPA) for environmental reviews of future 

licensing actions, with respect to spent nuclear fuel (spent fuel) storage after a reactor’s 

licensed life for operation (continued storage): (1) environmental effects of continued storage, 

including those that are adverse and unavoidable; (2) irreversible and irretrievable commitments 

of resources associated with continued storage; and 3) the relationship between local uses of 

the environment and long-term productivity with respect to continued storage.1 

The NRC’s regulations under Title 10 of the Code of Federal Regulations (CFR) 3DUW

implement NEPA requirements. Section 102(2)(C) of NEPA requires that environmental impact 

statements (EISs)—including those prepared to support NRC licensing actions—must contain 

the following information: 

x any adverse environmental effects that cannot be avoided, should the licensing action be 

implemented, 

x any irreversible and irretrievable commitments of resources that would be involved in the 

licensing action should it be implemented, and 

x the relationship between local short-term uses of the environment and the maintenance and 

enhancement of long-term productivity. 

As discussed in Chapter 1, and as applied throughout this GEIS, significance categories for 

potential environmental impacts are characterized as follows: 

SMALL—The environmental effects are not detectable or are so minor that they 

will neither destabilize nor noticeably alter any important attribute of the resource. 

MODERATE—The environmental effects are sufficient to alter noticeably, but not 

to destabilize, important attributes of the resource. 

 

1 As explained in Chapter 1, the environmental impact determinations summarized in this chapter provide 

the regulatory basis for the proposed action: adopting a UHYLVLRQWR&)53DUWWR codify the 

determinations of the GEIS. This rulemaking is not a licensing action and does not authorize continued 

storage or the creation of spent fuel. The environmental impacts of the rulemaking are addressed in 

Chapter 1 and &KDSWHU
Summary of Environmental Impacts of Continued Storage 

185(*௅ 8-2 September 2014 

LARGE—The environmental effects are clearly noticeable and are sufficient to 

destabilize important attributes of the resource. 

For some resource areas, the impact determination language is specific to the authorizing 

regulation, executive order, or guidance. 

8.1 Summarized Environmental Impacts of Continued 

Storage 

The tables in this section summarize the environmental impacts from continued storage 

considered elsewhere in this GEIS. The environmental impacts related to at-reactor continued 

storage are described in Chapter 4 and are summarized by timeframe in Table 8-1. Impacts 

associated with away-from-reactor continued storage DUHGHVFULEHGLQ&KDSWHU and are 

summarized by timeframe in Table 8-2. Cumulative impacts associated with continued storage 

when considered along with the impacts of other past, present, and reasonably foreseeable 

future actions are described in Chapter 6 and summarized with the incremental impacts from 

&KDSWHUVDQGLQTable 8-3. 

Table 8-1. Summary of Environmental Impacts of Continued At-Reactor Storage 

Resource Area Short-Term Storage Long-Term Storage Indefinite Storage 

Land Use SMALL SMALL SMALL 

Socioeconomics SMALL SMALL SMALL 

Environmental Justice Disproportionately high and adverse impacts are not expected. 

Air Quality SMALL SMALL SMALL 

Climate Change SMALL SMALL SMALL 

Geology and Soils SMALL SMALL SMALL 

Surface-Water Quality and Use SMALL SMALL SMALL 

Groundwater Quality and Use SMALL SMALL SMALL 

Terrestrial Resources SMALL SMALL SMALL 

Aquatic Ecology SMALL SMALL SMALL 

Special Status Species and 

Habitat 

Impacts for Federally listed threatened and endangered species and 

Essential Fish Habitat would be determined as part of the consultations 

for the Endangered Species Act and the Magnuson–Stevens Fishery 

Conservation and Management Act.

Historic and Cultural Resources SMALL SMALL to LARGE SMALL to LARGE 

Noise SMALL SMALL SMALL 

Aesthetics SMALL SMALL SMALL 

Waste Management 

 LLW SMALL SMALL SMALL 

 Mixed Waste SMALL SMALL SMALL 

 Nonradioactive Waste SMALL SMALL SMALL to MODERATE 
Summary of Environmental Impacts of Continued Storage 

September 2014 8-3 185(*௅

Table 8-1. Summary of Environmental Impacts of Continued At-Reactor Storage (cont’d) 

Resource Area Short-Term Storage Long-Term Storage Indefinite Storage 

Transportation SMALL SMALL SMALL 

Public and Occupational Health SMALL SMALL SMALL 

Accidents SMALL SMALL SMALL 

Sabotage or Terrorism SMALL SMALL SMALL 

Table 8-2. Summary of Environmental Impacts of Continued Storage at an Away-from-Reactor 

Independent Spent Fuel Storage Installation 

Resource Area Short-Term Storage Long-Term Storage Indefinite Storage 

Land Use SMALL SMALL SMALL 

Socioeconomics SMALL (adverse) to 

LARGE (beneficial) 

SMALL (adverse) to 

LARGE (beneficial) 

SMALL (adverse) to 

LARGE (beneficial) 

Environmental Justice Disproportionately high and adverse impacts are not expected. 

Air Quality SMALL to MODERATE SMALL SMALL 

Climate Change SMALL SMALL SMALL 

Geology and Soils SMALL SMALL SMALL 

Surface-Water Quality 

and Use 

SMALL SMALL SMALL 

Groundwater Quality 

and Use 

SMALL SMALL SMALL 

Terrestrial Resources SMALL to MODERATE SMALL SMALL 

Aquatic Ecology SMALL SMALL SMALL 

Special Status Species 

and Habitat 

Impacts for Federally listed threatened and endangered species and 

Essential Fish Habitat would be determined as part of the consultations for 

the Endangered Species Act and the Magnuson–Stevens Fishery 

Conservation and Management Act. 

Historic and Cultural 

Resources 

SMALL to LARGE SMALL to LARGE SMALL to LARGE 

Noise SMALL SMALL SMALL 

Aesthetics SMALL to MODERATE SMALL to MODERATE SMALL to MODERATE 

Waste Management 

 LLW SMALL SMALL SMALL 

 Mixed Waste SMALL SMALL SMALL

 Nonradioactive Waste SMALL SMALL SMALL to MODERATE

Transportation SMALL to MODERATE SMALL to MODERATE SMALL to MODERATE 

Public and 

Occupational Health 

SMALL SMALL SMALL 

Accidents SMALL SMALL SMALL 

Sabotage or Terrorism SMALL SMALL SMALL 
Summary of Environmental Impacts of Continued Storage 

185(*௅ 8-4 September 2014 

Table 8-3. Summary of the Cumulative Impacts from Continued Storage When Added to Other 

Federal and Non-Federal Activities 

Resource Area 

Incremental Impact 

from At-Reactor 

Storage 

Incremental Impact 

from Away-fromReactor Storage 

Cumulative Impact 

from Continued 

Storage and other 

Federal and NonFederal Activities 

Land Use SMALL SMALL SMALL to MODERATE 

Socioeconomics SMALL SMALL (adverse) to 

LARGE (beneficial) 

SMALL to LARGE 

Environmental Justice Disproportionately high and adverse impacts are not expected. 

Air Quality SMALL SMALL to MODERATE SMALL to MODERATE 

Climate Change SMALL SMALL MODERATE 

Geology and Soils SMALL SMALL SMALL to MODERATE 

Surface-Water Quality 

and Use 

SMALL SMALL SMALL to LARGE 

Groundwater Quality 

and Use 

SMALL SMALL SMALL to LARGE 

Terrestrial Resources(a) SMALL SMALL to MODERATE SMALL to MODERATE 

Aquatic Ecology(a) SMALL SMALL SMALL to LARGE 

Historic and Cultural 

Resources 

SMALL to LARGE SMALL to LARGE SMALL to LARGE 

Noise SMALL SMALL SMALL to MODERATE 

Aesthetics SMALL SMALL to MODERATE SMALL to MODERATE 

Waste Management SMALL to MODERATE SMALL to MODERATE SMALL to LARGE 

Transportation SMALL SMALL to MODERATE SMALL to MODERATE 

Public and Occupational 

Health 

SMALL SMALL SMALL 

Accidents SMALL SMALL SMALL 

(a) Cumulative impacts on Federally listed threatened and endangered species and Essential Fish Habitat would be 

determined as part of consultations for the Endangered Species Act and the Magnuson–Stevens Fishery 

Conservation and Management Act. 

8.2 Unavoidable Adverse Environmental Impacts of 

Continued Storage 

Section 102(2)(C)(ii) of NEPA requires that EISs—including those prepared to support NRC 

licensing actions—must contain information about any adverse environmental effects that 

cannot be avoided if an action is implemented. 

For the purposes of the analysis in this chapter, unavoidable adverse environmental impacts are 

those potential impacts of continued storage that cannot be avoided due to constraints inherent 

in using at-reactor and away-from-reactor spent fuel storage facilities for continued storage. 

The unavoidable adverse environmental impacts associated with continued storage would 
Summary of Environmental Impacts of Continued Storage 

September 2014 8- 185(*௅

include impacts of (1) short-term storage in a spent fuel pool, as well as (2) short-term storage, 

(3) long-term storage, and (4) indefinite dry storage in at-reactor and away-from-reactor 

independent spent fuel storage installations (ISFSIs). The short-term storage timeframe 

assumes that a repository becomes available by 60 years after the end of the reactor’s licensed 

life for operation. The long-term storage timeframe assumes that a repository becomes 

available by 160 years after the end of the reactor’s licensed life for operation. The indefinite 

storage timeframe assumes that a repository does not become available and that the spent fuel 

is stored in an at-reactor or away-from-reactor ISFSI indefinitely. As discussed in Chapter 1 and 

Appendix B of this GEIS, the NRC believes that the most likely outcome is that a repository will 

become available by the end of the short-term timeframe, or within 60 years after the end of the 

reactor’s licensed life for operation. 

The short-term storage timeframe involves continued operation of at-reactor spent fuel pool 

storage and dry storage at an at-reactor or away-from-reactor ISFSI until a repository is 

available. The long-term storage timeframe involves construction and operation of a dry 

transfer system (DTS), continued operation of an at-reactor or away-from-reactor ISFSI, and 

replacement of these facilities within the 100-year period until a repository is available. 

Indefinite storage continues at an at-reactor or away-from-reactor ISFSI in perpetuity with 

continued aging management activities and the assumed replacement of the ISFSI and DTS 

every 100 years. 

The potential impacts from the activities occurring within the three continued-storage timeframes 

on each resource area are described in Chapter 4 for at-UHDFWRUVWRUDJHDQGLQ&KDSWHUIRU

away-from-reactor storage. Table 8-1 and Table 8-2 summarize the adverse environmental 

impacts for each resource area. For at-reactor storage, the unavoidable adverse environmental 

impacts for each resource area across all timeframes are SMALL with the exception of wastemanagement impacts in the indefinite storage timeframe, which are SMALL to MODERATE, 

and historic and cultural resource impacts in the long-term and indefinite storage timeframes, 

which are SMALL to LARGE. These elevated impact conclusions are influenced, in part, by the 

uncertainties regarding the specific circumstances of continued storage over lengthy 

timeframes, including site-specific characteristics that could affect the intensity of potential 

environmental impacts, and the resulting analysis assumptions that have been made by the 

NRC as documented in detail in Chapter 4. The potentially MODERATE waste-management 

impacts are associated with the volume of nonhazardous solid waste generated by assumed 

facility-replacement activities for only the indefinite timeframe. The NRC considered a range of 

potential impacts on historic and cultural resources in the GEIS to account for varying scenarios. 

As discussed in Section 3.11, less-developed or disturbed portions of a power plant site, 

including areas that were used to support construction of the at-reactor ISFSI, could still contain 

unknown historic and cultural resources. However, the NRC recognizes that there is uncertainty 

associated with the degree of prior disturbances and what resources, if any, are present in 

areas where future ground-disturbing activities (e.g., initial and replacement DTS and 
Summary of Environmental Impacts of Continued Storage 

185(*௅ 8-6 September 2014 

replacement ISFSI) could occur. The NRC cannot eliminate the possibility that historic and 

cultural resources would be affected by construction activities during the long-term and 

indefinite timeframes because the initial ISFSI could be located within a less-disturbed area with 

historic and cultural resources in close proximity. Further, resources may be present that would 

not have been considered significant at the time the initial or replacement facilities were 

constructed, but could become significant in the future. The analysis concluded with an impact 

range from SMALL to LARGE. Therefore, generic summarization as a range is appropriate. 

For some resource areas the impact determination language is specific to the authorizing 

regulation, executive order, or guidance. For special status species, impacts would be 

determined as part of consultations pursuant to Endangered Species Act 6HFWLRQand the 

Magnuson–Stevens Fishery Conservation and Management Act, as amended. Continued atreactor storage is not expected to cause disproportionately high and adverse human health and 

environmental effects on minority and low-income populations. In addition, as indicated in the 

Commission’s policy statement, environmental justice impacts would be considered during sitespecific environmental reviews for specific licensing actions. 

For away-from-reactor storage, the unavoidable adverse environmental impacts over all 

timeframes would be SMALL for most resource areas, and SMALL to MODERATE for air 

quality, terrestrial ecology, aesthetics, waste management, and transportation. Socioeconomics 

impacts would range from SMALL (adverse) to LARGE (beneficial), and historic and cultural 

resource impacts could be SMALL to LARGE. The potential MODERATE impacts on air, 

terrestrial wildlife, and transportation are based on potential construction-related fugitive-dust 

emissions, terrestrial wildlife direct and indirect mortalities, terrestrial habitat loss, and temporary 

construction traffic impacts. The potential MODERATE impacts on aesthetics and waste 

management are based on noticeable changes to the viewshed from constructing a new ISFSI 

and the volume of nonhazardous solid waste generated by assumed ISFSI and DTS 

replacement activities for only the indefinite timeframe. Potential LARGE (beneficial) impacts on 

socioeconomics would be due to local economic tax revenue increases from an away-fromreactor ISFSI. The MODERATE or LARGE impacts on historic and cultural resources could 

result if historic and cultural resources are present at a site and, because they cannot be 

avoided, are impacted by ground-disturbing activities during a particular timeframe. The NRC 

believes that it is reasonable to assume that the replacement ISFSI and the initial and 

replacement DTS would be constructed near the existing ISFSI because the licensee would 

have already characterized and selected the existing ISFSI site to meet NRC siting, safety, and 

security requirements. Further, the NRC believes that it is reasonable to assume that licensees 

would generally avoid siting and operating an ISFSI away from the existing licensed area or 

outside previously characterized areas. The NRC recognizes that there is uncertainty 

associated with the degree of prior disturbance and what resources, if any, are present in areas 

where future ground-disturbing activities could occur. The NRC cannot eliminate the possibility 

that historic and cultural resources would be affected by construction activities because the 
Summary of Environmental Impacts of Continued Storage 

September 2014 8- 185(*௅

initial ISFSI could be located within a less-disturbed area with historic and cultural resources in 

close proximity. Further, resources may be present after initial construction of the away-fromreactor ISFSI that would not have been considered significant at the time the initial or 

replacement facilities were constructed, but could become significant in the future. Specifically, 

these potential historic and cultural resource impacts vary depending on where the facilities are 

sited, what resources are present, the extent of proposed land disturbance, whether the area 

has been previously surveyed, and whether the licensee has management plans and 

procedures that are protective of historic and cultural resources. 

Impacts on Federally listed species, designated critical habitat, and essential fish habitat would 

be based on site-specific conditions and determined as part of consultations pursuant to 

Endangered Species Act 6HFWLRQDQGWKHMagnuson–Stevens Fishery Conservation and 

Management Act, as amended. Continued storage at an away-from-reactor ISFSI is not 

expected to cause disproportionately high and adverse human health and environmental effects 

on minority and low-income populations. In addition, as indicated in the Commission’s policy 

statement, environmental justice impacts would be considered during site-specific 

environmental reviews for specific licensing actions. 

8.3 Irreversible and Irretrievable Commitments of 

Resources Associated with Continued Storage 

Section 102(2)(C)(v) of NEPA requires that EISs—including those prepared to support NRC 

licensing actions—must contain information about irreversible and irretrievable commitments of 

resources that would occur if an action is implemented. 7KH15&JXLGDQFHLQ185(*í

Environmental Review Guidance for Licensing Actions Associated with NMSS Programs

(NRC 2003), defines an irreversible commitment as the commitment of environmental resources 

that cannot be restored. In addition, an irretrievable commitment refers to the commitment of 

material resources that once used cannot be recycled or restored for other uses by practical 

means. For purposes of application to environmental reviews associated with future licensing 

actions, this section addresses the irreversible and irretrievable commitments of resources that 

would occur as a result of continued storage. 

Impacts on land use, terrestrial ecology, aquatic ecology, aesthetics, historic and cultural 

resources, and waste management would result in irreversible commitments; and replacement 

of ISFSI components and transportation would result in irretrievable commitments. As finite 

resources, the loss of historic and cultural resources would constitute irreversible impacts. For 

the indefinite storage timeframe, land and visual resources allocated for spent fuel storage 

would be committed in perpetuity because continued operations would preempt other productive 

land uses, including use as terrestrial ecological habitat, and permanently affect the viewshed. 

The area of land that would be occupied by at-reactor ISFSI is assumed to be 2.4 ha (6 ac) for 

both ISFSI and DTS facilities (Section 2.1.2.2) or 330 ha (820 ac) for an away-from-reactor 
Summary of Environmental Impacts of Continued Storage 

185(*௅ 8-8 September 2014 

ISFSI (Section 2.1.3). Waste-management activities involving waste treatment, storage, and 

disposal would result in irreversible commitment of capacity for waste disposal. The largest 

volume of waste requiring disposal during continued storage would be nonradiological 

demolition waste (primarily concrete) from replacement of an away-from-reactor ISFSI 

(308,000 m3 [403,000 yd3@DVGHVFULEHGLQ6HFWLRQ ISFSI replacement activities would 

also generate canister waste that would have to be disposed at an approved low-level waste 

facility (there would be approximately 4,000 canisters at an away-from-reactor ISFSI, as 

descrLEHGLQ6HFWLRQ). Transportation activities would involve irretrievable commitment of 

resources including vehicle fuel for commuting workers and shipping activities. The 

commitment of resources for construction of storage facilities and transportation is not expected 

to have a significant impact relative to the availability of these resources. 

8.4 Relationship Between Short-Term Uses of the 

Environment for Continued Storage and the Maintenance 

and Enhancement of Long-Term Productivity 

Section 102(2)(C)(iv) of NEPA requires that EISs—including EISs prepared to support NRC 

licensing actions—must contain information about the relationship between local short-term 

uses of the environment and the maintenance and enhancement of long-term productivity. For 

the purpose of this section, the NRC considers the relationship between local short-term uses of 

the environment and the maintenance and enhancement of long-term productivity that occurs 

from continued storage as may be authorized by future licensing actions. 

Consistent with the NRC guidance in NUREG–15&, the short-term use period 

evaluated in this section is the period of time encompassing all continued storage activities 

defined in Chapter 1 (i.e., the period of analysis of environmental impacts evaluated by the three 

WLPHIUDPHVLQ&KDSWHUVDQGRIWKLV*(,6,QDGGLWLRQWKHORQJ-term productivity period 

evaluated in this section is the time period beyond continued storage (i.e., based on the NRC 

guidance in NUREGí, the period beyond the future licensing action under review). With 

respect to the indefinite storage timeframe, however, there is no time period beyond continued 

storage. As discussed in Chapter 1 and Appendix B of this GEIS, the NRC believes that the 

most likely outcome is that a repository will become available to accept the spent fuel generated 

by a reactor by the end of the short-term timeframe, or 60 years after the end of the reactor’s 

licensed life for operation. Because the short-term timeframe is the most likely timeframe, the 

long-term productivity period considered in this chapter for the indefinite storage timeframe is 

assumed to begin at the end of the long-term storage timeframe evaluated in Chapters 4 and 

The local short-term use of the human environment is summarized in terms of the unavoidable 

adverse environmental impacts and irreversible and irretrievable commitments of resources 

summarized in Sections 8.2 and 8.3 and Table 8-1 and Table 8-2. With the exception of the 
Summary of Environmental Impacts of Continued Storage 

September 2014 8-9 185(*௅

consumption of depletable resources resulting from the evaluated construction and operations 

activities, these uses may be classified as short-term. 

The maximum long-term impact on productivity would result when an at-reactor or away-fromreactor ISFSI is not immediately dismantled at the end of storage operations, or, as with the 

indefinite storage timeframe, it remains in operation indefinitely. Consequently, the land 

occupied by an ISFSI would not be available for any other uses. Most long-term impacts 

resulting from land-use preemption by ISFSI structures can be eliminated by removing these 

structures or by converting them to productive uses. Once continued storage ends, the facilities 

and associated land areas would be decommissioned according to NRC regulations. Once 

decommissioning is complete, and the NRC license is terminated, the site would be available for 

other uses. Other potential long-term impacts on productivity include the commitment of land 

and consumption of disposal capacity necessary to meet waste disposal needs. This 

commitment of land for disposal would remove land from productive use. In addition, because 

loss of historic and cultural resources would constitute irreversible impacts, any loss of historic 

and cultural resources during continued storage would persist as long-term impacts. A small 

contribution to greenhouse gas emissions would add to the atmospheric burden of emissions 

that could contribute to potential long-term impacts. 

8.5 References 

&)53DUWCode of Federal Regulations, Title 10, Energy, 3DUW3(QYLURQPHQWDO

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

Washington, D.C. 

)5)HEUXDU\3Executive Order 12898: Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income Populations.” Federal Register, 

Executive Office of the President, Washington, D.C. 

(QGDQJHUHG6SHFLHV$FWRI (ESA)86& et seq. 

Magnuson–Stevens Fishery Conservation and Management Act RI, as amended. 16 USC 

1801 et seq. 

National Environmental Policy Act of 1969 (NEPA), as amended. USC 4321 et seq. 

NRC (U.S. Nuclear Regulatory Commission). 2003. Environmental Review Guidance for 

Licensing Actions Associated with NMSS Programs. NUREGí:DVKLQJWRQ'&

Accession No. 0/. 

September 2014 9-1 185(*௅

9.0 List of Preparers 

The overall responsibility for the preparation of this Generic Environmental Impact Statement

(GEIS) was assigned to the Office of Nuclear Material Safety and Safeguards (NMSS), 

U.S. Nuclear Regulatory Commission (NRC). NMSS had assistance from other NRC 

organizations as well as the Pacific Northwest National Laboratory (PNNL) and the Center for 

Nuclear Waste Regulatory Analyses (CNWRA). Tables 9-1 through 9-3 provide a listing of the 

NRC, CNWRA, and PNNL staff involved, their experience, and their role in preparing this GEIS. 
185(*௅ 9-2 September 2014 

List of Preparers Table 9-1. List of Preparers—NRC Name NRC Office Experience Function or Expertise David Brown NMSS B.S., Physics, Muhlenberg College, 1990 M.S., Environmental Health Physics, Clemson University, 1993 Years of Relevant Experience: 21 Air quality, climate change, surface water, groundwater, transportation, public and occupational health, 

accidents and safeguards 

Ralph Cady RES %6*HRORJ\8QLYHUVLW\RI&RQQHFWLFXW

0$*HRORJ\8QLYHUVLW\RI&RQQHFWLFXW

Ph.D., Hydrology, University of Arizona, 1989 Years of Relevant Experience: 2

Spent fuel pool leaks 

Keith Compton RES %63K\VLFV5KRGHV&ROOHJH

Ph.D., Environmental Engineering and Science, Clemson University, 2001 Years of relevant experience: 23 

Spent fuel pool fires 

Jennifer Davis NMSS B.A, Historic Preservation and Classical Civilization (Archaeology); 

0DU\:DVKLQJWRQ&ROOHJH2 years of fieldwork; 12 years of experience in NEPA compliance, project management, historic and cultural resource impact analysis and regulatory compliance 

Historic and cultural resources, socioeconomics, environmental justice, land use, noise 

Kevin Folk NRR B.A., Geoenvironmental Studies, Shippensburg University, 1989 

06(QYLURQPHQWDO%LRORJ\+RRG&ROOHJH

Years of Relevant Experience: 

Air quality, geology, hydrology, noise 

Michelle Hart NRO B.S., Physics, Muskingum College, 1991 

M.S., Nuclear Engineering, Ohio State University, 1994 Years of Relevant Experience: 18 

Accidents 

Donald Helton RES B.S., Nuclear Engineering, North Carolina State University, 1999 

M.S., Nuclear Engineering, Texas A&M University, 2002 Years of Relevant Experience: 11 

Spent fuel pool fires 

Merri Horn NMSS B.S., Physics, Eastern Illinois University, 1980 

M.S., Environmental Systems Engineering, Clemson 8QLYHUVLW\Years of Relevant Experience: 30 

Rule, repository feasibility, and continued safe storage feasibility 

Andrew Kugler NRO %60HFKDQLFDO(QJLQHHULQJ&RRSHU8QLRQ

M.S., Technical Management, Johns Hopkins, 1998 Years of Relevant Experience: 

Away-from-reactor impacts, GEIS assumptions 

Stacey Imboden NRO B.S., Pennsylvania State University, 1999 

M.S., Clemson University, 2001Years of Relevant Experience: 13 

Climate change 
September 2014 9-3 185(*௅

List of Preparers 

Table 9-1. List of Preparers—NRC (cont’d)

Name NRC Office Experience Function or Expertise

Emily Larson NRR B.A., Anthropology (major, emphasis archaeology) and History (minor), 

University of Minnesota, 2004; 0$$UFKDHRORJ\%DQJRU8QLYHUVLW\

Years of Relevant Experience: 1 year of fieldwork; 2\HDUVRI

experience in NEPA compliance; historic and cultural resource impact analysis and regulatory compliance 

Historic and cultural resources 

Sarah Lopas NMSS B.A., Molecular Biology, Lehigh University, 2001 

03$(QYLURQPHQWDO6FLHQFHDQG3ROLF\&ROXPELD8QLYHUVLW\Years of Relevant Experience: 12 

Executive summary, outreach 

Timothy McCartin NMSS %63K\VLFV;DYLHU8QLYHUVLW\

063K\VLFV:D\QH6WDWH8QLYHUVLW\

Over 31 years’ experience evaluating safety and regulatory compliance of geological disposal facilities 

Public and occupational health, accidents and safeguards, repository feasibility and continued safe storage feasibility, Rule 

Paul Michalak NMSS B.S., (GXFDWLRQ7HPSOH8QLYHUVLW\

M.S., Hydrology, New Mexico Institute of Mining and Technology, 1989 Years of Relevant Experience: 

Spent fuel pool leaks 

Michelle Moser NRR B.S., Environmental Sciences, Brown University, 2002 

M.S., Biological 6FLHQFHV6WDQIRUG8QLYHUVLW\10 years of experience in ecological research and aquatic ecology, 8 years of experience in cumulative impact assessment and NEPA compliance 

Ecology, cumulative impacts 

Jessie Muir Quintero 

NMSS B.S., Biosystems Engineering, Clemson University, 2000 

M.S., Environmental Engineering and Science, Clemson University, 2002 4 years in environmental compliance and solid waste management,  years in NEPA compliance and project management 

Project manager, executive summary, Chapter 1 

Tom Nicholson RES %6*HRORJLFDO6FLHQFHV3HQQV\OYDQLD6WDWH8QLYHUVLW\

06*HRORJ\6WDQIRUG8QLYHUVLW\Professional Geologist, Indiana Certified Professional Hydrogeologist, AIH Years of Relevant Experience: 39 

Senior technical advisor for radionuclide transport in the environment 
185(*௅ 9-4 September 2014 

List of Preparers Table 9-1. List of Preparers—NRC (cont’d) Name NRC Office Experience Function or Expertise Jeffrey Rikhoff NRR M.R.P., Regional Planning, University of Pennsylvania, 1988 M.S., Economic Development and Appropriate Technology, University of 3HQQV\OYDQLD

B.A., English (Composition), DePauw University, 1980 

Years of Relevant Experience: years of experience in NEPA 

compliance, socioeconomics and environmental justice impact analysis, cultural resource impacts, and comprehensive land-use and 

development planning 

Socioeconomics, environmental justice 

Robert Schaaf NRO B., Mechanical Engineering, Georgia Institute of Technology, 1988 

Years of Relevant Experience: 24 

GEIS Assumptions 

Andrew Stuyvenberg 

NMSS B.S., Biochemistry/Molecular Biology and Political Science, Marquette 

University, 2002 0(0(QYLURQPHQWDO(FRQRPLFVDQG3ROLF\'XNH8QLYHUVLW\J.D., Georgetown University Law Center Years of Relevant Experience: 9 

NEPA alternatives, NEPA process, cost-benefit analysis 

Michael Wentzel NMSS %60LFURELRORJ\8QLYHUVLW\RI7H[DV

Years of Relevant Experience: 

Ecological resources, aesthetics, spent fuel pool leaks and fires 

NRO = Office of New Reactors. NRR = Office of Nuclear Reactor Regulation. 

NSIR = Office of Nuclear Security and Incident Response. 

RES = Office of Nuclear Regulatory Research. 
September 2014 9- 185(*௅

List of Preparers 

Table 9-2. List of Preparers—CNWRA

Name Experience Function or Expertise

Hakan Basagaoglu B.S., Geologic Engineering, Middle East Technical University, Turkey, 1991 

M.S., Geologic Engineering, Middle East Technical University, Turkey, 1993 Ph.D., Civil and Environmental Engineering, University of California Davis, 2000 Years of Relevant Experience: 3 

Groundwater 

Amitava Ghosh %7HFK0LQLQJ(QJLQHHULQJ,QGLDQ,QVWLWXWHRI7HFKQRORJ\

M.S., Mining Engineering, University of Arizona, 1983 Ph.D., Mining Engineering, University of Arizona, 1990 Years of Relevant Experience: 13 

Natural events and accidents 

Amy Hester B.A., Environmental Studies, University of Kansas, 1998 

Years of Relevant Experience: 14 

Terrestrial resources 

Lane Howard B.S., Civil Engineering, Texas A&M University, 1988 

061XFOHDU(QJLQHHULQJ7H[DV$	08QLYHUVLW\Years of Relevant Experience: 23 

Public and occupational health 

Miriam Juckett B.A., Chemistry, University of Texas San Antonio, 2003 

06(QYLURQPHQWDO6FLHQFHV8QLYHUVLW\RI7H[DV6DQ$QWRQLR

Years of Relevant Experience: 11 

Communications, scoping, and outreach 

Patrick LaPlante B.S., Environmental Studies, Western Washington University, 1988 

M.S., Biostatistics and Epidemiology, Georgetown University, 1994 Years of Relevant Experience: 

Transportation 

Todd Mintz B.S., Chemical Engineering, Washington University St. Louis, 1998 

Ph.D., Materials Science and Engineering, University of California Berkeley, 2003 Years of Relevant Experience: 2 

Spent fuel pool fires 

Marla Morales B.A., Geology, Vanderbilt University, 2001 

M.S., GeolRJ\8QLYHUVLW\RI7H[DV6DQ$QWRQLR

Years of Relevant Experience: 13 

Socioeconomics, environmental justice, geology, and soils 

James Myers %6*HRORJ\0LFKLJDQ6WDWH8QLYHUVLW\

M.S., Geophysical Sciences, Georgia Institute of Technology, 1990 Ph.D., Environmental Science and Engineering, Clemson University, 2004 Years of Relevant Experience: 21 

Solid waste management 

Olufemi Osidele B.S&LYLO(QJLQHHULQJ8QLYHUVLW\RI,IH1LJHULD

M.S., Hydrology for Environmental Management, University of London, England, 1992 Ph.D., Environmental Systems Analysis, University of Georgia, 2001 Years of Relevant Experience: 19 

Surface water 
185(*௅ 9- September 2014 

List of Preparers Table 9-2. List of Preparers—CNWRA (cont’d) Name Experience Function or Expertise Roberto Pabalan %6*HRORJ\8QLYHUVLW\RIWKH3KLOLSSLQHV 3K'*HRFKHPLVWU\DQG0LQHUDORJ\3HQQV\OYDQLD6WDWH8QLYHUVLW\ Years of Relevant Experience: 1 Spent fuel pool leaks 

Robert Pauline B.S., Biology, Bates College, 1989 

M.S., Biology, George Mason University, 1999 Years of Relevant Experience: 8 

Scoping 

English Pearcy B.S., Geology, Furman University, 1983 

06*HRORJ\+DUYDUG8QLYHUVLW\Ph.D., Geology, Harvard University, 1989 Years of Relevant Experience: 24 

Aesthetics 

James Prikryl B.S., Geology, University of Texas, 1984 

M.S., Geology, University of Texas, 1989 Years of Relevant Experience: 24 

Land use 

David Turner B.A. in Music/Geology, College of William and Mary, 1981 

06LQ*HRORJ\8QLYHUVLW\RI8WDK

Ph.D. in Geology, University of Utah, 1990 Years of Relevant Experience: 24 

Cumulative impacts 

Bradley Werling %$(QJLQHHULQJ3K\VLFV:HVWPRQW&ROOHJH

B.S., Chemistry, Southwest Texas State University, 1999 M.S., Environmental Science, University of Texas San Antonio, 2000 Years of Relevant Experience: 19 

Noise, air quality, climate change 

Table 9-3. List of Preparers—PNNL

Name Experience Function or Expertise

Eva Hickey B.S., Biology with Health 3K\VLFVRSWLRQ9LUJLQLD3RO\WHFKQLF,QVWLWXWHDQG6WDWH8QLYHUVLW\

M.S., Health Physics, Georgia Institute of Technology, 1980 Years of Relevant Experience: 

Accidents 

Tara O’Neil B.A., Anthropology with an emphasis on Archaeology, Oregon State University, 1992 

MBA, University of Phoenix, 2009 Years of Relevant Experience: 22

Historic and Cultural Resources 

Terri Miley B.S. Mathematics, University of South Carolina, 1982 

060DWKHPDWLFV8QLYHUVLW\RI6RXWK&DUROLQDYears of Relevant Experience: 

Appendix D 
September 2014 10-1 185(*௅

10.0 Index 

A

Accident, xxviii, xlvi, xlvii, xlviii, lviii, lix, lxi, 

lxiv, 2-13, 2-23, 2-39, 3-42, 4-3, 4-18, 4-

66, 4-, 4-, 4-, 4-, 4-, 4-, 4-

, 4-, 4-80, 4-81, 4-82, 4-83, 4-84, 4-

, 4-86, 4-88, 4-89, 4-90, 4-91, 4-92, 4-

, 4-98, 4-104, 4-, 4-109, -19, -, 

-, -, -, -, -, -, -, 

6-, 6-, 6-, 6-, 6-, 6-, 6-, 

6-63, 8-3, 8-4, 9-2, 9-3, 9-, 9-6, 11-1, 11-

, 11-, 11-, 11-18, 11-19, B-4, B-12, 

B-13, B-14, B-16, B-, B-20, B-21, B-26, 

B-30, B-32, B-36, B-, B-39, B-41, D-, 

D-6, D-21, D-22, D-, D-, D-68, D-69, 

D-, D-, D-86, D-94, D-, D-96, D99, D-104, D-109, D-, D-124, D-, 

D-, D-129, D-131, D-132, D-133, D136, D-, D-144, D-, D-, D-148, 

D-149, D-, D-160, D-161, D-, D-

, D-, D-, D-190, D-191, D-209, 

D-212, D-218, D-219, D-220, D-, D264, D-, D-, D-, D-280, D-281, 

D-282, D-283, D-284, D-, D-289, D290, D-291, D-293, D-294, D-, D-296, 

D-, D-298, D-299, D-300, D-308, D310, D-312, D-313, D-314, D-, D-316, 

D-, D-318, D-319, D-320, D-321, D322, D-323, D-324, D-, D-326, D-, 

D-328, D-329, D-330, D-331, D-332, D333, D-334, D-, D-336, D-, D-338, 

D-339, D-340, D-341, D-344, D-, D346, D-, D-348, D-349, D-, D-, 

D-, D-360, D-361, D-366, D-368, D-

, D-386, D-, D-391, D-393, D-396, 

D-, D-398, D-402, D-403, D-404, D410, D-411, D-, D-418, D-419, D-420, 

D-421, D-422, D-423, D-426, D-, D429, D-430, D-433, D-434, D-, D-436, 

D-438, D-439, D-440, D-442, D-443, D444, D-, D-446, D-, D-449, D-, 

D-, D-, D-, D-461, D-, D469, D-484, D-, D-491, D-493, D-, 

D-496, D-498, D-499, D-, D-, D-

, D-, D-, D-, D-, D-, 

D-, D-, D-, D-, D-, D-

, D-, D-, D-, D-, D-, 

D-, D-, D-, D-, D-606, D614, D-616, D-, D-620, D-621, D-626, 

D-, D-632, D-633, E-1, E-4, E-9, F-1, 

F-2, F-3, F-4, F-, F-6, F-, F-8, F-9, F10, F-11, F-12, F-13, F-14, F-, F-16, F-

, F-18, F-19, F-20, F-21, I-2, I-, I-

Aesthetics, xxxiv, xxxv, xliv, xlviii, xlix, lvi, 

lix, lxi, lxii, 3-9, 3-30, 3-34, 4-, 4-, 4-

, 4-98, -13, -14, -43, -44, -, -

, -, 6-43, 6-44, 6-, 6-, 8-2, 8-3, 

8-4, 8-6, 8-, 9-4, 9-6, 11-1, 11-6, D-, D182, D-183, D-, D-268 

Aging management, xlv, lii, lvi, 1-16, 2-29, 

2-31, 4-6, 4-69, -, -9, -10, -14, -18, 

-21, -23, -28, -29, -30, -33, -, 

-42, -43, -44, -, -, 8-, 11-1, 

11-13, B-, B-18, B-19, B-20, B-22, B-

, B-28, B-32, B-42, D-31, D-32, D-132, 

D-, D-, D-181, D-286, D-303, D314, D-390, D-, D-402, D-413, D-, 

D-463, D-464, D-468, D-469, D-, E-, 

I-8 

Air quality, xxxiv, xxxv, xxxvii, xlvii, xlix, l, lix, 

lx, 3-11, 3-13, 3-43, 3-44, 4-3, 4-14, 4-, 

4-16, 4-, 4-18, 4-34, 4-98, -, -13, -

, -16, -, -18, -, -, 6-18, 6-

19, 6-20, 6-, 8-2, 8-3, 8-4, 8-6, 9-2, 9-6, 
Index 

185(*௅ 10-2 September 2014 

11-1, 11-4, 11-9, 11-, D-, D-, D208, D-209, D-210, D-

Alternative, xxiii, xxvi, xxviii, xxix, lvii, lxv, 1-

6, 1-9, 1-10, 1-11, 1-, 2-33, 2-34, 4-, 

4-, -28, -36, 6-22, -1, -4, -6, -

11, -14, -, 9-4, 11-1, 11-6, 11-9, 11-

, B-24, B-30, D-, D-13, D-14, D-, D38, D-41, D-42, D-46, D-48, D-, D-60, 

D-61, D-, D-, D-, D-, D-, D-

, D-80, D-81, D-82, D-83, D-, D-86, 

D-, D-88, D-89, D-90, D-91, D-92, D93, D-94, D-98, D-100, D-104, D-106, D-

, D-109, D-110, D-111, D-112, D-113, 

D-114, D-, D-116, D-, D-118, D119, D-120, D-121, D-122, D-123, D-124, 

D-, D-126, D-128, D-143, D-144, D-

, D-, D-, D-, D-182, D-193, 

D-316, D-, D-322, D-323, D-330, D-

, D-, D-, D-361, D-368, D-420, 

D-, D-462, D-498, D-499, D-, D-

, D-, D-, D-, D-, D-, 

D-, D-, D-, E-, F-16, F-19, 

H-1, H-6 

Aquifer, 3-, 3-18, 4-, 4-26, 6-28, 6-30, 

11-2, 11-11, D-130, D-, D-234, D-240, 

D-, D-, D-, D-, D-481, D482, D-, E-12, E-13, E-14, E-16 

Archaeological resource, 3-30, 11-2 

Attainment, 3-13, 3-14, 4-, 4-16, 4-, -

, -16, -, -18, 11-9 

B

Bare fuel, 2-13, 2-24, 2-30, 4-16, 4-82, -18, 

-21, 6-9, 6-, 6-, 11-2, B-18, D-, 

D-160, D-286 

Biota, 3-22, 3-23, 4-30, 4-31, 4-39, 4-42, -

30, 11-1, 11-3, D-222, D-229, D-, D249, D-300, D-301, D-, D-344, D-, 

D-

Boiling water reactor, 2-3, 2-4, 2-, 2-6, 2-, 

2-8, 2-18, 3-3, 3-36, 4-2, 4-23, 4-, 4-88, 

4-, 6-48, 11-3, B-12, B-14, B-19, B-42, 

D-269, D-, D-314, D-319, D-322, D-

, D-, D-, D-424, D-, D-438, 

D-446, D-448, D-, D-, D-, D-

, D-, D-, D-, D-, D-, 

D-629, D-632, E-1, E-2, E-3, E-19, E-20, 

E-22, E-, F-3, F-, F-18, F-21, F-22, 

G-1, G-3, G-4, G-, G-6, G-, G-9, G-11, 

G-13 

Burnup, xxviii, 2-8, 2-24, 2-28, 2-33, 4-, 4-

96, 11-3, B-9, B-10, B-12, B-, B-16, B19, B-22, B-23, B-33, B-, D-60, D-63, 

D-, D-, D-180, D-269, D-283, D284, D-, D-288, D-, D-322, D-, 

D-334, D-, D-400, D-401, D-403, D412, D-413, D-414, D-, D-424, D-433, 

D-, D-, D-, D-632, F-18, G-10, 

G-11, G-13, G-14, G-, I-1, I-2, I-3, I-4, I-

, I-6, I-, I-8 

C

Cladding, 2-2, 2-, 2-9, 2-11, 2-33, 2-40, 4-

3, 4-63, 4-86, -, 11-3, B-10, B-11, B-12, 

B-14, B-, B-16, B-31, D-132, D-, D-

, D-281, D-282, D-284, D-, D-, 

D-288, D-, D-, D-318, D-322, D333, D-334, D-, D-, D-360, D-, 

D-393, D-, D-399, D-401, D-402, D403, D-404, D-413, D-414, D-418, D-428, 

D-434, D-, D-436, D-, D-440, D-

, D-, D-, D-614, D-628, F-1, F9, F-14, I-2, I-3, I-, I-6 

Clean Air Act, 3-13, 3-14, 3-44, -16, -61, 

6-60, 11-4, 11-9, 11-, D-

Climate change, xxxviii, xlvii, l, lix, lx, 3-, 

3-49, 4-18, 4-, 4-80, 4-81, 4-83, 4-84, 

4-, 4-89, 4-98, 4-103, 4-109, -19, -

, -, 6-8, 6-11, 6-21, 6-31, 6-34, 6-
Index 

September 2014 10-3 185(*௅

, 6-61, 6-62, 6-66, 8-2, 8-3, 8-4, 9-2, 

11-4, B-6, B-, D-, D-211, D-212, D-

, D-, D-, D-, D-611, D-, 

D-616 

Coastal, 3-6, 3-11, 3-, 3-20, 3-23, 3-24, 3-

, 3-29, 3-44, 4-46, 4-, 4-48, 4-, 4-

80, 4-, 4-101, 4-103, -32, -33, -61, 

6-, 6-11, 6-28, 6-31, 11-2, D-94, D-212, 

D-213, D-, D-, D-, D-314, D342, D-611, F-

Consolidated storage, 2-20, 11-, D-303, D406, D-, D-408 

Cooling system, xli, 1-, 2-2, 2-3, 2-4, 2-, 

2-28, 3-1, 3-3, 3-21, 3-22, 3-23, 4-2, 4-22, 

4-29, 4-30, 4-31, 4-32, 4-33, 4-36, 4-, 

4-38, 4-39, 4-40, 4-41, 4-42, 4-44, 4-, 

4-46, 4-, 4-86, 6-9, 6-11, 6-32, 6-, 

11-, 11-16, D-233, D-241, D-249, D-, 

D-, D-330, D-, D-396, D-411, D-

, D-468, D-494, D-

Core damage frequency, 4-, 11-, D-

Costs, xxix, lxiv, lxv, 1-, 2-1, 2-2, 2-12, 2-

, 2-19, 2-21, 2-24, 2-, 2-26, 2-, 2-

28, 2-29, 2-30, 2-31, 2-32, 2-34, 2-, 4-

12, 4-38, 4-96, 6-16, -1, -2, -3, -4, -

, -, -8, -9, -10, -11, -12, -13, -

14, -, -16, -, 11-3, B-, B-, D-, 

D-, D-, D-42, D-, D-60, D-, D82, D-88, D-104, D-108, D-120, D-121, D122, D-123, D-124, D-, D-126, D-132, 

D-149, D-, D-160, D-162, D-164, D-

, D-, D-, D-182, D-184, D-, 

D-191, D-193, D-, D-, D-, D-

, D-, D-293, D-316, D-, D-328, 

D-336, D-, D-, D-346, D-349, D-

, D-, D-, D-392, D-408, D-413, 

D-, D-421, D-460, D-, D-498, D499, D-, D-, D-, D-, D-, 

D-, D-, D-, D-, D-, D-

, D-, D-, D-, D-, D-, 

D-, D-, D-630, F-4, F-, F-8, F-9, 

F-12, F-13, F-14, F-19, H-1, H-2, H-3, H4, H-, H-6, H-, H-8 

Council on Environmental Quality, 1-, 1-8, 

1-23, 3-8, 3-44, -20, 6-1, 6-3, 6-4, 6-22, 

6-60, 6-61, -8, -10, -12, -16, -18, 

11-, D-39, D-44, D-, D-46, D-48, D-, 

D-84, D-, D-108, D-148, D-212, D-

, D-, D-231, D-234, D-, D-611 

Critical habitat, xl, xli, liii, 3-28, 4-44, 4-, 

4-, 4-48, 4-49, -31, -32, -33, -34, 

6-36, 8-, 11-, D-, D-

Criticality, 2-33, 2-34, 4-, 4-, 11-6, B12, B-22, D-163, D-290, D-291, D-, D-

, D-318, D-320, D-321, D-333, D-334, 

D-, D-398, D-399, D-400, D-410, D468, D-, D-, D-, D-613, D-614, 

I-2, I-

Cultural resource, xxxiv, xxxv, xxxvii, xlii, 

xliii, xlviii, xlix, liii, liv, lv, lix, lxi, lxii, 3-30, 

3-31, 3-32, 4-13, 4-14, 4-49, 4-, 4-, 

4-, 4-, 4-, 4-, 4-98, -3, -12, -

13, -14, -, -36, -, -38, -39, -

40, -, -, 6-10, 6-, 6-38, 6-39, 6-

, 8-2, 8-3, 8-4, 8-, 8-6, 8-, 8-9, 9-2, 9-

3, 9-4, 9-6, 11-6, D-, D-129, D-202, D203, D-, D-, D-, D-260, D-261, 

D-262, D-263, D-264, D-, D-

D

Decommissioning, xxiv, xxxii, xliv, lvi, lx, lxii, 

lxiv, 1-16, 1-, 1-18, 1-20, 1-29, 2-3, 2-, 

2-, 2-10, 2-12, 2-, 2-19, 2-20, 2-24, 2-

, 2-26, 2-, 2-28, 2-29, 2-34, 2-, 2-

38, 2-39, 2-40, 3-4, 3-, 3-, 3-19, 3-34, 

3-41, 3-44, 3-, 3-46, 3-, 3-48, 4-2, 4-

, 4-10, 4-11, 4-18, 4-19, 4-, 4-, 4-

34, 4-, 4-62, 4-63, 4-64, 4-, 4-, 4-

102, 4-, 4-110, -3, -4, -22, -32, -

, -48, -63, -64, 6-2, 6-3, 6-8, 6-9, 6-

11, 6-13, 6-14, 6-, 6-, 6-18, 6-19, 6-
Index 

185(*௅ 10-4 September 2014 

23, 6-24, 6-26, 6-, 6-29, 6-32, 6-33, 6-

, 6-36, 6-38, 6-39, 6-41, 6-42, 6-44, 6-

, 6-48, 6-49, 6-, 6-, 6-, 6-, 6-

, 6-61, 6-62, 6-63, 6-66, 8-9, 11-6, 11-

8, 11-19, B-8, B-12, B-14, B-21, B-24, B34, B-39, B-41, D-6, D-, D-49, D-60, D61, D-68, D-69, D-86, D-101, D-103, D109, D-110, D-111, D-132, D-134, D-, 

D-139, D-140, D-141, D-142, D-143, D149, D-, D-, D-182, D-183, D-184, 

D-, D-188, D-191, D-194, D-, D196, D-, D-200, D-202, D-, D-, 

D-216, D-233, D-, D-263, D-, D-

, D-, D-328, D-330, D-340, D-361, 

D-366, D-, D-382, D-, D-391, D396, D-, D-398, D-423, D-424, D-430, 

D-431, D-432, D-442, D-444, D-449, D-

, D-, D-, D-, D-461, D-464, 

D-, D-466, D-, D-468, D-469, D-

, D-, D-484, D-, D-499, D-, 

D-, D-, D-, D-, D-, D-

, D-, D-, D-, D-, D-, 

D-62, D-, D-, D-, D-608, D611, D-621, D-622, D-623, D-630, E-1, E-

, E-6, E-, E-8, E-19, E-23, E-24, E-, 

E-, E-28, F-1, F-2, F-10, F-11, F-12, F-

, F-16, F-, F-18, F-21, G-1, G-9, G18 

Decommissioning GEIS, xxiv, 1-18, 2-, 6-

9, 6-11, 6-13, 6-14, 6-, 6-19, 6-24, 6-

, 6-29, 6-33, 6-36, 6-38, 6-41, 6-42, 6-

44, 6-, 6-, 11-6, D-134, D-183 

Department of Energy, 1-1, 1-, 1-16, 1-20, 

1-23, 1-, 1-26, 1-28, 2-1, 2-10, 2-18, 2-

20, 2-21, 2-22, 2-23, 2-30, 2-32, 2-33, 2-

, 2-38, 3-41, 4-3, 4-31, 4-42, 4-63, 4-

64, 4-68, 4-, 4-, 4-83, 4-89, 4-102, -

1, -20, -, -61, -62, -64, 6-10, 6-

14, 6-20, 6-42, 6-46, 6-48, 6-61, 11-6, 11-

21, B-3, B-4, B-8, B-16, B-, B-28, B-29, 

B-30, B-31, B-34, B-, B-36, B-38, B-40, 

B-41, D-12, D-28, D-32, D-48, D-49, D63, D-68, D-, D-90, D-94, D-, D122, D-, D-, D-141, D-, D-, 

D-, D-164, D-, D-, D-, D-

, D-, D-, D-180, D-182, D-183, 

D-184, D-221, D-222, D-, D-229, D248, D-269, D-, D-290, D-291, D-, 

D-296, D-298, D-323, D-324, D-336, D-

, D-, D-, D-, D-, D-381, 

D-383, D-384, D-, D-402, D-403, D-

, D-408, D-412, D-, D-, D-, 

D-, D-2, D-, D-, D-, D-

, D-, D-, D-, D-, D-, 

D-, D-, D-, D-, D-, D611, D-612, D-618, D-630, E-4, E-26, G14, G-, G-16, I-6, I-

Design-basis accidents, xlvi, 4-, 4-, 4-

, 4-, 4-81, 4-82, 4-84, 6-, 11-1, 11-

, 11-19, D-109, D-, D-264, D-319, D346, D-366, D-410, D-

Disposal (permanent), xxiii, xxviii, xxxiv, 

xxxv, xxxvii, xliv, l, lvi, lvii, lxii, 1-1, 1-2, 1-

3, 1-4, 1-, 1-18, 1-20, 1-23, 1-, 1-26, 

1-, 1-28, 2-4, 2-, 2-20, 2-21, 2-, 2-

36, 2-, 3-, 3-21, 3-34, 3-, 3-36, 3-

, 3-42, 3-4, 3-49, 4-14, 4-, 4-60, 4-

61, 4-62, 4-63, 4-64, 4-, 4-, 4-68, 4-

, 4-102, -, -22, -, -46, -48, -

, -, -, -61, -62, 6-9, 6-10, 6-

19, 6-20, 6-42, 6-, 6-46, 6-, 6-48, 6-

49, 6-, 6-, 6-, 6-61, 8-8, 8-9, 9-3, 

11-3, 11-4, 11-, 11-, 11-10, 11-11, 11-

13, 11-21, B-1, B-2, B-3, B-4, B-, B-6, B-

, B-8, B-10, B-26, B-, B-28, B-29, B30, B-33, B-34, B-, B-36, B-, B-40, 

D-4, D-, D-, D-8, D-12, D-13, D-, D18, D-19, D-28, D-29, D-32, D-33, D-34, 

D-, D-39, D-, D-49, D-, D-, D-

, D-60, D-62, D-66, D-, D-, D-83, 

D-, D-90, D-93, D-, D-100, D-104, D-

, D-110, D-, D-118, D-119, D-122, 
Index 

September 2014 10- 185(*௅

D-134, D-, D-141, D-143, D-144, D-

, D-163, D-164, D-, D-166, D-, 

D-, D-, D-, D-, D-, D193, D-204, D-, D-269, D-, D-, 

D-, D-, D-, D-, D-, D-

, D-284, D-289, D-294, D-, D-299, 

D-, D-, D-, D-, D-, D-

, D-, D-, D-, D-, D-, 

D-, D-380, D-381, D-382, D-383, D384, D-388, D-393, D-, D-, D-, 

D-408, D-416, D-499, D-, D-, D-

, D-, D-, D-, D-, D-, 

D-, D-, D-, D-, D-, D-

, D-, D-, D-, D-, D-604, 

D-, D-609, D-612, D-, D-616, D620, D-621, D-630, F-14 

Dose, xxxiv, xxxv, xlv, xlvii, lvii, lviii, lxiv, 2-

23, 3-38, 3-39, 3-40, 3-41, 4-10, 4-11, 4-

13, 4-26, 4-31, 4-42, 4-60, 4-69, 4-, 4-

, 4-, 4-, 4-, 4-, 4-82, 4-83, 4-

88, 4-89, 4-94, 4-96, 4-, 4-101, 4-104, 

4-, -3, -13, -14, -, -, -, 

-, -, 6-, 6-, 6-, 6-, 6-, 

11-2, 11-4, 11-6, 11-, 11-16, 11-, 11-

19, 11-20, B-14, B-, B-23, B-32, D-, 

D-144, D-, D-161, D-163, D-186, D229, D-230, D-239, D-244, D-248, D-249, 

D-264, D-, D-, D-283, D-284, D-

, D-290, D-298, D-299, D-300, D-301, 

D-302, D-303, D-304, D-, D-306, D-

, D-308, D-309, D-310, D-311, D-312, 

D-, D-316, D-318, D-320, D-321, D324, D-, D-331, D-, D-, D-, 

D-390, D-421, D-, D-460, D-461, D462, D-, D-466, D-482, D-, D-491, 

D-492, D-493, D-496, D-, D-, D-

, D-613, D-619, D-633, E-6, E-16, E19, E-20, E-24, E-, E-29, F-2, F-3, F-4, 

F-6, F-, F-8, F-12, F-16 

E

Earthquake, xxxii, xlvi, lviii, 1-10, 2-12, 3-, 

4-, 4-, 4-, 4-, 4-81, 4-82, 4-, 

4-86, 4-88, -, 11-, B-12, B-13, B-19, 

B-20, B-22, B-42, D-24, D-94, D-, D212, D-, D-218, D-219, D-238, D-283, 

D-298, D-313, D-314, D-, D-320, D322, D-323, D-324, D-334, D-340, D-341, 

D-342, D-343, D-346, D-348, D-349, D360, D-366, D-368, D-, D-389, D-391, 

D-392, D-394, D-396, D-398, D-406, D409, D-410, D-440, D-448, D-449, D-, 

D-, D-496, D-, D-, D-, D-

, D-, D-, D-, D-, D-612, 

D-629, D-633, E-1, F-3, F-, F-16, F-, 

F-18, F-21, G-2 

Effluent, xxxix, xl, lii, lxiv, 2-4, 2-32, 3-16, 3-

39, 3-40, 4-, 4-23, 4-, 4-29, 4-31, 4-

32, 4-33, 4-34, 4-, 4-36, 4-39, 4-40, 4-

42, 4-43, 4-104, 4-, -13, -29, 6-29, 

6-, 11-, B-23, B-24, D-130, D-131, D160, D-161, D-190, D-210, D-, D-226, 

D-228, D-229, D-236, D-, D-239, D242, D-244, D-249, D-, D-300, D-301, 

D-, D-309, D-311, D-390, D-, D460, D-461, D-462, D-468, D-, D-, 

D-, D-480, D-490, D-, D-, D-

, D-609, D-619, E-6, E-, E-13, E-, 

E-19, E-20, E-26, E-, E-28 

Electromagnetic field, 3-22, 4-32, 6-, 11-8 

Endangered species, xlvii, lix, lxi, 3-28, 4-

98, -, 6-, 8-2, 8-3, 8-4, 11-8, 11-9, 

D-, D-, D-, D-

Entrainment, 3-22, 4-36, 4-, 4-38, 4-39, 4-

46, 6-34, 6-, 11-8, D-, D-249, D-

, D-491 

Environmental justice, xxxiv, xxxv, xxxvii, 

xlvii, xlix, lix, lx, 3-8, 3-10, 3-11, 3-43, 3-

44, 4-9, 4-10, 4-11, 4-12, 4-13, 4-14, 4-

98, 4-100, 4-, 4-106, -10, -11, -12, 
Index 

185(*௅ 10-6 September 2014 

-13, -, -, -61, 6-, 6-16, 6-18, 

6-, 6-60, 8-2, 8-3, 8-4, 8-6, 8-, 8-9, 9-

2, 9-4, 9-, 11-9, D-, D-, D-198, D199, D-200, D-201, D-202, D-203, D-204, 

D-, D-206, D-, D-222, D-230, D-

, D-260, D-490, D-491, D-, D-

Environmental Protection Agency, xxvii, xliii, 

xliv, lv, lxiii, 1-11, 1-12, 1-, 1-28, 3-8, 3-

12, 3-13, 3-14, 3-16, 3-, 3-19, 3-33, 3-

36, 3-39, 3-44, 3-, 3-46, 4-9, 4-19, 4-

26, 4-31, 4-, 4-, 4-, 4-, 4-61, 4-

102, -13, -, -20, -41, -42, -43, -

48, -62, 6-1, 6-22, 6-40, 6-42, 6-60, 6-

62, 11-, 11-9, 11-14, B-26, C-3, D-, D28, D-60, D-130, D-, D-208, D-216, D-

, D-236, D-246, D-, D-303, D-328, 

D-, D-381, D-383, D-460, D-461, D462, D-, D-, D-, D-482, D-486, 

D-, D-, D-, D-, D-606, D-

, D-613, E-8, E-, E-16, E-, E-20, 

E-26 

Essential Fish Habitat, xlvii, lix, lxi, 3-28, 3-

29, 4-44, 4-46, 4-, 4-48, 4-49, 4-98, -

32, -34, -, 6-, 8-2, 8-3, 8-4, 8-, 

11-9 

Evacuation, B-14, D-68, D-94, D-, D190, D-294, D-, D-332, D-336, D-, 

D-342, D-349, D-441, D-, D-, F-4, 

F-, F-6, F-8, F-12 

F

Findings, 1-2, 1-3, 1-, 1-8, 1-18, 1-21, 1-

29, 2-10, 2-20, 3-44, 3-, 4-, 4-, 4-

, 4-, 4-86, 4-96, 4-, 4-, -6, -

26, -34, -, -39, -, 6-60, -, -

10, -11, -12, -13, -16, -, 11-8, B1, B-11, D-, D-10, D-11, D-22, D-24, D26, D-28, D-29, D-33, D-40, D-46, D-, 

D-, D-64, D-68, D-, D-, D-80, D-

, D-, D-111, D-113, D-130, D-131, D-

, D-, D-198, D-202, D-, D-211, 

D-213, D-214, D-216, D-229, D-244, D-

, D-249, D-, D-, D-, D-260, 

D-261, D-, D-, D-314, D-316, D341, D-, D-348, D-, D-360, D-, 

D-, D-, D-, D-382, D-384, D411, D-412, D-416, D-, D-418, D-428, 

D-438, D-439, D-446, D-449, D-, D-

, D-463, D-, D-, D-, D-481, 

D-, D-, D-621, H-8 

Fish and Wildlife Service, xli, 3-21, 3-28, 3-

29, 3-, 4-, 4-46, 4-48, 4-49, 4-103, -

31, -32, -33, -62, 6-32, 6-, 6-36, 11-

3, 11-8, 11-9, D-, D-, D-, D-



Flood, xlvi, 4-, 4-, 4-, 4-, 4-80, 4-

81, 4-82, 4-83, 4-84, 4-88, 4-89, 4-90, 4-

104, 4-110, -6, 11-, B-19, D-24, D-

, D-238, D-292, D-313, D-319, D-320, 

D-321, D-332, D-334, D-340, D-341, D342, D-343, D-360, D-392, D-394, D-410, 

D-496, D-, E-13 

Frequency-weighted consequence, D-422, 

F-13 

Fuel cycle, 1-18, 1-23, 2-20, 3-39, 3-40, 6-

22, 6-46, 6-, 6-, 11-10, 11-16, D-12, 

D-, D-64, D-, D-, D-204, D-216, 

D-269, D-294, D-304, D-, D-413, D491, D-496, D-499, D-, D-, D-612 

Fukushima, xxxii, 1-10, 2-12, 2-13, 2-39, 4-

, 4-80, 4-86, 4-109, B-13, B-20, B-22, 

B-32, B-, B-41, D-6, D-22, D-68, D-, 

D-, D-94, D-109, D-114, D-132, D-133, 

D-, D-212, D-219, D-, D-238, D302, D-306, D-313, D-, D-316, D-320, 

D-322, D-, D-326, D-332, D-334, D-

, D-344, D-368, D-386, D-389, D-391, 

D-392, D-396, D-, D-398, D-412, D-

, D-418, D-419, D-440, D-442, D-, 

D-, D-, D-464, D-, D-, D-

, D-, D-, D-, D-, D-, 
Index 

September 2014 10- 185(*௅

D-, D-, D-, D-, D-, D-

, D-, D-, D-, D-626, D-, 

D-633, F-, F-16, F-20, F-21 

G

Greenhouse gases, xxxiv, xxxv, xxxviii, l, li, 

lxii, 3-11, 3-12, 3-44, 3-48, 3-49, 4-, 4-

18, 4-19, 4-20, 4-80, 4-102, 4-109, -19, 

-20, -21, -62, -, 6-21, 6-22, 6-60, 

6-61, 6-62, 6-66, 8-9, 11-11, D-211, D212, D-, D-216, D-, D-249, D-491, 

D-, D-496, D-, D-, D-611 

Groundwater, xxxiv, xxxv, xxxviii, xxxix, xlvii, 

li, lii, lix, lxi, lxiii, 2-30, 3-11, 3-, 3-, 3-

18, 3-19, 3-21, 3-48, 3-49, 4-10, 4-20, 4-

22, 4-23, 4-, 4-26, 4-, 4-28, 4-30, 4-

, 4-98, 4-108, -24, -, -26, -, -

28, -, 6-28, 6-29, 6-30, 6-31, 6-, 8-

2, 8-3, 8-4, 9-2, 9-, 11-11, 11-12, 11-20, 

11-21, B-23, B-40, B-41, D-130, D-131, 

D-213, D-214, D-220, D-221, D-223, D224, D-, D-226, D-, D-228, D-229, 

D-230, D-231, D-232, D-233, D-234, D-

, D-, D-238, D-239, D-240, D-242, 

D-243, D-244, D-301, D-306, D-334, D344, D-, D-, D-, D-, D-, 

D-, D-, D-460, D-462, D-463, D464, D-, D-466, D-, D-, D-, 

D-, D-4, D-, D-, D-, D-

, D-, D-480, D-481, D-482, D-483, 

D-484, D-, D-486, D-, D-490, D492, D-493, D-, D-609, D-, D-618, 

D-626, D-631, D-633, E-1, E-, E-6, E-, 

E-8, E-9, E-10, E-11, E-12, E-13, E-14, E-

, E-16, E-, E-18, E-19, E-20, E-21, 

E-22, E-23, E-24, E-, E-26, E-, E-28, 

E-29 

H

Hardened onsite storage, xxvi, xxviii, 1-10, 

11-11, D-6, D-, D-60, D-, D-113, D114, D-, D-116, D-118, D-369, D-, 

D-420, D-, D-, D-, D-, D-

, D-

Hazardous waste, xxxiv, xxxv, xliv, 3-, 3-

36, 3-, 3-43, 4-, 4-61, 4-64, -46, 6-

, 11-11, 11-14, D-, D-, D-

High-burnup fuel, xxviii, 1-, 2-6, 2-8, 2-28, 

B-9, B-11, B-12, B-16, D-4, D-60, D-, 

D-86, D-, D-138, D-, D-, D162, D-163, D-, D-283, D-284, D-, 

D-, D-288, D-, D-318, D-, D333, D-334, D-368, D-392, D-, D-399, 

D-401, D-402, D-403, D-404, D-411, D413, D-414, D-, D-, D-, D-, 

D-, F-18, G-1, G-13, G-, I-1, I-2, I-3, 

I-4, I-6, I-

High-level waste, 1-10, 1-24, 1-28, 1-30, 11-

12, 11-21, B-40, D-39, D-40, D-48, D-, 

D-, D-, D-, D-210, D-290, D313, D-, D-364, D-, D-381, D-384, 

D-, D-, D-, D-, D-, D630 

Human health, xxxiv, xxxv, xxxvii, xlix, l, 3-8, 

3-9, 3-10, 3-11, 3-, 4-9, 4-10, 4-11, 4-

12, 4-13, 4-14, 4-, 4-, -10, -11, -

12, -13, -14, -, -, -, -, 6-

16, 6-, 6-18, 6-, 8-6, 8-, 11-9, 11-

11, 11-14, D-, D-, D-199, D-200, D204, D-, D-206, D-, D-209, D-, 

D-260, D-300, D-301, D-306, D-309, D344, D-, F-4 

I

Impingement, 3-22, 4-36, 4-, 4-38, 4-39, 

4-46, 6-34, 6-, 11-12, D-, D-249, D-

, D-491 
Index 

185(*௅ 10-8 September 2014 

Institutional control, xxviii, xxix, xxxi, 1-16, 

11-12, B-10, B-26, B-, B-28, B-29, B30, B-31, D-, D-63, D-89, D-, D-128, 

D-138, D-139, D-141, D-143, D-, D-

, D-, D-, D-, D-, D-, 

D-, D-, D-, D-, D-210, D-

, D-248, D-, D-464, D-469, D-, 

D-, D-613, D-633 

Interim storage, xxxi, 2-4, 2-19, 2-20, 2-38, 

2-39, 11-10, 11-12, 11-13, B-, B-, D66, D-89, D-118, D-, D-, D-202, D292, D-, D-406, D-, D-409, D-412, 

D-, D-623 

L

Land use, xxxiv, xxxv, xxxvi, xlvii, xlviii, lii, 

lix, lx, lxii, 1-16, 2-8, 3-1, 3-3, 3-20, 3-46, 

4-3, 4-4, 4-, 4-6, 4-98, -, -6, -, -8, 

-29, -, 6-10, 6-11, 6-12, 6-, 8-2, 8-

3, 8-4, 8-, 9-2, 9-6, D-, D-23, D-, D-

, D-168, D-182, D-183, D-184, D-, 

D-186, D-, D-188, D-189, D-191, D192, D-194, D-, D-489, F-9 

License renewal, xxiii, xxiv, xxxii, xxxiii, 

xxxix, xl, lvi, lxiv, 1-4, 1-, 1-13, 1-18, 1-

20, 1-22, 1-30, 2-40, 3-1, 3-2, 3-, 3-11, 

3-14, 3-, 3-19, 3-20, 3-22, 3-, 3-28, 

3-31, 3-32, 3-34, 3-, 3-, 3-48, 4-2, 4-

3, 4-, 4-, 4-29, 4-30, 4-31, 4-32, 4-

33, 4-36, 4-, 4-38, 4-39, 4-40, 4-41, 4-

42, 4-43, 4-, 4-, 4-, 4-, 4-, 4-

, 4-60, 4-61, 4-63, 4-66, 4-69, 4-, 4-

, 4-106, 4-, 4-109, -, -38, -

48, -64, 6-4, 6-6, 6-13, 6-, 6-, 6-48, 

6-49, 6-, 6-64, 6-, -3, -, -6, -, 

-9, -11, -13, -19, 11-13, B-18, B-19, 

B-, C-1, C-3, D-20, D-23, D-26, D-28, 

D-29, D-48, D-, D-, D-, D-, D-

, D-68, D-, D-, D-, D-, D-, 

D-80, D-88, D-, D-96, D-101, D-104, D-

, D-116, D-126, D-133, D-134, D-146, 

D-, D-, D-, D-183, D-, D-

, D-206, D-211, D-220, D-234, D-236, 

D-238, D-240, D-242, D-243, D-244, D-

, D-, D-248, D-249, D-, D-, 

D-, D-, D-260, D-261, D-264, D266, D-, D-, D-, D-286, D-, 

D-344, D-, D-412, D-, D-, D463, D-469, D-494, D-499, D-, D-, 

D-, D-, D-, D-, D-, D-

, D-, D-620, D-624, D-, D-630, 

D-631, E-, E-24, E-28, F-14, F-16, F-20, 

F-21, H-1, H-3, H-4, H-, H-, H-8 

License Renewal GEIS, xxiv, xxxiii, xxxix, xl, 

lvi, lxiv, 1-13, 1-18, 3-1, 3-2, 3-11, 3-14, 3-

, 3-19, 3-20, 3-22, 3-, 3-28, 3-31, 3-

, 4-3, 4-, 4-, 4-29, 4-30, 4-31, 4-

32, 4-33, 4-36, 4-, 4-38, 4-39, 4-40, 4-

41, 4-42, 4-43, 4-, 4-, 4-, 4-, 4-

60, 4-61, 4-66, 4-69, 4-, 6-4, 6-13, 6-

, 6-48, 6-49, 6-, -6, 11-13, D-, D-

, D-104, D-, D-146, D-183, D-234, 

D-238, D-240, D-242, D-243, D-244, D-

, D-, D-249, D-, D-, D-, 

D-, D-, D-494, D-, D-, F14, F-16 

License termination, 1-23, 1-29, 6-24, D462, D-, D-, D-621, E-9, E-

Low-level waste, xliv, xlv, xlviii, lvi, lvii, lix, 1-

18, 1-24, 2-, 3-34, 3-, 3-36, 4-, 4-

60, 4-61, 4-62, 4-63, 4-64, 4-, 4-66, 4-

, 4-68, 4-69, 4-98, -, -46, -, -

48, -, -, -, 6-11, 6-, 6-46, 6-

, 6-48, 6-49, 6-, 6-, 6-, 8-2, 8-3, 

8-8, 11-4, 11-14, 11-21, D-62, D-, D-

, D-, D-269, D-, D-, D-, 

D-, D-, D-, D-, D-380, D381, D-, D-412, D-, D-630 
Index 

September 2014 10-9 185(*௅

M

Mitigation, xli, lxiv, 2-36, 3-12, 3-19, 4-, 4-

, 4-46, 4-, 4-48, 4-49, 4-, -16, -

26, -30, -32, -33, -, -, -39, -

44, 6-11, 6-19, 6-24, 6-26, 6-, 6-29, 6-

32, 6-, 6-36, 6-38, 6-41, 6-46, 6-48, 6-

49, 11-1, 11-8, 11-14, D-, D-38, D-41, 

D-, D-61, D-, D-, D-83, D-, D86, D-, D-94, D-, D-98, D-99, D-, 

D-106, D-110, D-111, D-113, D-, D-

, D-, D-194, D-, D-, D-, 

D-264, D-316, D-328, D-334, D-343, D344, D-, D-, D-, D-360, D-361, 

D-, D-398, D-399, D-402, D-, D426, D-431, D-432, D-, D-, D-, 

D-, D-, E-10, E-26, F-6, F-9, F-, 

F-16, F-18, F-21 

Mixed oxide fuel, xxxi, xxxii, 2-8, 2-9, 11-14, 

B-10, B-12, B-16, D-60, D-, D-, D180, D-304, D-398, D-399, D-403, D-411, 

D-413, D-414, D-, D-416, D-, D-

, I-1, I-

Mixed waste, xxxiv, xxxv, xliv, xlviii, lvi, lvii, 

lix, 3-, 3-36, 3-, 4-, 4-60, 4-61, 4-

63, 4-, 4-98, -, -46, -48, -, 6-

46, 6-, 6-48, 6-49, 6-, 8-2, 8-3, 11-14 

Monitoring, xxxii, xxxvi, xxxvii, xxxviii, xxxix, 

xli, xlii, xliii, l, liv, lv, lxiii, 2-4, 2-, 2-28, 

2-29, 2-30, 2-31, 2-32, 3-11, 3-13, 3-16, 

3-, 3-19, 3-39, 4-3, 4-4, 4-, 4-, 4-10, 

4-11, 4-12, 4-13, 4-14, 4-, 4-16, 4-21, 

4-23, 4-26, 4-, 4-31, 4-33, 4-, 4-43, 

4-, 4-48, 4-, 4-, 4-, 4-, 4-, 

4-, 4-62, 4-63, 4-64, 4-, 4-, 4-, 

-3, -4, -13, -14, -, -, -29, -

32, -39, -40, -42, -43, -46, -, 6-

40, 6-, 11-1, 11-9, 11-13, 11-14, 11-21, 

B-10, B-22, B-24, B-26, B-28, B-32, B-, 

B-40, D-24, D-, D-46, D-133, D-143, D-

, D-160, D-161, D-, D-168, D-169, 

D-3, D-184, D-188, D-189, D-190, D194, D-220, D-221, D-224, D-, D-, 

D-230, D-239, D-, D-261, D-, D301, D-, D-311, D-336, D-364, D-388, 

D-390, D-, D-400, D-402, D-411, D-

, D-, D-, D-, D-, D-463, 

D-464, D-, D-466, D-, D-468, D-

, D-, D-, D-, D-, D-, 

D-480, D-481, D-482, D-483, D-484, D-

, D-491, D-492, D-, D-, D-, 

D-, D-609, D-618, D-633, E-4, E-, E6, E-, E-9, E-10, E-16, E-, E-20, E-23, 

E-24, E-29 

N

National Ambient Air Quality Standards, 3-

13, 3-14, 3-46, -, -16, 11-

National Environmental Policy Act, xxiii, 

xxiv, xxv, xxvi, xxxi, xxxii, xlii, xlvii, xlix, lxi, 

lxvi, 1-1, 1-3, 1-4, 1-, 1-6, 1-, 1-8, 1-9, 

1-12, 1-, 1-18, 1-19, 1-20, 1-21, 1-, 

1-29, 3-8, 3-9, 3-10, 3-32, 3-44, 3-46, 4-2, 

4-9, 4-11, 4-12, 4-16, 4-49, 4-, 4-, 4-

91, 4-104, -11, -14, -33, -, -36, -

, -38, -63, 6-1, 6-4, 6-16, 6-39, 6-60, 

6-61, 6-62, -3, -, -8, -9, -10, -11, 

-12, -14, -18, 8-1, 8-4, 8-, 8-8, 8-9, 9-

2, 9-3, 9-4, 11-, 11-8, 11-, B-26, B-28, 

B-30, B-38, D-, D-, D-14, D-16, D-18, 

D-19, D-20, D-21, D-22, D-23, D-26, D28, D-29, D-30, D-32, D-34, D-, D-36, 

D-, D-39, D-40, D-43, D-44, D-, D46, D-, D-48, D-49, D-, D-, D-, 

D-, D-, D-, D-61, D-, D-68, D-

, D-, D-, D-, D-, D-, D-, 

D-80, D-81, D-82, D-83, D-84, D-, D86, D-, D-88, D-, D-99, D-101, D102, D-, D-106, D-, D-108, D-110, 

D-111, D-112, D-114, D-116, D-121, D-

, D-126, D-, D-133, D-136, D-139, 
Index 

185(*௅ 10-10 September 2014 

D-140, D-146, D-148, D-, D-, D-

, D-, D-, D-, D-160, D-164, 

D-, D-, D-, D-, D-198, D199, D-200, D-201, D-202, D-204, D-206, 

D-208, D-212, D-214, D-, D-, D218, D-223, D-226, D-231, D-234, D-236, 

D-239, D-243, D-, D-, D-, D-

, D-260, D-262, D-263, D-, D-268, 

D-282, D-, D-303, D-313, D-318, D-

, D-338, D-339, D-343, D-, D-349, 

D-3, D-369, D-382, D-384, D-, D-

, D-409, D-412, D-, D-419, D-420, 

D-424, D-443, D-446, D-, D-, D-

, D-, D-, D-460, D-461, D-464, 

D-469, D-, D-, D-, D-, D492, D-493, D-, D-496, D-, D-, 

D-, D-, D-, D-, D-, D-

, D-606, D-611, D-618, F-4, G-2, G-

, I-2, I-8 

National Historical Preservation Act, xlii, liv, 

3-30, 3-31, 3-32, 3-46, 4-2, 4-13, 4-14, 4-

49, 4-, 4-, 4-, 4-, 4-104, -13, -

, -36, -, -38, -40, -63, 6-38, 6-

39, 6-62, 11-, D-, D-260, D-262, D263, D-264, D-, D-266, D-, D-618 

National Marine Fisheries Service, xli, 3-28, 

3-29, 4-, 4-46, 4-, 4-48, 4-49, 4-103, 

-31, -32, -33, -34, -62, 6-32, 6-, 

6-36, 11-3, 11-8, 11-, D-, D-, D-

, D-612, D-, D-619, D-630 

National Pollution Discharge Elimination 

System, 3-16, 3-, 3-, 4-20, 4-22, 4-

, 4-30, 4-31, 4-34, 4-40, 4-42, 4-43, -

23, -30, 6-, 6-29, 6-32, 6-, D-, 

D-236, D-242, D-, D-248, D-249, D-

, D-, D-, D-

Native American, 2-, 3-3, 3-6, 3-11, 3-31, 

4-10, 6-10, 11-2, 11-9, C-2, D-, D-202 

Natural phenomena, xlvi, lviii, 3-12, 3-, 4-

18, 4-, 4-, 4-, 4-, 4-, 4-80, 4-

81, 4-82, 4-84, 4-88, -19, -, 6-, 11-

, 11-, D-109, D-219, D-230, D-232, D-

, D-238, D-264, D-313, D-314, D-, 

D-320, D-322, D-324, D-326, D-342, D343, D-, D-391, D-394, D-, D-410, 

D-, D-, D-

No-action alternative, 1-6, 1-, 1-11, 4-, 

-14, 11-8, 11-, B-30, B-31, D-42, D63, D-, D-, D-, D-81, D-82, D-, 

D-88, D-89, D-90, D-91, D-92, D-93, D94, D-100, D-104, D-106, D-, D-108, 

D-110, D-111, D-112, D-116, D-, D118, D-119, D-120, D-121, D-122, D-123, 

D-124, D-, D-, D-

O

Occupational Safety and Health 

Administration, 3-33, 3-42, 3-43, 4-, 4-

, -, 6-, 6-, 11-16 

P

Population (population density), xxxiv, xxxv, 

xxxvii, xlix, l, lx, lxiv, 2-4, 3-6, 3-, 3-8, 3-

9, 3-10, 3-11, 3-26, 3-31, 3-33, 3-38, 3-

40, 3-41, 3-43, 3-46, 3-49, 4-9, 4-10, 4-

11, 4-12, 4-13, 4-14, 4-, 4-38, 4-39, 4-

41, 4-, 4-96, 4-100, -2, -3, -8, -9, 

-10, -11, -12, -13, -14, -, -32, 

-34, -43, -63, 6-6, 6-, 6-13, 6-, 6-

16, 6-, 6-18, 6-, 6-43, 6-, 6-, 6-

66, 8-6, 8-, 8-9, 11-14, 11-16, 11-19, D94, D-, D-99, D-144, D-, D-188, D190, D-198, D-199, D-200, D-202, D-203, 

D-204, D-, D-, D-240, D-, D260, D-264, D-280, D-288, D-293, D-, 

D-, D-310, D-311, D-316, D-318, D329, D-331, D-340, D-341, D-342, D-348, 

D-, D-, D-406, D-413, D-, D421, D-422, D-423, D-424, D-, D-441, 

D-442, D-443, D-0, D-, D-481, D490, D-494, D-, D-, D-, D-, 
Index 

September 2014 10-11 185(*௅

D-, D-619, D-, E-14, F-1, F-3, F-4, 

F-, F-8, F-9, F-12, F-13, F-14, F-16 

Postulated accident, xlvi, lviii, 3-, 4-, 4-

81, 4-88, 4-, -, -, 6-, 6-, 11-

, B-14, D-31, D-98, D-109, D-, D218, D-220, D-230, D-232, D-, D-, 

D-, D-313, D-319, D-321, D-324, D328, D-331, D-, D-, D-393, D-, 

D-498, I-2 

Pressurized water reactor, 2-3, 2-, 2-6, 2-

, 2-8, 2-9, 2-18, 2-34, 3-3, 3-36, 4-2, 4-

23, 4-, 4-, 4-88, 4-104, 6-48, -, 11-

, B-12, B-14, B-36, B-42, D-, D-269, 

D-, D-304, D-322, D-340, D-, D-

, D-414, D-424, D-, D-429, D-439, 

D-, D-632, E-1, E-2, E-3, E-19, E-20, 

E-22, E-, F-14, F-, F-22, G-1, G-3, 

G-4, G-, G-6, G-, G-8, G-9, I-3 

Private Fuel Storage Facility, xlviii, 2-1, 2-

, 2-18, 2-19, 2-30, 2-40, 4-9, -1, -2, 

-, -6, -, -8, -9, -12, -14, -, -

16, -, -19, -21, -23, -24, -, -

26, -, -28, -30, -36, -41, -42, -

44, -, -46, -, -49, -, -, -

, -, -, -, -62, -63, -, 6-

9, 6-, 6-20, 6-, 6-29, 6-33, 6-36, 6-

42, 6-44, 6-, 6-, -, -19, 11-, B18, B-19, B-39, D-, D-66, D-102, D128, D-, D-181, D-, D-198, D-206, 

D-208, D-, D-, D-268, D-, D-

, D-, D-, G-1, G-, G-

R

Radionuclide, xxxix, lxiii, 2-26, 3-19, 3-20, 3-

, 4-20, 4-22, 4-26, 4-31, 4-36, 4-41, 4-

42, 4-, 4-83, 6-30, 9-3, 11-11, 11-, B3, B-20, B-24, B-31, D-101, D-, D-

, D-, D-, D-181, D-214, D-220, 

D-222, D-229, D-232, D-, D-248, D-

, D-, D-284, D-300, D-302, D-304, 

D-, D-308, D-, D-329, D-, D-

, D-, D-404, D-414, D-434, D-, 

D-460, D-461, D-, D-, D-480, D482, D-, D-, D-490, D-492, D-, 

D-, E-6, E-, E-8, E-9, E-11, E-12, E13, E-, E-16, E-, E-18, E-19, E-20, 

E-21, E-23, E-, F-4, F-11, F-13, I-2 

Remediation, 11-18, B-29, B-38, D-, D-

, D-, D-246, D-328, D-, D-460, 

D-462, D-, D-486, D-, D-618, D631, E-6, E-, E-8, E-, E-1, E-24, E-

, E-29 

Repackaging, xxxi, xl, xliv, xlvi, xlix, 2-20, 2-

21, 2-23, 2-30, 2-31, 2-32, 2-33, 4-, 4-6, 

4-16, 4-34, 4-, 4-62, 4-63, 4-64, 4-, 

4-68, 4-69, 4-, 4-82, 4-83, 4-89, -, -

18, -21, -26, -28, -46, -, -, -

, 11-, 11-18, B-, B-18, B-20, B-32, 

D-132, D-143, D-144, D-, D-, D-

, D-180, D-181, D-224, D-, D-, 

D-286, D-324, D-402, D-, D-

Repository (geologic), xxiii, xxiv, xxvi, xxx, 

xxxii, xlix, liii, lxv, lxvi, 1-1, 1-2, 1-3, 1-4, 1-

10, 1-12, 1-, 1-20, 1-23, 1-, 1-26, 1-

28, 2-, 2-20, 2-29, 2-30, 2-, 2-40, 4-

1, 4-2, 4-, 4-6, 4-9, 4-14, 4-, 4-20, 4-

21, 4-24, 4-28, 4-, 4-, 4-, 4-66, 4-

69, 4-, 4-, 4-102, -3, -4, -, -8, 

-10, -18, -20, -21, -23, -, -26, 

-29, -31, -34, -, -48, -49, -, 

-, -61, -64, 6-9, 6-10, 6-14, 6-19, 6-

20, 6-26, 6-29, 6-32, 6-, 6-41, 6-42, 6-

, 6-48, 6-, 6-, 6-, 6-, 6-61, 8-

, 8-8, 9-2, 9-3, 11-3, 11-, 11-11, 11-13, 

11-18, 11-21, B-1, B-2, B-3, B-4, B-, B-6, 

B-, B-8, B-9, B-10, B-26, B-, B-28, B29, B-30, B-33, B-34, B-, B-38, B-40, 

B-41, D-6, D-, D-8, D-11, D-12, D-13, D-

, D-22, D-23, D-28, D-30, D-31, D-33, 

D-34, D-, D-38, D-, D-48, D-49, D-

, D-, D-, D-60, D-61, D-62, D-64, 
Index 

185(*௅ 10-12 September 2014 

D-, D-66, D-, D-, D-, D-, D86, D-, D-90, D-93, D-, D-, D114, D-116, D-, D-118, D-119, D-120, 

D-122, D-123, D-129, D-134, D-, D136, D-, D-138, D-139, D-140, D-141, 

D-143, D-144, D-, D-, D-, D160, D-162, D-163, D-164, D-166, D-, 

D-, D-, D-, D-, D-180, D188, D-192, D-194, D-, D-, D-200, 

D-202, D-, D-260, D-290, D-294, D-

, D-344, D-, D-368, D-, D-, 

D-, D-, D-, D-, D-, D-

, D-, D-, D-380, D-381, D-382, 

D-383, D-384, D-, D-386, D-388, D-

, D-406, D-, D-408, D-416, D-, 

D-491, D-499, D-, D-, D-, D-

, D-, D-, D-, D-, D-, 

D-, D-, D-, D-, D-, D-

, D-, D-, D-, D-604, D-612, 

D-621, D-630, E-1 

Reprocessing, xxvi, xxvii, 1-24, 2-1, 2-11, 2-

12, 4-2, -49, 11-10, 11-12, 11-18, D-, 

D-62, D-, D-93, D-, D-389, D-413, 

D-, D-, D-, E-4 

Risk, xxxiii, xlv, xlvi, xlvii, lix, lxiv, 1-1, 1-3, 1-

9, 1-24, 2-12, 2-21, 2-32, 3-8, 3-9, 3-10, 

3-12, 3-39, 3-42, 4-10, 4-, 4-66, 4-, 

4-, 4-, 4-, 4-, 4-, 4-, 4-, 

4-80, 4-81, 4-84, 4-, 4-86, 4-, 4-88, 

4-89, 4-90, 4-91, 4-94, 4-, 4-103, 4-

104, 4-, 4-, 4-108, -13, -, -

, -, -, -, 6-16, 6-, 6-22, 6-

, 6-, 6-, 6-, 6-, 6-, 6-63, 6-

66, 11-18, B-, B-12, B-13, B-14, B-19, B28, B-29, B-30, B-39, B-40, D-29, D-, 

D-, D-, D-68, D-, D-86, D-, D96, D-98, D-, D-, D-108, D-113, D114, D-, D-, D-130, D-131, D-141, 

D-144, D-, D-, D-148, D-, D-

, D-161, D-162, D-, D-, D-, 

D-, D-, D-188, D-189, D-190, D193, D-203, D-, D-, D-219, D-222, 

D-229, D-231, D-232, D-234, D-, D-

, D-264, D-, D-, D-, D-, 

D-, D-280, D-281, D-282, D-283, D-

, D-, D-289, D-290, D-292, D-293, 

D-294, D-, D-296, D-, D-298, D299, D-303, D-304, D-, D-306, D-308, 

D-309, D-311, D-312, D-313, D-, D316, D-, D-318, D-319, D-320, D-321, 

D-322, D-323, D-324, D-, D-326, D-

, D-328, D-329, D-330, D-331, D-332, 

D-338, D-339, D-340, D-341, D-342, D343, D-344, D-, D-, D-348, D-349, 

D-, D-, D-, D-, D-, D-

, D-, D-, D-, D-, D-360, 

D-361, D-364, D-366, D-368, D-369, D-

, D-, D-386, D-391, D-394, D-396, 

D-, D-398, D-403, D-406, D-, D408, D-412, D-, D-418, D-419, D-420, 

D-421, D-422, D-423, D-424, D-428, D439, D-440, D-442, D-443, D-, D-448, 

D-449, D-, D-, D-, D-, D-

, D-460, D-, D-, D-494, D-, 

D-496, D-498, D-, D-, D-, D-

, D-, D-, D-, D-, D-, 

D-, D-, D-, D-, D-, D-

, D-, D-609, D-610, D-613, D-614, 

D-616, D-618, D-620, D-621, D-624, D-

, D-631, D-632, D-633, F-1, F-2, F-3, 

F-, F-, F-8, F-10, F-12, F-13, F-14, F-

, F-16, F-, F-18, F-20, F-21 

Rulemaking, xxiii, xxiv, xxv, xxvi, xxvii, xxviii, 

xxix, 1-1, 1-2, 1-3, 1-6, 1-9, 1-10, 1-23, 1-

26, 1-, 1-28, 1-29, 1-30, 2-12, 2-13, 3-

10, 3-32, 4-49, 4-93, 4-100, -, -2, -

8, -9, -10, -11, -12, -13, -14, -, 

-16, 8-1, 11-, 11-18, 11-21, B-20, C-2, 

C-3, C-4, C-, C-6, C-, C-8, C-9, C-12, 

C-13, C-, C-, D-1, D-3, D-4, D-, D-

, D-9, D-11, D-12, D-13, D-14, D-, D16, D-, D-18, D-19, D-20, D-21, D-, 
Index 

September 2014 10-13 185(*௅

D-26, D-33, D-, D-36, D-39, D-40, D41, D-42, D-44, D-, D-48, D-, D-, 

D-, D-, D-, D-, D-, D-61, D62, D-64, D-, D-66, D-68, D-, D-, 

D-, D-, D-80, D-81, D-82, D-83, D84, D-, D-88, D-89, D-108, D-110, D111, D-112, D-113, D-116, D-, D-118, 

D-119, D-120, D-121, D-123, D-, D-

, D-201, D-, D-206, D-208, D-218, 

D-219, D-238, D-240, D-260, D-263, D266, D-, D-299, D-306, D-, D-316, 

D-334, D-336, D-, D-360, D-368, D-

, D-394, D-404, D-, D-410, D-431, 

D-432, D-448, D-462, D-, D-, D-

, D-, D-, D-, D-, D-, 

D-, D-, D-, D-, D-, D-

, D-, D-, D-, D-, D-, 

D-, D-, D-, D-608, D-621, D628, E-9, E-, F-, F-16, F-19, H-1, H6, H-

S

Safety, xxxii, xlv, xlvi, lvii, lviii, lxiii, 1-1, 1-9, 

1-16, 1-, 2-2, 2-, 2-6, 2-12, 2-13, 2-, 

2-21, 2-23, 2-, 2-29, 2-32, 2-33, 2-34, 

2-, 2-38, 2-39, 2-40, 3-6, 3-, 3-13, 3-

, 3-39, 3-42, 3-, 3-48, 3-49, 4-2, 4-4, 

4-, 4-64, 4-66, 4-, 4-69, 4-, 4-, 

4-, 4-, 4-, 4-, 4-, 4-, 4-, 

4-80, 4-81, 4-82, 4-83, 4-84, 4-, 4-, 

4-89, 4-90, 4-93, 4-94, 4-, 4-102, 4-

104, 4-, 4-108, 4-110, -1, -, -39, 

-, -, -, -, -60, -61, -62, 

6-14, 6-, 6-, 6-, 6-60, 6-61, -4, 8-

6, 9-1, 9-3, 11-2, 11-, 11-6, 11-, 11-11, 

11-14, 11-, 11-16, 11-18, 11-19, 11-20, 

11-21, B-2, B-3, B-4, B-, B-6, B-, B-8, 

B-12, B-13, B-14, B-16, B-, B-18, B-19, 

B-20, B-21, B-22, B-23, B-, B-26, B-28, 

B-29, B-30, B-32, B-33, B-36, B-, B-38, 

B-40, B-41, B-42, D-, D-8, D-9, D-, D16, D-, D-18, D-19, D-21, D-, D-26, 

D-28, D-29, D-30, D-31, D-36, D-, D38, D-, D-, D-, D-62, D-64, D-68, 

D-69, D-, D-, D-, D-86, D-, D89, D-92, D-96, D-100, D-101, D-109, D114, D-, D-116, D-, D-118, D-, 

D-131, D-132, D-133, D-, D-139, D140, D-141, D-142, D-, D-146, D-, 

D-149, D-, D-, D-, D-160, D161, D-163, D-169, D-, D-, D-, 

D-181, D-182, D-188, D-192, D-193, D196, D-, D-198, D-, D-210, D-211, 

D-212, D-213, D-214, D-218, D-219, D230, D-, D-236, D-238, D-242, D-244, 

D-, D-264, D-, D-269, D-, D-

, D-282, D-283, D-, D-286, D-, 

D-288, D-289, D-290, D-291, D-292, D294, D-, D-296, D-, D-298, D-299, 

D-300, D-301, D-306, D-, D-311, D313, D-314, D-316, D-, D-318, D-319, 

D-320, D-321, D-323, D-324, D-, D-

, D-330, D-332, D-333, D-, D-336, 

D-, D-341, D-343, D-348, D-349, D-

, D-, D-362, D-364, D-366, D-368, 

D-, D-, D-, D-, D-, D-

, D-383, D-384, D-, D-386, D-, 

D-388, D-390, D-391, D-392, D-393, D394, D-, D-, D-398, D-399, D-400, 

D-401, D-402, D-403, D-404, D-, D-

, D-409, D-410, D-411, D-412, D-414, 

D-, D-422, D-440, D-449, D-, D-

, D-, D-461, D-464, D-466, D-468, 

D-469, D-, D-, D-484, D-494, D-

, D-498, D-, D-, D-, D-, 

D-, D-, D-, D-, D-, D-

, D-, D-, D-, D-, D-, 

D-, D-, D-, D-, D-, D-

, D-, D-, D-, D-, D-, 

D-, D-, D-, D-, D-, D-

, D-606, D-609, D-610, D-611, D-613, 
Index 

185(*௅ 10-14 September 2014 

D-616, D-618, D-621, D-623, D-626, D-

, D-632, E-4, E-13, E-, E-, E-26, 

F-8, F-11, F-13, F-14, F-, F-18, F-19, 

F-20, F-22, G-2, G-16, I-2, I-6, I-8 

Scoping, xxvi, xxvii, xxviii, lxv, lxvi, 1-9, 1-

11, 1-24, 1-, 1-30, 6-1, -16, -, 9-, 

9-6, 11-19, A-1, A-2, C-1, C-2, C-3, C-4, 

C-, C-6, C-, C-8, D-14, D-, D-41, D43, D-, D-, D-, D-, D-86, D-91, 

D-92, D-98, D-102, D-123, D-126, D-266, 

D-286, D-321, D-629 

Seismic, 2-13, 3-, 4-, 4-, 4-, 4-86, 

4-, 4-, 4-108, 4-109, B-12, B-14, B22, D-68, D-, D-, D-148, D-183, D218, D-219, D-238, D-, D-314, D-331, 

D-334, D-339, D-341, D-343, D-348, D349, D-363, D-386, D-, D-389, D-410, 

D-421, D-422, D-430, D-442, D-444, D-

, D-, D-, D-, D-, D-620, 

D-623, E-22, E-24, F-2, F-3, F-6, F-10, F11, F-12, F-, F-20 

Severe accidents, xxxiii, xlvi, xlvii, 2-40, 3-

38, 4-, 4-, 4-84, 4-, 4-86, 4-88, 4-

89, 4-90, 6-, 6-, 6-, 11-1, 11-19, B14, D-, D-104, D-, D-, D-144, D148, D-, D-190, D-218, D-264, D-, 

D-280, D-284, D-286, D-293, D-296, D-

, D-312, D-313, D-314, D-, D-318, 

D-319, D-323, D-, D-326, D-, D328, D-329, D-330, D-336, D-, D-338, 

D-339, D-340, D-341, D-344, D-346, D349, D-361, D-, D-, D-429, D-436, 

D-438, D-440, D-442, D-444, D-446, D461, D-, D-, D-616, D-620, D-632, 

F-2, F-4, F-, F-, F-9, F-13, F-, F-20 

Socioeconomic, xxxiv, xxxv, xxxvi, xlvii, xlix, 

lix, lx, 3-4, 3-, 4-6, 4-, 4-8, 4-9, 4-10, 4-

11, 4-12, 4-98, -3, -8, -9, -10, -11, 

-12, -13, -14, -, -, 6-12, 6-13, 

6-14, 6-, 6-16, 6-, 8-2, 8-3, 8-4, 8-6, 

9-2, 9-4, 9-, 11-2, 11-19, D-, D-23, D-

, D-64, D-, D-182, D-183, D-184, D-

, D-190, D-192, D-193, D-194, D-, 

D-196, D-198, D-204, D-260, D-264, D293, D-, D-346, D-462, D-491, D-498 

Solid waste, 3-, 3-36, 3-, -, -48, -

62, 6-, 6-62, 8-, 8-6, 9-3, 9-, 11-11, 

11-14, D-613, E-, E-26, E-28 

Spent fuel pool fires, xxiv, xxviii, xxxiii, xlvii, 

lxiii, lxiv, lxvi, 1-3, 1-, 4-86, 4-94, 9-2, 9-

, B-14, D-6, D-, D-, D-, D-108, 

D-113, D-114, D-, D-131, D-, D-

, D-, D-281, D-306, D-314, D-, 

D-316, D-, D-318, D-319, D-, D326, D-, D-328, D-329, D-331, D-333, 

D-334, D-, D-, D-339, D-340, D341, D-346, D-, D-, D-, D-, 

D-360, D-366, D-391, D-, D-, D418, D-419, D-420, D-423, D-424, D-, 

D-426, D-, D-428, D-429, D-431, D433, D-, D-436, D-, D-438, D-439, 

D-440, D-441, D-442, D-443, D-444, D-

, D-446, D-, D-448, D-449, D-, 

D-, D-, D-, D-494, D-, D498, D-, D-, D-, D-, D-, 

D-, D-, D-, D-, F-1, F-2, F3, F-4, F-, F-, F-9, F-10, F-11, F-12, F13, F-14, F-, F-16, F-, F-18 

Spent fuel pool leaks, xxiii, xxvi, xxxix, xlv, 

lxiii, lxvi, 1-3, 1-, 3-19, 4-20, 4-23, 4-26, 

4-, 9-2, 9-3, 9-4, 9-6, B-23, B-24, D-6, 

D-, D-, D-, D-, D-130, D-131, D-

, D-, D-196, D-214, D-220, D-221, 

D-224, D-226, D-, D-228, D-229, D230, D-232, D-234, D-, D-, D-248, 

D-386, D-428, D-430, D-, D-, D-

, D-, D-, D-, D-460, D-461, 

D-462, D-463, D-464, D-, D-466, D-

, D-468, D-469, D-, D-, D-, 

D-, D-, D-, D-, D-, D-

, D-, D-480, D-481, D-482, D-483, 

D-484, D-, D-486, D-488, D-492, D-
Index 

September 2014 10- 185(*௅

493, D-, E-1, E-, E-8, E-9, E-10, E11, E-12, E-14, E-, E-16, E-, E-18, 

E-19, E-20, E-21, E-22, E-23, E-26, E-, 

E-28 

Stormwater, li, lii, 3-, 3-21, 3-, 4-20, 4-

22, 4-23, 4-, 4-34, 4-42, 4-43, -6, -

23, -29, -30, 6-, 6-32, 6-, 11-20, D223, D-, D-228, D-232 

Surface water, xxxiv, xxxv, xxxviii, xxxix, 

xlvii, li, lix, lx, lxiii, 3-11, 3-16, 4-10, 4-22, 

4-23, 4-24, 4-, 4-29, 4-30, 4-31, 4-38, 

4-40, 4-80, 4-98, -23, -24, -, -26, 

-28, -, 6-24, 6-, 6-26, 6-, 6-28, 

6-29, 6-31, 6-34, 6-, 8-2, 8-3, 8-4, 9-2, 

9-, 11-, 11-12, 11-20, 11-21, D-, D130, D-131, D-188, D-212, D-213, D-214, 

D-220, D-222, D-223, D-224, D-, D226, D-229, D-230, D-231, D-232, D-233, 

D-, D-236, D-, D-238, D-240, D241, D-242, D-243, D-244, D-, D-246, 

D-, D-, D-300, D-330, D-334, D344, D-, D-, D-460, D-461, D-462, 

D-, D-, D-480, D-481, D-482, D-

, D-490, D-492, D-609, E-1, E-13, E14, E-, E-, E-18, E-19, E-20, E-21 

T

Tax, xxxiv, xxxv, xxxvi, 3-4, 3-6, 3-, 3-44, 

3-49, 4-6, 4-, 4-8, 4-9, -9, -10, -, 6-

13, 6-14, 6-, 6-, 8-6, D-, D-182, D183, D-184, D-, D-191, D-192, D-194, 

D-, D-196, D-, D-, D-498, D-

, D-

Terrorism, xxviii, xlvii, xlviii, lviii, lix, 4-3, 4-

91, 4-94, 4-, 4-98, 4-104, -, -, 8-

3, B-22, B-30, B-32, D-, D-149, D-, 

D-, D-, D-294, D-, D-299, D-

, D-, D-, D-, D-, D-361, 

D-366, D-, D-368, D-369, D-392, D410, D-, D-449, D-, D-498, D-, 

D-, D-, D-

Thermal impacts, xl, 3-22, 4-36, 4-39, 4-40, 

4-41, 4-42, 4-43, 4-46, 11-20, D-210, D421 

Threatened species, xli, 3-28, 11-8, 11-20 

Tornado, xlvi, lviii, 3-12, 4-, 4-, 4-, 4-

, 4-80, 4-81, 4-82, 4-84, 4-, 4-86, 4-

, 4-90, 4-104, 4-, -, 6-, 11-, 

D-298, D-313, D-314, D-324, D-342, D346, D-360, D-366, D-, D-392, D-394, 

D-410, D-496, D-, D-, F-10, G-2 

Transmission lines, 2-2, 2-4, 3-1, 3-, 3-

21, 3-22, 4-, 4-32, -3, -6, 6-6, 6-11, 

6-32, 6-38, 6-43, 6-, 11-20, D-183, D184, D-

Tribal, xxvii, 3-8, 3-13, 3-14, 3-32, 4-9, -, 

-36, 11-9, A-1, C-1, C-2, C-3, C-4, C-, 

C-11, D-, D-, D-100, D-261, D-263, 

D-, D-266, D-, D-, D-, D-



Tritium, xxxiv, lxiii, 3-19, 3-20, 4-83, 11-20, 

D-66, D-, D-, D-221, D-, D-228, 

D-234, D-240, D-, D-301, D-302, D-

, D-, D-, D-, D-, D-, 

D-481, D-, D-493, D-618, E-8, E-12, 

E-19, E-20, E-22, E-23, E-24, E-, E-26 

U

Uranium, xxiv, xxxii, xlviii, 1-, 1-23, 2-, 2-

8, 2-9, 2-10, 2-11, 2-28, 3-39, 3-40, 6-6, 

6-46, 6-, 6-61, -, 11-3, 11-8, 11-10, 

11-14, 11-16, 11-, 11-21, B-10, B-11, 

B-12, B-, D-64, D-, D-101, D-141, D-

, D-204, D-216, D-269, D-294, D-304, 

D-, D-, D-, D-399, D-403, D414, D-, D-, D-, D-491, D-496, 

D-499, D-, D-, D-, D-, D624, F-18, I-1, I-3, I-4, I-8 
Index 

185(*௅ 10-16 September 2014 

W

Waste Confidence, xxiii, xxiv, xxvii, xxviii, 

lxv, lxvi, 1-1, 1-2, 1-3, 1-4, 1-11, 1-12, 1-

22, 1-23, 1-24, 1-, 1-28, 1-30, 1-31, 4-

91, 4-100, -2, -18, 11-21, A-1, A-2, B-1, 

B-2, B-9, B-11, B-13, B-34, C-1, C-2, C-3, 

C-4, C-, C-6, C-, C-8, C-9, C-10, C-11, 

C-12, C-13, C-14, C-, C-16, C-, C18, D-1, D-2, D-3, D-4, D-, D-9, D-10, D11, D-13, D-14, D-22, D-, D-30, D-32, 

D-33, D-34, D-, D-41, D-42, D-, D-

, D-, D-, D-, D-, D-, D-, 

D-61, D-, D-, D-, D-, D-, D80, D-81, D-, D-89, D-92, D-96, D-, 

D-116, D-, D-, D-, D-183, D199, D-201, D-, D-249, D-, D-, 

D-, D-, D-, D-409, D-416, D448, D-, D-, D-, D-, D-, 

D-, D-, D-, D-606, D-608, D609, D-, D-624, D-, D-626, D-, 

D-628, D-629, D-630, D-631, E-

Wetlands, xxxiv, xxxv, lii, 3-2, 3-20, 3-21, 3-

24, 3-, 4-34, -, -28, 6-11, 6-31, 6-

32, 11-21, D-

Y

Yucca Mountain, 1-16, 1-20, 1-28, 2-40, 4-

, 4-102, -20, -61, -64, 6-20, 6-42, 6-

48, 6-61, 11-21, B-3, B-29, B-30, B-31, B34, B-, B-36, B-38, B-40, B-41, C-2, D4, D-6, D-12, D-28, D-63, D-, D-90, D106, D-, D-, D-143, D-144, D-, 

D-, D-, D-, D-, D-180, D202, D-290, D-, D-, D-, D-, 

D-, D-, D-, D-, D-381, D382, D-384, D-, D-, D-, D-, 

D-, D-, D-, D-, D-604, D-

, D-612, D-614, D-618, D-621 

Yucca Mountain EIS, -20, 6-20, 6-42, 11-

21, B-30, B-31, D-106, D-, D-, D-

, D-, D-, D-, D-, D-180 
September 2014 11-1 185(*௅

11.0 Glossary 

Accident 

See Design basis accident and severe accident

Adverse environmental impacts 

Impacts that are determined to be harmful to the environment. 

Aesthetics (visual resources) 

The natural and cultural features of the landscape that can be seen and that contribute to the 

public’s appreciative enjoyment of the environment. Visual resource or aesthetic impacts are 

generally defined in terms of a project’s physical characteristics and potential visibility and the 

extent to which the project’s presence would change the perceived visual character and quality 

of the environment in which it would be located. 

Aging management (activity) 

An application of either the aging management program or time-limited aging analysis to provide 

reasonable assurance that the intended functions of structures, systems, and components of 

spent fuel storage facilities are maintained during the license period of extended operation. 

Aging management program 

A program conducted by the licensee or certificate of compliance holder for addressing aging 

effects that may include prevention, mitigation, condition monitoring, and performance 

monitoring in accordance with the requirements of Title 10 of the Code of Federal Regulations

(CFR) PartVDQG . 

Air quality 

Assessment of the health-related and visual characteristics of the air, often derived from 

quantitative measurements of the concentrations of specific injurious or contaminating 

substances. Air quality standards are the prescribed levels of substances in the outside air that 

cannot be exceeded during a specific time in a specified area. 

Alternative 

Reasonable means, other than the proposed action, by which to achieve the same purpose and 

satisfy the same need as the proposed action. 

Aquatic biota 

An organism that lives in, on, or near the water, including fish, macroinvertebrates, zooplankton, 

phytoplankton, macrophytes, and aquatic vegetation.
Glossary 

185(*௅ 11-2 September 2014 

Aquatic ecosystem types: 

x Freshwater 

Waters that contain DVDOWFRQFHQWUDWLRQRUVDOLQLW\RIOHVVWKDQ parts per thousand (ppt) 

RU percent. 

– Lentic: Stagnant or slow-flowing fresh water (e.g., lakes and ponds). 

– Lotic: Flowing fresh water with a measurable velocity (e.g., rivers and streams). 

x Marine 

Waters that contain a salt concentration of about 30 ppt (e.g., ocean overlying the 

continental shelf and associated shores). 

x Estuarine 

Coastal bodies of water where freshwater merges with marine waters. These waterbodies 

are often semi-enclosed and have a free connection with marine ecosystems (e.g., bays, 

inlets, lagoons, and ocean-flooded river valleys). Salinity concentrations fluctuate between 

0 and 30 ppt, varying spatially and temporally due to location and tidal activity.

Aquifer 

An underground layer of permeable, unconsolidated sediments or porous or fractured bedrock 

that yields usable quantities of water to a well or spring. 

Archaeological Resources Protection Act of 1979 

A statute which requires Federal permitting for excavation or removal of archaeological 

resources from public or Native American lands. 

As low as (is) reasonably achievable (ALARA) 

Making every reasonable effort to maintain exposures to ionizing radiation as far below the dose 

limits as practical, consistent with the purpose for which the licensed activity is undertaken, 

taking into account the state of technology, the economics of improvements in relation to state 

of technology, the economics of improvements in relation to benefits to the public health and 

safety, and other societal and socioeconomic considerations, and in relation to utilization of 

nuclear energy and licensed materials in the public interest (see 10 CFR 20.1003). 

Bare fuel 

Spent fuel rods or assemblies that are separate from or can be loaded into containment 

systems such as canisters or casks. 
Glossary 

September 2014 11-3 185(*௅

Baseline 

A quantitative expression of conditions, costs, schedule, or technical progress that constitutes 

the standard against which to measure the performance of an activity. For this generic 

environmental impact statement (GEIS), the baseline is the affected environment at the 

beginning of continued storage, taking into account the environmental impacts during reactor 

operations.

Biota 

The combined flora and fauna of a region.

Boiling water reactor (BWR) 

A reactor in which water, used as both coolant and moderator, boils in the core to produce 

steam, which drives a turbine connected to an electrical generator, thereby producing electricity. 

Burnup 

A measure of how much energy is extracted from the nuclear fuel before it is removed from the 

core. Its units are gigawatt-days (GWd) per tonne of uranium (MTU) in fresh fuel. Spent fuel is 

FRQVLGHUHGWRKDYHORZEXUQXSLIWKHEXUQXSLVOHVVWKDQ*:G078

Candidate species 

Animal or plant species for which the Fish and Wildlife Service (FWS) or National Marine 

Fisheries Service (NMFS) has on file sufficient information on vulnerability and threats to 

support a proposal to list it as endangered or threatened. 

Canister 

A large rugged cylinder containing one to six dozen spent fuel assemblies. A canister, typically 

made of a corrosion-resistant metal, is filled with inert gas and bolted or welded closed. The 

sealed canister is typically emplaced inside an outer shell of steel, concrete, lead, or other 

material as part of a dry cask storage system. 

Cask 

A heavily shielded container used for the dry storage or shipment (or both) of radioactive 

materials such as spent nuclear fuel (spent fuel) or other high-level radioactive waste. Casks 

are often made from lead, concrete, or steel. Casks must meet regulatory requirements and are 

not intended for long-term disposal in a repository. 

Cladding 

The thin-walled metal tube that forms the outer jacket of a nuclear fuel rod. It prevents 

corrosion of the fuel by the coolant within the nuclear reactor and the release of fission products 

into the coolant. Stainless steel and zirconium alloys are common cladding materials. 
Glossary 

185(*௅ 11-4 September 2014 

Clean Air Act (CAA) 

Establishes national ambient air quality standards and requires facilities to comply with emission 

limits or reduction limits stipulated in State Implementation Plans (SIPs). Under this Act, 

construction and operating permits, as well as reviews of new stationary sources and major 

modifications to existing sources, are required. This statute also prohibits the Federal 

government from approving actions that do not conform to SIPs. 

Climate change (Global climate change) 

Changes in the Earth’s surface temperature thought to be caused by the greenhouse effect and 

responsible for changes in global climate patterns. The greenhouse effect is the trapping and 

buildup of heat in the atmosphere (troposphere) near the Earth’s surface. Some of the heat 

flowing back toward space from the Earth’s surface is absorbed by water vapor, carbon dioxide, 

ozone, and certain other gases in the atmosphere and then reradiated back toward the Earth’s 

surface. 

Closed-cycle cooling 

In this type of cooling-water system, the cooling water is recirculated through the condenser 

after the waste heat is removed by dissipation to the atmosphere, usually by circulating the 

water through large cooling towers constructed for that purpose. 

Code of Federal Regulations (CFR) 

The codification of the general and permanent rules published in the Federal Register by the 

executive departments and agencies of the Federal government. IWLVGLYLGHGLQWRWLWOHVWKDW

represent broad areas subject to Federal regulation. Each volume of the CFR is updated once 

each calendar year and is issued on a quarterly basis. 

Committed dose equivalent 

The dose equivalent to organs or tissues of reference that will be received from an intake of 

UDGLRDFWLYHPDWHULDOE\DQLQGLYLGXDOGXULQJWKH-year period following the uptake. 

Committed effective dose equivalent (CEDE) 

The sum of the products of the weighting factors for body organs or tissues that are irradiated 

and the committed dose equivalent to these organs or tissues. 

Compact 

A group of two or more states formed to dispose of low-level radioactive waste on a regional 

basis. The Low-Level Radioactive Waste Policy Act of 1980 encouraged states to form 

compacts to ensure continuing low-level waste disposal capacity. As of December 2000, 44 

states have formed 10 compacts. 
Glossary 

September 2014 11- 185(*௅

Confinement 

The ability of a storage system to retain radioactive material, including gases and particulates, 

within the system. 

Consolidated storage 

A spent fuel storage facility designed to store spent fuel produced from multiple nuclear power 

plants. 

Continued storage 

The time period during which spent fuel is stored after the end of the licensed life for operations 

of a nuclear reactor and prior to disposal in a permanent repository. 

Cooling system (Reactor) 

System used to remove energy from the reactor core and transfer that energy either directly or 

indirectly to the steam turbine. 

Cooling system (Spent Fuel) 

System used to remove energy from spent fuel pools that typically consists of pumps to 

circulate cooling water through the system, a purification system of filters and a demineralizer, 

and a heat exchanger (which transfers the heat from the spent fuel pool cooling system to the 

service-water system or its equivalent). 

Core damage frequency 

An expression of the likelihood that, given the way a reactor is designed and operated, an 

accident could cause the fuel in the reactor to be damaged. 

Corrective action 

Measures taken to rectify conditions adverse to quality, safety, or compliance with NRC 

requirements. 

Council on Environmental Quality (CEQ) 

Established by the National Environmental Policy Act (NEPA). Council on Environmental 

4XDOLW\UHJXODWLRQV&)53DUWV–GHVFULEHWKHSURFHVVIRULPSOHPHQWLQJ1(3$

including preparation of environmental assessments and environmental impact statements, and 

the timing and extent of public participation. As an independent regulatory body, the NRC’s 

policy is to take account of the regulations of the Council on Environmental Quality published 

1RYHPEHU)5-YROXQWDULO\WRWKHH[WHQWDSSOLFDEOH

Critical habitat 

Specific geographic areas, whether occupied by a listed species or not, that are essential for its 

conservation and that have been formally designated by rule published in the Federal Register. 
Glossary 

185(*௅ 11- September 2014 

Criticality 

The normal operating condition of a reactor, in which nuclear fuel sustains a fission chain 

reaction. A reactor achieves criticality when each fission event releases a sufficient number of 

neutrons to sustain an ongoing series of reactions. Nuclear fuel that is in storage or being 

handled is required to avoid criticality, or remain “subcritical.” 

Cultural resource (historic resource) 

The remains of past human activity and include prehistoric era and historic era archaeological 

sites, historic districts, buildings, or objects with an associated historical, cultural, 

archaeological, architectural, community, or aesthetic value. Historic and cultural resources 

also include traditional cultural properties that are important to a living community of people for 

maintaining their culture. 

Decommissioning 

The process of safely closing a nuclear power plant (or other facility where nuclear materials are 

handled) to retire it from service after its useful life has ended. This process primarily involves 

decontaminating the facility to reduce residual radioactivity and then releasing the property for 

unrestricted use (see 10 CFR 20.1003) or (under certain conditions) restricted use. This often 

includes dismantling the facility or dedicating it to other purposes. Decommissioning begins 

after the nuclear fuel, coolant, and radioactive waste are removed from the reactor. 

Decommissioning GEIS (NUREG-0586) 

A generic environmental evaluation of the scope and impact of environmental effects associated 

with the decommissioning of nuclear power reactors as residual radioactivity at the site is 

reduced to levels that allow for termination of the NRC license. 

DECON 

A method of decommissioning in which the equipment, structures, and portions of a facility and 

site containing radioactive contaminants are removed and safety buried in a low-level 

radioactive waste landfill or decontaminated to a level that permits the property to be released 

for unrestricted use shortly after cessation of operations.

Deep dose equivalent 

The dose equivalent at a tissue depth of 1 cm (0.39 in.); applies to external whole-body 

exposure. 

Department of Energy (DOE) 

The DOE is a cabinet-level agency that has both important energy- and national security-related 

missions. DOE officials oversee the laboratories that were once primarily responsible for 

creating nuclear weapons, along with implementing policies geared toward strengthening the 

United States’ sources of energy. The DOE carries out policies ranging from nuclear power to 

fossil fuels to alternative energy sources. 
Glossary 

September 2014 11- 185(*௅

Design basis events 

Conditions of normal operation, design basis accidents, external events, and natural 

phenomena, for which the plant must be designed to ensure the capability to prevent or mitigate 

the consequences of accidents that could result in potential offsite exposures. 

Design basis accident 

A postulated accident that a nuclear facility must be designed and built to withstand without loss 

to the systems, structures, and components necessary to ensure public health and safety. 

Disposal 

The act of placing unwanted materials in an area with the intent of not recovering in the future. 

Dose 

A general term which may be used to refer to the amount of energy absorbed by an object or 

person per unit mass. Known as the “absorbed dose,” this reflects the amount of energy that 

ionizing radiation sources deposit in materials through which they pass, and is measured in 

units of radiation-absorbed dose (rad). The related international system unit is the gray (Gy), 

where 1 Gy is equivalent to 100 rad. See also, total effective dose equivalent (TEDE),

committed effective dose equivalent (CEDE), and deep dose equivalent. 

Dose equivalent 

The product of the absorbed dose in tissue, quality factor, and all other modifying factors at the 

location of interest. The units of dose equivalent are the rem and Sievert (Sv). 

Dry cask storage 

A method for storing spent fuel in special containers known as casks. After fuel has been 

cooled in a spent fuel pool for at least 1 year, dry cask storage allows approximately one to six 

dozen spent fuel assemblies to be sealed in casks and surrounded by inert gas. 

Dry transfer system (DTS) 

A facility that enables retrieval of spent fuel from dry cask storage for inspection or repackaging 

without the need to return the spent fuel to a pool. Proposed designs for dry transfer systems 

consist of concrete and steel structures designed to provide both confinement and shielding 

during fuel transfer operations. 

Effective dose equivalent 

The sum of the products of the dose equivalent to the organ or tissue and the weighting factors 

applicable to each of the body organs or tissues that are irradiated. 

Effluent 

A discharge of gas or liquid into the environment, partially or completely treated or in its natural 

state. This term typically refers to wastes discharged into surface waters. 
Glossary 

185(*௅ 11-8 September 2014 

Electromagnetic fields 

The field of energy resulting from the movement of alternating electric current (AC) along the 

path of a conductor, composed of both electrical and magnetic components and existing in the 

immediate vicinity of, and surrounding, the electric conductor. Electromagnetic fields exist in 

both high-voltage electric transmission power lines and in low-voltage electric conductors in 

homes and appliances. 

Endangered species 

Animal or plant species in danger of extinction throughout all or a significant portion of its range. 

Endangered Species Act of 1973 (ESA) 

Requires consultation with the FWS DQGRUWKH1MFS to determine whether endangered or 

threatened species or their habitats will be affected by a proposed activity and what, if any, 

mitigation measures are needed to address the impacts. 

ENTOMB 

A method of decommissioning nuclear facilities in which radioactive contaminants are encased 

in a structurally long-lived material, such as concrete. The entombment structure is 

appropriately maintained and continued surveillance is carried out until the radioactivity decays 

to a level permitting unrestricted release of the property. 

Enrichment 

Increasing the proportion of uranium atoms that can be “split” by fission to release energy 

(usually in the form of heat) that can be used to produce electricity. 

Entrainment 

The incorporation of all life stages of fish and shellfish with intake water flow entering and 

passing through a cooling-water-intake structure and into a cooling-water system (40 CFR 

. 

Environmental assessment (EA) 

A concise public document that a Federal agency prepares under NEPA to provide sufficient 

evidence and analysis to determine whether a proposed action requires preparation of an 

environmental impact statement or whether a Finding of No Significant Impact can be issued. 

An EA must include brief discussions on the need for the proposed action and the 

environmental impacts of the proposed action and the no-action alternative. 

Environmental impact statement (EIS) 

A document required of Federal agencies by NEPA for major proposals or legislation that will or 

could significantly affect the environment. The primary purpose of an EIS is to serve as an 

action-forcing device to ensure that the policies and goals defined in the Act are infused into the 

ongoing programs and actions of the Federal government. An EIS provides full and fair 
Glossary 

September 2014 11-9 185(*௅

discussion of significant environmental impacts and shall inform decision-makers and the public 

of the reasonable alternatives which would avoid or minimize adverse impacts or enhance the 

quality of the human environment. The EIS should be used by Federal officials in conjunction 

with other relevant material to plan actions and make decisions. 

Environmental justice 

The fair treatment of people of all races, cultures, incomes, and educational levels with respect 

to the development, implementation, and enforcement of environmental laws, regulations, and 

policies. 

Environmental Protection Agency (EPA) 

A Federal agency, created for the purpose of promoting human health by protecting the nation’s 

air, water, and soil from harmful pollution by enforcing environmental regulations based on laws 

passed by Congress. The agency performs environmental assessments, conducts research, 

and provides education. It has the responsibility of maintaining and enforcing national 

standards under a variety of environmental laws (e.g., Clean Air Act), in consultation with State, 

Tribal, and local governments. It delegates some permitting, monitoring, and enforcement 

responsibility to States and Native American Tribes. EPA enforcement powers include fines, 

sanctions, and other measures. The agency also works with industries and all levels of 

government in a wide variety of voluntary pollution prevention programs and energy 

conservation efforts. 

EPA Air Quality Designations 

x Attainment: An EPA air quality designation for any area that meets the national primary or 

secondary ambient air quality standard for the pollutant. 

x Nonattainment: An EPA air quality designation for any area that does not meet (or that 

contributes to ambient air quality in a nearby area that does not meet) the national primary 

or secondary ambient air quality standard for the pollutant. 

x Unclassifiable: Any area that cannot be classified on the basis of available information as 

meeting or not meeting the national primary or secondary ambient air quality standard for 

the pollutant. 

Essential fish habitat (EFH) 

Those waters and substrates needed by Federally managed marine and anadromous fish for 

spawning, breeding, feeding, or growth to maturity. 

Fish and Wildlife Service (FWS) 

A Federal agency within the U.S. Department of the Interior responsible for the management of 

fish, wildlife, and natural habitats. The FWS's major responsibilities are for migratory birds, 

endangered species, certain marine mammals, and freshwater and anadromous fish. 
Glossary 

185(*௅ 11-10 September 2014 

Fuel assembly (fuel bundle) 

A structured group of fuel rods, which are long, slender, metal tubes containing pellets of 

fissionable material, which provide fuel for nuclear reactors. Depending on the design, each 

reactor vessel may have dozens of fuel assemblies (also known as fuel bundles), each of which 

may contain 200 or more fuel rods. 

Fuel cycle 

The series of steps involved in supplying fuel for nuclear power reactors include the following: 

x uranium recovery to extract (or mine) uranium ore, and concentrate (or mill) the ore to 

produce "yellowcake", 

x conversion RI\HOORZFDNHLQWRXUDQLXPKH[DIOXRULGH8), 

x enrichment to increase the concentration of uranium-8-LQ8), 

x fuel IDEULFDWLRQWRFRQYHUWHQULFKHG8)LQWRIXHOIRUQXFOHDUUHDFWRUV, 

x use of the fuel in reactors (nuclear power, research, or naval propulsion), 

x interim storage of spent fuel, 

x reprocessing of high-level waste to recover the fissionable material remaining in the spent 

fuel (currently not done in the United States), and 

x final disposition (disposal) of high-level waste. 

The NRC regulates these processes, as well as the fabrication of mixed oxide nuclear fuel, 

which is a combination of uranium and plutonium oxides. 

Fuel reprocessing (recycling) 

The processing of reactor fuel to separate the unused fissionable material from waste material. 

Reprocessing extracts isotopes from spent fuel so they can be used again as reactor fuel. 

Fugitive dust 

Particulate air pollution released to the ambient air from ground-disturbing activities related to 

construction, manufacturing, or transportation (i.e., the discharges are not released through a 

confined stream such as a stack, chimney, vent, or other functionally equivalent opening). 

Specific activities that generate fugitive dust include, but are not limited to, land-clearing 

operations, travel of vehicles on disturbed land or unpaved access roads, or onsite roads. 

Generic environmental impact statement (GEIS) 

In general, a GEIS assesses the scope and impact of environmental effects that would be 

associated with an action at numerous sites. This GEIS assesses the scope and impact of 

environmental effects associated with the continued storage of spent fuel after the licensed life 

of a nuclear power reactor. 
Glossary 

September 2014 11-11 185(*௅

Geologic repository 

An excavated, underground facility that is designed, constructed, and operated for safe and 

secure permanent disposal of high-level radioactive waste. A geologic repository uses an 

engineered barrier system and a portion of the site's natural geology, hydrology, and 

geochemical systems to isolate the radioactivity of the waste. 

Greater-than-class-C waste (GTCC) 

GTCC waste means low-level radioactive waste that exceeds the concentration limits of 

UDGLRQXFOLGHVHVWDEOLVKHGIRU&ODVV&ZDVWHLQ&)5

Greenhouse gases 

Gases that trap heat in the atmosphere. The most common greenhouse gases are carbon 

dioxide, methane, nitrous oxide, and fluorinated gases. Greenhouse gases contribute to global 

climate change. 

Groundwater 

The water found beneath the Earth’s surface, usually in porous rock formations (aquifers) or in a 

zone of saturation, which may supply wells and springs, as well as base flow to major streams 

and rivers. Generally, it refers to all water contained in the ground. 

Habitat 

Area in which a plant or animal lives and reproduces. 

Half-life 

The time in which one-half of the atoms of a particular radioactive substance disintegrate into 

another nuclear form. Measured half-lives vary from millionths of a second to billions of years. 

Also called physical or radiological half-life. 

Hardened onsite storage (HOSS) 

A term referring to a proposed strategy to enhance the safety and security of spent fuel storage 

in dry casks or vault systems. As described by proponents, HOSS is the preferred end-point of 

a process that involves moving spent fuel from dense-packed cooling pools and into dry storage 

systems at reactor sites. The HOSS concept adds berms to conventional dry storage systems 

with the intent of offering greater resistance to potential terrorist attacks using aircraft or 

conventional weapons. 

Hazardous waste 

A solid waste or combination of solid wastes that, because of its quantity, concentration, or 

physical, chemical, or infectious characteristics, may (1) cause or significantly contribute to an 

increase in mortality or an increase in serious irreversible or incapacitating reversible illness or 

(2) pose a substantial present or potential hazard to human health or the environment when 
Glossary 

185(*௅ 11-12 September 2014 

improperly treated, stored, transported, disposed of, or otherwise managed (as defined in the 

Resource Conservation and Recovery Act, as amended, Public Law 94-

High-level radioactive waste (HLW) 

The highly radioactive materials produced as byproducts of fuel reprocessing or of the reactions 

that occur inside nuclear reactors. HLW includes the following: 

x irradiated spent fuel discharged from commercial nuclear power reactors, 

x the highly radioactive liquid and solid materials resulting from the reprocessing of spent fuel, 

which contain fission products in concentration (this includes some reprocessed HLW from 

defense activities and a small quantity of reprocessed commercial HLW), and 

x other highly radioactive materials that the Commission may determine require permanent 

isolation. 

Historic property 

Any prehistoric or historic district, site, building, structure, or object included in, or eligible for 

inclusion in, the National Register of Historic Places maintained by the Secretary of the Interior. 

Historic properties also include artifacts, records, and remains that are related to and located 

within such properties. The term includes properties of traditional religious and cultural 

importance to an Indian Tribe or Native Hawaiian organization that meet the National Register 

FULWHULDVHHDOVR&)5O

Hydrology 

The study of water that considers its occurrence, properties distribution, circulation, and 

transport and includes groundwater, surface water, and rainfall. 

Impingement 

The entrapment of all life stages of fish and shellfish on the outer part of an intake structure or 

DJDLQVWDVFUHHQLQJGHYLFHGXULQJSHULRGVRIZDWHUZLWKGUDZDO&)5

Independent spent fuel storage installation (ISFSI) 

A complex designed and constructed for the interim storage of spent fuel; solid, reactor-related, 

GTCC waste; and other associated radioactive materials. A spent fuel storage facility may be 

considered independent, even if it is located on the site of another NRC-licensed facility. The 

most common design for an ISFSI, at this time, is a concrete pad with dry casks containing 

spent fuel bundles. ISFSIs are used by operating plants that require increased spent fuel 

storage capability because their spent fuel pools are nearly full. 

Institutional controls 

In the context of continued storage of spent fuel, institutional controls refers to actions taken by 

an institution (e.g., a government, corporation, or other entity) for long-term site management 
Glossary 

September 2014 11-13 185(*௅

and control of radioactive waste. Institutional controls at storage facilities include controlling site 

access, implementation of aging management programs, performing maintenance or remedial 

actions, monitoring, and controlling or remediating releases. 

Interim storage 

The storage of spent fuel, typically in dry cask storage systems, from the time it is removed from 

a spent fuel pool until disposal in a geologic repository. 

Isotope 

Two or more forms (or atomic configurations) of a given element that have identical atomic 

numbers (the same number of protons in their nuclei) and the same or very similar chemical 

properties but different atomic masses (different numbers of neutrons in their nuclei) and distinct 

physical properties. Thus, carbon-12, carbon-13, and carbon-14 are isotopes of the element 

carbon, and the numbers denote the approximate atomic masses. Among their distinct physical 

properties, some isotopes (known as radioisotopes) are radioactive because their nuclei emit 

radiation as they strive toward a more stable nuclear configuration. For example, carbon-12 

and carbon-13 are stable, but carbon-14 is unstable and radioactive. 

License amendment 

Changes to the operating license for a nuclear power plant such as a change to the technical 

specifications, system modifications, or changes to operating procedures that require approval 

by the NRC before they can be implemented by a licensee. 

License renewal 

Renewal of the operating license of a nuclear power plant or ISFSI.

License Renewal GEIS (NUREG-1437) 

A generic environmental evaluation of the scope and impact of environmental effects associated 

with the continued operation of nuclear power plants during the license renewal term. 

Licensee 

A company, organization, institution, or other entity to which the NRC or an Agreement State 

has granted a general license or specific license to construct or operate a nuclear facility, or to 

receive, possess, use, transfer, or dispose of source material, byproduct material, or special 

nuclear material. 

Licensed material 

Source material, byproduct material, or special nuclear material that is received, possessed, 

used, transferred, or disposed of under a general license or specific license issued by the NRC 

or Agreement States. 
Glossary 

185(*௅ 11-14 September 2014 

Licensing basis 

The aggregate documents or technical criteria that provides the basis upon which the NRC 

issues a license to construct or operate a nuclear facility; to conduct operations involving the 

emission of radiation; or to receive, possess, use, transfer, or dispose of source material, 

byproduct material, or special nuclear material. 

Low-income populations 

Persons whose average family income is below the poverty line. The poverty line takes into 

account family size and age of individuals in the family. In 2013, the poverty line for a family of 

four with two children below the age of 18 was $. For any family below the poverty line, 

all family members are considered to be below the poverty line. 

Low-level waste (LLW) 

A general term for a wide range of items that have become contaminated with radioactive 

material or have become radioactive through exposure to neutron radiation. The radioactivity in 

these wastes can range from just above natural background levels to much higher levels, such 

as seen in parts from inside the reactor vessel in a nuclear power reactor. 

Mitigation 

A method or process by which impacts from actions can be made less injurious to the 

environment through appropriate protective measures. 

Mixed oxide fuel (MOX) 

A type of nuclear reactor fuel (often called "MOX") that contains plutonium oxide mixed with 

either natural or depleted uranium oxide, in ceramic pellet form. Using plutonium reduces the 

amount of highly enriched uranium needed to produce a controlled reaction in commercial lightwater reactors. 

Mixed waste 

Material that contains two components: LLW and hazardous waste, as defined in EPA 

regulations. 

Monitoring 

Periodic or continuous processes and activities necessary to assess the status of the 

environment that is typically part of a structured program required or approved by a regulatory 

agency responsible for protection of human health and safety and the environment. 

Municipal solid waste 

Residential solid waste and some nonhazardous commercial, institutional, and industrial 

wastes. 
Glossary 

September 2014 11- 185(*௅

National Ambient Air Quality Standards (NAAQS) 

Air quality standards established by the Clean Air Act, as amended. The primary NAAQS 

specify maximum outdoor air concentrations of criteria pollutants that would protect the public 

health within an adequate margin of safety. The secondary NAAQS specify maximum 

concentrations that would protect the public welfare from any known or anticipated adverse 

effects of a pollutant. 

National Environmental Policy Act of 1969 (NEPA) 

An Act requiring Federal agencies to prepare a detailed statement on the environmental impacts 

of their proposed major actions that may significantly affect the quality of the human 

environment. 

National Historical Preservation Act of 1966 (NHPA) 

6HFWLRQRIWKH1+3$DGGUHVVHVWKHLPSDFWVRI)HGHUDOXQGHUWDNLQJVRQKLVWRULFSURSHUWLHV. 

Undertakings are defined in the NHPA as any project or activity that is funded or under the 

direct jurisdiction of a Federal agency, or any project or activity that requires a Federal permit, 

OLFHQVHRUDSSURYDOVHHDOVR&)5\

National Marine Fisheries Service (NMFS) 

A Federal agency responsible for the stewardship and management of the nation's living marine 

resources and their habitat within the United States' Exclusive Economic Zone, which extends 

VHDZDUGQDXWLFDOPLOHVIURPWKHFRDVWOLQHDERXWNLORPHWHUV The NMFS is a division 

of the National Oceanic and Atmospheric Administration within the Department of Commerce. 

Natural phenomena 

Events that occur in nature such as earthquakes, tornadoes, hurricanes, floods, and tsunamis. 

No-action alternative 

In general, the no-action alternative of an EIS assumes that the proposed action would not take 

place; the resulting environmental impacts from taking no action would be compared with the 

impacts of permitting the proposed action or an alternative action. For this GEIS, the no-action 

alternative represents a decision by the Nuclear Regulatory Commission to not proceed with a 

rulemaking that codifies the impact determinations in this GEIS. 

Nonradioactive nonhazardous waste 

Waste that is neither radioactive nor hazardous and typically deposited in a landfill. 

Nuclear fuel 

Fissionable material that has been enriched to a composition that will support a self-sustaining 

fission chain reaction when used to fuel a nuclear reactor, thereby producing energy (usually in 

the form of heat or useful radiation) for use in other processes. 
Glossary 

185(*௅ 11- September 2014 

Nuclear power plant 

A facility that uses a nuclear reactor to generate electricity. 

Nuclear reactor 

A device in which nuclear fission may be sustained and controlled in a self-supporting nuclear 

reaction. There are many types of reactors, but all incorporate certain features, including 

fissionable material or fuel, a moderating material (unless the reactor is operated on fast 

neutrons), a reflector to conserve escaping neutrons, provisions of removal of heat, measuring 

and controlling instruments, and protective devices. The reactor is the principal component of a 

nuclear power plant. 

Nuclear waste 

A subset of radioactive waste that includes unusable byproducts produced during the various 

stages of the nuclear fuel cycle, including recovery (or extraction), conversion, and enrichment 

of uranium; fuel fabrication; and use of the fuel in nuclear reactors. Specifically, these stages 

produce a variety of nuclear waste materials, including uranium mill tailings, depleted uranium, 

and spent (depleted) fuel, all of which are regulated by the NRC. By contrast, "radioactive 

waste" is a broader term, which includes all wastes that contain radioactivity, regardless of how 

they are produced. 

Occupational dose 

The dose received by an individual in the course of employment in which the individual’s 

assigned duties involves exposure to radiation or to radioactive material. Occupational dose is 

restricted by NRC regulations under 10 CFR Part 20, Subpart C. 

Occupational Safety and Health Administration (OSHA) 

A Federal agency in the Department of Labor whose mission is to prevent work-related injuries, 

illnesses, and deaths. Congress created OSHA under the Occupational Safety and Health Act 

RQ'HFHPEHU

Once-through cooling system 

In this cooling system, circulating water for condenser cooling is obtained from an adjacent body 

of water, such as a lake or river, passed through the condenser tubes, and returned directly at a 

higher temperature to the adjacent body of water. 

Population dose 

Dose received collectively by a population. 

Power block 

The buildings and components directly involved in generating electricity at a power plant. At a 

nuclear power plant, the components of the power block vary with the reactor design, but 

always include the reactor and turbine building, and usually include several other buildings that 
Glossary 

September 2014 11- 185(*௅

house access, reactor auxiliary, safeguards, waste processing, or other nuclear generation 

support functions. 

Pressurized water reactor (PWR) 

A power reactor in which thermal energy is transferred from the core to a heat exchanger by 

high-temperature water kept under high pressure in the primary system. Steam is generated in 

the heat exchanger in a secondary circuit. 

Private Fuel Storage Facility (PFSF) 

A proposed away-from-reactor ISFSI on the Reservation of the Skull Valley Band of Goshute 

Indians in Tooele County, Utah. The NRC analyzed the environmental impacts of constructing 

and operating the PFSF LQ185(*௅

Probability weighted consequence 

A measure of the severity of an environmental impact or accident that accounts for both the 

likelihood that the event occurs and the consequences if the event does occur. Where both the 

likelihood and consequences (e.g., cumulative dose, cost to the local economy, or area of land 

contamination) can be quantified, it is the product of these two factors. 

Proposed species 

Animal or plant species that is proposed for inclusion under Section 4 of the Endangered 

Species Act. 

Radiation (ionizing radiation) 

Alpha particles, beta particles, gamma rays, x-rays, neutrons, high-speed electrons, high-speed 

protons, and other particles capable of producing ions, which are atoms or molecules with a net 

electric charge due to the loss or gain of one or more electrons. Radiation, as used in the 

NRC’s standards for radiation protection, 10 CFR Part 20, does not include natural sources of 

radiation such as soil or the sun or non-ionizing radiation, such as radio- or microwaves, or 

visible, infrared, or ultraviolet light (see also 10 CFR 20.1003). 

Radioactivity 

The property possessed by some elements (e.g., uranium) of spontaneously emitting energy in 

the form of radiation as a result of the decay (or disintegration) of an unstable atom. 

Radioactivity is also the term used to describe the rate at which radioactive material emits 

radiation. Radioactivity is measured in curies (Ci) and becquerels (Bq). 

Radioisotope (radionuclide) 

An unstable isotope of an element that decays or disintegrates spontaneously, emitting 

radiation. ASSUR[LPDWHO\QDWXUDO and artificial radioisotopes have been identified. 
Glossary 

185(*௅ 11-18 September 2014 

Refurbishment 

Repair or replacement of spent fuel storage systems, structures, and components. 

Remediation 

The restoration of a site by removal of pollution or contamination from the site environment, 

consistent with regulatory standards, for the protection of public health and safety and the 

environment. 

Repackaging 

5HSODFHPHQWRIWKHFDQLVWHUDQGRUFDVNZKLFKKRXVHVVSHQWIXHODVVHPEOLHV

Repository 

See Geologic repository. 

Reprocessing 

See Fuel reprocessing. 

Risk 

The combined probability of an accident with the consequences of that accident. In other 

words, the NRC examines the following questions: (1) What can go wrong? (2) How likely is it? 

(3) What are the consequences? Where both the likelihood and consequences can be 

quantified, it is the product of the likelihood and consequences. See also Probability weighted 

consequence. More information can be found at KWWSZZZQUFJRYDERXWQUFUHJXODWRU\ULVNinformed.html.

Risk-informed regulation 

An approach to regulation taken by the NRC, which is guided by an assessment of safety 

significance or relative risk. This approach ensures that the regulatory burden imposed by an 

individual regulation or process is appropriate to its importance in protecting the health and 

safety of the public and the environment. 

Risk-significant 

"Risk-significant" can refer to a facility’s system, structure, component, or accident sequence 

that exceeds a predetermined limit for contributing to the risk associated with the facility. The 

term also describes a level of risk exceeding a predetermined "significance" level. 

Rulemaking 

The process by which NRC formulates, amends, or repeals regulations. 

Safeguards 

The use of material control and accounting programs to verify that all special nuclear material is 

properly controlled and accounted for, as well as the physical protection (or physical security) 
Glossary 

September 2014 11-19 185(*௅

equipment and security forces. Requirements for physical protection of plants and materials are 

found in 10 CFR PartVDQG

Safety-related 

Systems, structures, components, procedures, and controls (of a facility or process) that are 

relied upon to remain functional during and following design basis events. Their functionality 

ensures that key regulatory criteria, such as levels of radioactivity released, are met. 

SAFSTOR 

A method of decommissioning in which a nuclear facility is placed and maintained in a condition 

that allows the facility to be safely stored and subsequently decontaminated (deferred 

decontamination) to levels that permit release for unrestricted use. 

Scoping 

An early and open process for determining the scope of issues to be addressed and for 

identifying the significant issues related to a proposed action. During scoping, an agency will 

solicit stakeholder input. 

Severe accident (beyond-design-basis accident) 

Accidents that may challenge safety systems at a level much higher than expected. See also 

Design basis accident. 

Shielding 

Any material or obstruction that absorbs radiation and thus tends to protect personnel or 

materials from the effects of ionizing radiation. Shielding also refers to the resulting ability of a 

system to limit the dose rate at designated locations to acceptable regulatory limits. 

Small modular reactors 

Nuclear power plants that are smaller in size (e.g., 300 MW(e)) than current generation 

baseload plants (1,000 MW(e) or higher). These compactly designed reactors are factoryfabricated and can be transported by truck or rail to a nuclear power site. 

Socioeconomic 

Social and economic characteristics of a human population. Includes both the social impacts of 

economic activity and the economic impacts of social activity. 

Spent fuel (spent nuclear fuel) 

Nuclear reactor fuel that has been removed from a nuclear reactor because it can no longer 

sustain power production for economic or other reasons. 
Glossary 

185(*௅ 11-20 September 2014 

Spent fuel pool 

An underwater storage and cooling facility for spent fuel assemblies that have been removed 

from a reactor. 

Stormwater 

Stormwater runoff, snowmelt runoff, and surface runoff and drainage. 

Surface water 

Water on the Earth’s surface that is directly exposed to the atmosphere, as distinguished from 

water in the ground (i.e., groundwater). 

Terrestrial 

Belonging to or living on land. 

Thermal impacts 

Impacts to the environment, typically aquatic ecosystems, that result from the release of heat 

energy. 

Threatened species 

Animal or plant species likely to become endangered within the foreseeable future throughout 

all or a significant portion of its range. Requirements for declaring a species threatened are 

contained in the Endangered Species Act. 

Total effective dose equivalent (TEDE) 

Sum of the effective dose equivalent (for external exposure) and the CEDE (for internal 

exposure). 

Transmission line 

A set of conductors, insulators, supporting structures, and associated equipment used to move 

large quantities of power at high voltage, usually over long distances between a generating or 

receiving point and major substations or delivery points. 

Tritium 

A radioactive isotope of hydrogen with one proton and two neutrons. It decays by beta 

emission, which is the emission of a very low energy beta particle, and transforms to stable, 

nonradioactive helium. It has a radioactive half-OLIHRIDERXW\HDUV:DWHUFRQWDLQLQJ

tritium is normally released from nuclear power plants under controlled, monitored conditions 

that the NRC mandates to protect public health and safety. The NRC evaluates abnormal 

releases of tritium-contaminated water. More information about tritium from nuclear power 

plants can be found at KWWSZZZQUFJRYUHDGLQJ-UPGRFFROOHFWLRQVIDFW-VKHHWVWULWLXPradiationfs.html. 
Glossary 

September 2014 11-21 185(*௅

Uranium 

A radioactive element with the atomic number 92 and, as found in natural ores, an atomic 

weight of approximately 238. The two principal natural isotopes are uranium-SHUFHQWof 

natural uranium) and uranium-238 (99.3 percent of natural uranium). Natural uranium also 

includes a minute amount of uranium-234. Uranium-LVWKHSULPDU\LVRWRSHXVHGWRSURGXFH

a chain reaction in a nuclear power reactor. Natural uranium must be processed, or enriched, to 

increase the concentration of uranium-WREHXVHGDVIXHOIRUDQXFOHDUSRZHUUHDFWRU

Waste classification (classes of waste) 

Classification of LLW according to its radiological hazard. The classes include Class A, B, and 

&ZLWK&ODVV$EHLQJWKHOHDVWKD]DUGRXVDQGDFFRXQWLQJIRUSHUFHQWRI//:. As the waste 

class and hazard increase, the regulations established by the NRC require progressively greater 

controls to protect the health and safety of the public and the environment. 

Waste Confidence 

Historically, Waste Confidence has been the NRC’s generic determination regarding the safety 

and environmental impacts of storing spent fuel beyond the licensed life for operations of a 

nuclear power plant. As part of this rulemaking, the name used for the rule will be changed from 

“Waste Confidence” to “Continued Storage.” 

Waste, radioactive 

Radioactive materials at the end of a useful life cycle or in a product that is no longer useful and 

should be properly disposed. 

Wetlands 

Areas that are inundated or saturated by surface water or groundwater and that typically support 

vegetation adapted for life in saturated soils. Wetlands generally include swamps, marshes, 

bogs, and similar areas (e.g., sloughs, potholes, wet meadows, river overflow areas, mudflats, 

natural ponds). 

Yucca Mountain 

Yucca Mountain, Nevada, was the DOE’s proposed location for a geologic repository for spent 

fuel and HLW. After the DOE requested to withdraw the application for the Yucca Mountain site 

in 2010 and the NRC’s Atomic Safety and Licensing Board dismissed the proceeding, the U.S. 

Court of Appeals in 2013 ordered the NRC resume its license review and the Commission 

complied. Site selection remains an ongoing process. 

Yucca Mountain EIS 

The environmental review prepared by the DOE that discusses the potential impacts from 

constructing, operating and monitoring, and eventually closing a geologic repository at Yucca 

Mountain in southern Nevada for the disposal of spent fuel and HLW.

Appendix A 

–

Scoping Comments 

September 2014 A-1 185(*௅

Appendix A 

Scoping Comments 

In this appendix, the U.S. Nuclear Regulatory Commission (NRC) incorporates, by reference, 

the Waste Confidence Generic Environmental Impact Statement Scoping Process Summary 

Report (NRC 2013a), which was prepared by the NRC in response to comments received on 

the scope of the environmental review. The NRC issued the Scoping Summary Report on 

March 4, 2013. 

The Scoping Summary Report is available for public inspection in the NRC Public Document 

5RRPORFDWHGDW2QH:KLWH)OLQW1RUWK5RFNYLOOH3LNH5RFNYLOOH0DU\ODQGRU

from the NRC’s Agencywide Documents Access and Management System (ADAMS). The 

ADAMS Public Electronic Reading Room is accessible at http://www.nrc.gov/reading 

rm/adams/web-based.html. The Scoping Summary Report is listed under Accession No. 

0/$3HUVRQVZKRGRQRWKDYHDFFHVVWR$'$06RUZKRHQFRXQWHUSUREOHPVLQ

accessing the documents located in ADAMS should contact the NRC’s Public Document Room 

reference staff by telephone at 1---4209 or 301--RUE\H-mail at pdr@nrc.gov. 

2Q2FWREHUWKH15&SXEOLVKHGLQWKHFederal Register a Notice of Intent to prepare 

an environmental impact statement and conduct scoping, “Consideration of Environmental 

Impacts of Temporary Storage of Spent Fuel After Cessation of Reactor Operation” 

( FR ). The notice described the NRC’s intent to prepare a generic environmental 

impact statement (GEIS) and conduct webcast public scoping meetings and webinars and 

requested comments on the scope of the GEIS. Through the notice, the NRC invited Federal, 

Tribal, State, and local governments; organizations; and members of the public to provide 

comments on the scope of the GEIS no later than January 2, 2013. 

'XULQJWKH-day scoping period, the NRC held two public webcast scoping meetings and two 

scoping webinars. The meetings and webinars each began with a slide presentation by NRC, 

which was followed by a question-and-answer period DQGDEORFNRI time dedicated to listening 

to and transcribing public scoping comments. The NRC considered all comments received 

during the scoping meetings and webinars and all written comments submitted in-person at the 

November 14, 2012 afternoon meeting. Appendix C provides the ADAMS accession numbers 

for the meeting summaries. 

In addition, the NRC received hundreds of written comment letters through mail, fax, and 

www.regulations.gov 'RFNHW,'15&–2012–0246) during the comment period. Comments 

received after the January 2, 2013 closing date were considered where practicable. The NRC 
Appendix A 

185(*௅ A-2 September 2014 

reviewed and considered written comments together with the comments received during the 

public meetings and webinars. Individual comments each received a unique comment 

LGHQWLILFDWLRQFRGHWRHQVXUHWKDWHDFKFRPPHQWFRXOGEHWUDFNHGDQGUHFHLYHGDUHVSRQVH

Comments were consolidated and categorized according to subject matter or topic. The 

Scoping Summary Report contains the NRC responses to these grouped comments. 

Separately, the NRC published a document containing the text of the comments, Scoping 

Comments on the Waste Confidence Generic Environmental Impact Statement (NRC 2013b). 

This document contains a table that identifies the scoping comments made in each category 

and provides those scoping comment excerpts organized by scoping comment category. 

As a result of the scoping process, the NRC identified and eliminated peripheral issues that are 

not covered in the GEIS. The Scoping Summary Report provides responses that either discuss 

why particular topics or concerns are outside the scope of the GEIS or indicates concerns or 

topics that are in scope and are evaluated in the GEIS. 

Further detail regarding scoping, public comments received, and the NRC’s responses can be 

found in the full text of the Scoping Summary Report (NRC 2013a). Comments received on the 

draft GEIS are included in Appendix D of this GEIS. 

References 

)52FWREHU3&RQVLGHUDWLRQRI(QYLURQPHQWDO,PSDFWVRI7HPSRUDU\

Storage of Spent Fuel After Cessation of Reactor Operation.” Federal Register. U.S. Nuclear 

Regulatory Commission, Washington, D.C. 

NRC (U.S. Nuclear Regulatory Commission). 2013a. “Waste Confidence Generic 

Environmental Impact Statement Scoping Process Summary Report.” Washington, D.C. 

Accession No. 0/$. 

NRC (U.S. Nuclear Regulatory Commission). 2013b. “Scoping Comments on the Waste 

Confidence Generic Environmental Impact Statement.” Washington, D.C. Accession No. 

ML13060A130. 
Appendix B 

–

Technical Feasibility of Continued Storage and 

Repository Availability 

September 2014 B-1 NUREG-2157 

Appendix B 

Technical Feasibility of Continued Storage and 

Repository Availability 

B.1 Introduction 

In this Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel

(GEIS), the U.S. Nuclear Regulatory Commission (NRC) addresses the environmental impacts 

of continuing to store spent nuclear fuel (spent fuel) at a reactor site or at an away-from-reactor 

storage facility, after the end of a reactor’s licensed life for operation until final disposition in a 

geologic repository (“continued storage”). This GEIS provides a regulatory basis for the NRC’s 

proposed amendment to Title 10 of the Code of Federal Regulations (CFR) Part 51. 

Historically, past Waste Confidence proceedings included a Decision with five findings that 

addressed technical feasibility of a mined geologic repository, the degree of assurance that 

disposal would be available by a certain time, and the degree of assurance that spent fuel and 

commercial high-level waste could be managed safely without significant environmental impacts 

for a certain period beyond the expiration of plants’ operating licenses. Preparation of and 

reliance upon a GEIS is a fundamental departure from the approach used in past Waste 

Confidence proceedings. This GEIS acknowledges the uncertainties in the Commission’s 

prediction of repository availability and provides an environmental analysis of three possible 

storage timeframes. To this end the GEIS considers impacts for three possible timeframes 

constrained by repository availability, including the impacts from indefinite storage, should a 

repository never become available. 

The NRC’s underlying conclusions regarding the technical feasibility of continued storage and a 

repository continue to undergird its environmental analyses. These underlying conclusions, 

which are relevant to an analysis of the potential environmental impacts assessed in this GEIS, 

are discussed as two broad issues in this appendix: the NRC’s technical information regarding 

the availability of a repository for disposal of spent fuel generated in a power reactor (Section 

B.2) and the technical feasibility of safe storage of spent fuel in an at-reactor or away-fromreactor storage facility until sufficient repository capacity becomes available (Section B.3). 

These two broad issues were addressed in the five findings contained in the Waste Confidence 

Decision from past Waste Confidence proceedings; this appendix addresses these issues under 

two broad topic areas rather than five findings. Section B.4 provides a summary of the 

conclusions reached in this appendix. 
Appendix B 

NUREG-2157 B-2 September 2014 

B.2 Repository will be Available to Dispose of Spent Fuel 

Based on the analysis below and elsewhere in this GEIS, the NRC believes that the most-likely 

scenario is that a repository will become available to dispose of spent fuel by the end of the 

short-term timeframe (within 60 years of the end of a reactor’s licensed life for operation). The 

NRC’s belief is based on the resolution of two questions: whether a repository is technically 

feasible and, if so, how long will it take to site, license, construct, and open a repository. 

“Technical feasibility” simply means whether a geologic repository is technically possible using 

existing technology (i.e., without any fundamental breakthroughs in science and technology). If 

technically feasible, then the question becomes what is a reasonable timeframe for the siting, 

licensing, construction, and opening of a geologic repository. Both questions are discussed in 

detail below in Sections B.2.1 (Technical Feasibility of a Repository) and B.2.2 (Availability of a 

Repository). 

B.2.1 Technical Feasibility of a Repository 

The Commission has consistently determined that current knowledge and technology support 

the technical feasibility of deep geologic disposal. In its original 1984 Waste Confidence 

proceeding, the NRC stated that “[t]he Commission finds that safe disposal of [high-level 

radioactive waste and spent nuclear fuel] is technically possible and that it is achievable using 

existing technology” (49 FR 34658) (emphasis added). The Commission then stated: “Although 

a repository has not yet been constructed and its safety and environmental acceptability 

demonstrated, no fundamental breakthrough in science or technology is needed to implement a 

successful waste disposal program.” Although the Commission has conducted Waste 

Confidence proceedings since 1984, this focal point—whether a fundamental breakthrough in 

science or technology is needed—continues to guide the Commission’s consideration of the 

feasibility of spent fuel disposal. Since 1984, the technical feasibility of a geological repository 

has moved significantly beyond a theoretical concept. 

Today, the consensus within the scientific and technical community engaged in nuclear waste 

management is that safe geologic disposal is achievable with currently available technology 

(see, e.g., Blue Ribbon Commission on America’s Nuclear Future [BRC 2012], Section 4.3). 

Currently, 25 countries, including the United States, are considering disposal of spent or 

reprocessed nuclear fuel in deep geologic repositories. Repository programs in other countries, 

which continue to provide additional information useful to the U.S. program, are actively 

considering crystalline rock, clay, and salt formations as repository host media (IAEA 2005). 

Many of these programs have researched these geologic media for several decades. 

Ongoing research in both the United States and other countries supports a conclusion that 

geological disposal remains technically feasible and that acceptable sites can be identified. 

After decades of research into various geological media, no insurmountable technical or 

scientific problem has emerged to challenge the conclusion that safe disposal of spent fuel and 
Appendix B 

September 2014 B-3 NUREG-2157 

high-level radioactive waste can be achieved in a mined geologic repository. Over the past two 

decades, significant progress has been made in the scientific understanding and technological 

development needed for geologic disposal. There is now a better understanding of the 

processes that affect the ability of repositories to isolate waste over long periods (e.g., the 

International Atomic Energy Agency’s [IAEA’s] Scientific and Technical Basis for the Geologic 

Disposal of Radioactive Wastes, Technical Reports Series No. 413 [IAEA 2003a] and Ahn and 

Apted’s Geological Repository Systems for Safe Disposal of Spent Nuclear Fuels and 

Radioactive Wastes [Ahn and Apted 2010]). 

Further, the ability to characterize and quantitatively assess the capabilities of geologic and 

engineered barriers has been repeatedly demonstrated (see the Organisation for Economic 

Cooperation and Development, Nuclear Energy Agency’s Lessons Learnt from Ten 

Performance Assessment Studies [NEA 1997]). In addition, specific sites have been 

investigated and extensive experience has been gained in underground engineering (see 

IAEA’s Radioactive Waste Management Studies and Trends, IAEA/WMDB/ST/4 [IAEA 2005] 

and The Use of Scientific and Technical Results from Underground Research Laboratory 

Investigations for the Geologic Disposal of Radioactive Waste [IAEA 2001]). These advances 

and others throughout the world (e.g., IAEA’s Joint Convention on Safety of Spent Fuel 

Management and on Safety of Radioactive Waste Management, INFCIRC/546 [IAEA 1997]) 

continue to confirm the soundness of the basic concept of deep geologic disposal (IAEA 1997). 

In the United States, the technical approach for safe high-level radioactive waste disposal has 

remained unchanged for several decades—a deep geologic repository containing natural 

barriers to hold canisters of high-level radioactive waste with additional engineered barriers to 

further retard radionuclide release. Although some elements of this technical approach have 

changed in response to new knowledge, safe disposal remains feasible with current technology. 

The recent report by the Blue Ribbon Commission on America’s Nuclear Future (BRC 2012) 

supported geologic disposal by concluding that: 

geologic disposal in a mined repository is the most promising and technically 

accepted option available for safely isolating high-level nuclear wastes for very 

long periods of time. This view is supported by decades of expert judgment and 

by a broad international consensus. All other countries with spent fuel and highlevel waste disposal programs are pursuing geologic disposal. The United 

States has many geologic media that are technically suitable for a repository. 

In addition, support for the feasibility of geologic disposal can be drawn from experience gained 

from the review of the U.S. Department of Energy’s (DOE’s) license application for a high-level 

nuclear waste repository at Yucca Mountain, Nevada (DOE 2008a). On June 3, 2008, the DOE 

submitted an application for a construction authorization to the NRC, and on September 8, 

2008, the NRC notified DOE that it found the application acceptable for docketing 

(73 FR 53284) and began its review. DOE subsequently filed a motion with an NRC Atomic 

Safety and Licensing Board seeking permission to withdraw the license application 
Appendix B 

NUREG-2157 B-4 September 2014 

(NRC 2010a). In recognition of budgetary limitations, the Commission directed the Atomic 

Safety and Licensing Board to complete all necessary and appropriate case management 

activities, and the Atomic Safety and Licensing Board suspended the proceeding. The NRC 

staff completed three technical review documents (i.e., NRC 2011a,b,c) covering the operational 

period and the postclosure period (i.e., the period after permanent closure of the repository) and 

one safety evaluation report on general information (NRC 2010b). The NRC staff’s technical 

review did not identify any issues that would challenge the feasibility of geological disposal as a 

general matter. However, these technical reports did not include conclusions as to whether or 

not DOE’s proposed Yucca Mountain repository satisfies the Commission’s regulations and do 

not constitute a final judgment or determination of the acceptability of the DOE construction 

application. 

In August 2013, the U.S. Court of Appeals for the District of Columbia Circuit (Court of Appeals) 

issued a writ of mandamus and directed the NRC to resume the licensing process for DOE’s 

license application. In response, the Commission directed the NRC staff to complete and issue 

the safety evaluation report associated with the license application (NRC 2013). Currently, the 

NRC is working on completing its safety review of DOE’s license application and plans to 

publish the remaining volumes of its safety evaluation report by January 2015. 

The technical feasibility of a deep geologic repository is further supported by current DOE 

defense-related activities. The DOE sited and constructed, and since March 1999 has been 

operating, a deep geologic repository for defense-related transuranic radioactive wastes near 

Carlsbad, New Mexico. At this site, the DOE has successfully disposed of transuranic waste 

from nuclear weapons research and testing operations. This Waste Isolation Pilot Plant (WIPP) 

is located in the Chihuahauan Desert of southeastern New Mexico, approximately 42 km (26 mi) 

east of Carlsbad. The facility is used to store transuranic waste from nuclear weapons research 

and testing operations from past defense activities. Project facilities include mined disposal 

rooms 655 m (2,150 ft) underground. 

The NRC recognizes the incident at WIPP on February 14, 2014, which resulted in the release 

of americium and plutonium from one or more transuranic (TRU) waste containers into the 

environment. Trace amounts of americium and plutonium are believed to have leaked through 

unfiltered exhaust ducts and escaped aboveground. No personnel were determined to have 

received external contamination; however, 21 individuals were identified through bioassay to 

have initially tested positive for low level amounts of internal contamination. No adverse health 

impacts have been reported. The DOE has issued a Phase 1 accident report on the incident 

(DOE 2014). Despite the event, the NRC continues to conclude that a repository is technically 

feasible. 

In January 2013, the DOE released Strategy for the Management and Disposal of Used Nuclear 

Fuel and High-Level Radioactive Waste, a response to the Blue Ribbon Commission on 

America’s Nuclear Future’s report (DOE 2013). In this strategy document, DOE presents a 
Appendix B 

September 2014 B-5 NUREG-2157 

framework for “moving toward a sustainable program to deploy an integrated system capable of 

transporting, storing, and disposing of [spent] nuclear fuel and high-level radioactive waste from 

civilian nuclear power generation...” (DOE 2013). This new DOE strategy includes a nuclear 

waste-management system consisting of a pilot interim storage facility, a larger full-scale interim 

storage facility, and a geologic repository. U.S. policy remains that geologic disposal is the 

appropriate long-term solution for disposition of spent fuel and high-level radioactive waste. 

Finally, the activities of European countries support the technical feasibility of a deep geologic 

repository. In late 2012, a Finnish nuclear-waste-management company (Posiva) submitted a 

construction license application for a geological repository for spent fuel to Finland’s Radiation 

and Nuclear Safety Authority, and in spring 2011, Swedish nuclear authorities accepted an 

application from the Swedish Nuclear Fuel and Waste Management Company for permission to 

build a repository for spent fuel. Based on the national and international research, proposals, 

and experience with geologic disposal, the NRC concludes that a geologic repository continues 

to be technically feasible. 

B.2.2 Availability of a Repository 

Given the consensus that geologic repositories are technically feasible, experience to date is 

also relevant in determining the timeframe to successfully site, license, construct, and open a 

repository. Of the 24 countries other than the United States considering disposal of spent or 

reprocessed nuclear fuel in deep geologic repositories, 10 have established target dates for the 

availability of a repository.1 The majority of the 14 countries with no established target date for 

repository availability rely on centralized interim storage, which may include a protracted period 

of at-reactor storage before shipment to a centralized facility. 

While some countries have struggled with specific implementation issues, the international 

consensus regarding an approach to disposal in a deep geologic repository and a reasonable 

timeframe for a repository to become available has not been abandoned. 

In 1997, the United Kingdom rejected an application for the construction of a rock 

characterization facility at Sellafield, leaving the country without a path forward for long-term 

management or disposal of intermediate-level waste or spent fuel. In 1998, an inquiry by the 

United Kingdom House of Lords endorsed geologic disposal but specified that public 

acceptance was required. As a result, the United Kingdom Government embraced a repository 

plan based on the principles of voluntarism and partnership between communities and 

 

1 The three countries with target dates that plan direct disposal of spent fuel are: Czech Republic (2050), 

Finland (2020), and Sweden (2025). The seven countries with target dates for disposal of reprocessed 

spent fuel and high-level radioactive waste are: Belgium (2035), China (2050), France (2025), Germany 

(2025), Japan (2030s), Netherlands (2103), and Switzerland (2042). 
Appendix B 

NUREG-2157 B-6 September 2014 

implementers. This led to the initiation of a national public consultation and major structural 

reorganization within the United Kingdom program. In 2008, the UK Government called for 

potential volunteers to host the repository and was expecting the repository would open around 

2040 (MRWS 2012). In 2013, the Cumbria County Council voted to withdraw from the United 

Kingdom process to find a host community for an underground radioactive waste disposal 

facility and to end the site-selection process in West Cumbria. In responding to the outcome of 

the votes in West Cumbria, the Secretary of State for Energy and Climate Change published a 

Written Ministerial Statement on January 31, 2013, that made clear that the United Kingdom 

Government remains committed to geological disposal for the safe and secure management of 

higher activity radioactive waste (DECC 2013) . In July 2014, the United Kingdom continued to 

support geological disposal and provided a revised policy framework for implementing 

geological disposal that favors a voluntarist approach based on working with communities that 

are willing to participate in the siting process (DECC 2014). The formal process for working with 

communities is expected to begin in 2016. 

In Germany, a large salt dome at Gorleben had been under study since 1977 as a potential 

spent fuel repository. After suspension of exploration in 2000, Germany resumed exploration of 

Gorleben as a potential spent fuel repository in 2010. In July 2013, the Site Selection Act 

became effective in Germany. Currently, a 33-member commission made up of representatives 

from societal groups, academia, and the German government is preparing proposals for site 

selection procedures, which are due by the end of 2015. 

Initial efforts in France during the 1980s also failed to identify potential repository sites, using 

solely technical criteria. Failure of these attempts led to the passage of nuclear waste 

legislation that prescribed 15 years of research. Reports on generic disposal options in clay and 

granite media were prepared and reviewed by the French Nuclear Safety Authority in 2005. In 

2006, the French Parliament passed new legislation designating a single site for deep geologic 

disposal of intermediate- and high-level radioactive waste. This facility, to be located near the 

town of Bure in northeastern France, is scheduled to open in 2025, about 34 years after 

passage of the original Nuclear Waste Law of 1991, and 19 years after site selection. On May 

6, 2014, the French National Agency for Radioactive Waste Management (ANDRA) announced 

the actions it intends to take resulting from recent public debate on geological disposal. ANDRA 

announced plans for a pilot facility and improvements for greater public involvement. ANDRA 

anticipates completion of the license application at the end of 2017 and, subject to approvals, 

construction of the facility could begin in 2020 and a pilot phase could begin in 2025. 

In Switzerland, after detailed site investigations in several locations, the Swiss National 

Cooperative for Radioactive Waste Disposal proposed, in 1993, a deep geologic repository for 

low- and intermediate-level waste at Wellenberg. In 1998, Swiss authorities found that technical 

feasibility of the disposal concept had been successfully demonstrated; however, in 2002, a 

public cantonal referendum rejected the proposed repository. Despite difficulties with public 

acceptance, Swiss authorities have gathered more than 25 years of high-quality field and 
Appendix B 

September 2014 B-7 NUREG-2157 

laboratory research and are anticipating constructing and operating a deep geologic repository 

after 2040, less than 30 years from today. A site selection plan was approved by the Federal 

Council in 2008 and three geological siting areas were identified by 2011 for deep geological 

disposal of high-level waste. A second phase is currently underway and involves regional 

participation and comparative studies with safety as the decision criterion. 

In 1998, an independent panel reported to the Governments of Canada and Ontario on its 

review of Atomic Energy of Canada Ltd.’s concept of geologic disposal (CEAA 1998). The 

panel concluded that broad public support is necessary in Canada to ensure the acceptability of 

a concept for managing spent fuel. The panel also found that technical safety is a key part, but 

only one part, of acceptability. To be considered acceptable in Canada, the panel found that a 

concept for managing nuclear fuel wastes must (1) have broad public support; (2) be safe from 

a technical perspective; (3) have been developed within a sound ethical and social assessment 

framework; (4) have the support of Aboriginal people; (5) be selected after comparison with the 

risks, costs, and benefits of other options; and (6) be advanced by a stable and trustworthy 

proponent and overseen by a trustworthy regulator. Resulting legislation mandated a 

nationwide consultation process and widespread organizational reform. 

In 2007, the Government of Canada announced its selection of the Adaptive Phased 

Management approach and directed the Nuclear Waste Management Organization to take at 

least 2 years to develop a “collaborative community-driven site-selection process.” The Nuclear 

Waste Management Organization is using this process to open consultations with citizens, 

communities, Aboriginals, and other interested parties to find a suitable site in a willing host 

community. Nuclear Waste Management Organization’s site-selection process was initiated in 

May 2010. For financial planning and cost estimation purposes only, the Nuclear Waste 

Management Organization assumes the availability of a deep geological repository in 2035, 

27 years after initiating development of new site-selection criteria, 30 years after embarking on 

a national public consultation, and 37 years after rejection of the original geologic disposal 

concept (NWMO 2008). At the end of 2012, 21 communities had expressed interest in learning 

more about the project (NWMO 2013). As of June 2014, 14 of the initial 21 communities are still 

actively engaged in the siting process. In particular, four communities are continuing with more 

detailed analyses having completed preliminary assessments; 10 communities are still in the 

preliminary assessment phase; and seven communities are no longer being considered in the 

site selection process. 

Repository development programs in Finland and Sweden are further along than in other 

countries but have taken time to build support from potential host communities. In Finland, 

preliminary site investigations started in 1986, and detailed characterizations of four locations 

were performed between 1993 and 2000. In 2001, the Finnish Parliament ratified the 

government’s decision to proceed with a repository project at a chosen site only after the 1999 

approval by the municipal council of the host community. In December 2012, Posiva (i.e., the 

nuclear-waste-management company in Finland) submitted a construction permit application for 
Appendix B 

NUREG-2157 B-8 September 2014 

a final repository that will hold spent fuel from Finland’s nuclear reactors. In June 2014, the 

Radiation and Nuclear Safety Authority (STUK) in Finland estimated that it can complete its 

safety assessment report for the construction permit application in January 2015. Finland 

expects this facility to begin receipt of spent fuel for disposal in 2020, 34 years after the start of 

preliminary site investigations. 

Between 1993 and 2000, Sweden conducted feasibility studies in eight municipalities. One site 

was found technically unsuitable, and two sites were eliminated by municipal referenda. Three 

of the remaining five sites were selected for detailed site investigations. Municipalities adjacent 

to two of these sites agreed to be potential hosts, and one refused. Since 2007, detailed site 

investigations were conducted at Östhammar and Oskarshamn, both of which already host 

nuclear power stations. On June 3, 2009, the Swedish Nuclear Fuel and Waste Management 

Company (SKB) selected the Forsmark site located in the Östhammar municipality for the 

Swedish spent fuel repository and, in spring 2011, SKB submitted a license application. At the 

request of the Swedish government, the Nuclear Energy Agency organized an international 

team to review the SKB license application. In June 2012, the international review team 

completed its review and report stating: “SKB‘s post-closure radiological safety analysis report, 

SR-Site, is sufficient and credible for the licensing decision at hand. SKB‘s spent fuel disposal 

programme is a mature programme—at the same time innovative and implementing best 

practice—capable in principle to fulfil the industrial and safety-related requirements that will be 

relevant for the next licensing steps” (NEA 2012). In April 2014, the Swedish Radiation Safety 

Authority, as part of its review process, circulated the license application for comment to other 

public authorities and environmental organizations. A government decision is expected in 2015. 

If Swedish authorities authorize construction, the repository could be available for disposal 

around 2025, about 30 years after feasibility studies began. 

In the United States, the DOE is the agency responsible for carrying out the national policy to 

site and build a repository, which includes designing, constructing, operating, and 

decommissioning the repository. The time DOE will need to develop a repository site will 

depend upon a variety of factors, including Congressional action and funding. Public 

acceptance will also influence the time it will take to implement geologic disposal. The NRC, by 

contrast, is the agency responsible for reviewing, licensing, and overseeing the construction and 

operation of the repository. 

In 2012, the Blue Ribbon Commission on America’s Nuclear Future recommended “prompt 

efforts to develop one or more geologic disposal facilities” (BRC 2012). In response to the Blue 

Ribbon Commission’s report, the DOE (2013) stated that its “...goal is to have a repository sited 

by 2026; the site characterized, and the repository designed and licensed by 2042; and the 

repository constructed and its operations started by 2048.” Based on the evaluation of 

international experience with geologic repository programs—including the issues some 

countries have overcome—and the affirmation by the Blue Ribbon Commission of the geologic 

repository approach, the NRC continues to believe that 25 to 35 years is a reasonable period for 
Appendix B 

September 2014 B-9 NUREG-2157 

repository development (i.e., candidate site selection and characterization, final site selection, 

licensing review, and initial construction for acceptance of waste). 

Although the NRC believes that 25 to 35 years is a reasonable timeframe for repository 

development, it acknowledges that there is sufficient uncertainty in this estimate that the 

possibility that more time will be needed cannot be ruled out. International and domestic 

experience have made it clear that technical knowledge and experience alone are not sufficient 

to bring about the broad social and political acceptance needed to construct a repository. The 

time needed to develop a societal and political consensus for a repository could add to the time 

to site and license a repository or overlap it to some degree. 

Because the availability of a repository can be substantially affected by whatever process is 

employed to achieve a national consensus on repository site selection, and consistent with the 

decision of the Court of Appeals in New York v. NRC, this GEIS offers three timeframes for 

continued storage that reflect significant differences in the availability of the repository. The 

short-term timeframe assumes a repository is available 60 years after the end of a reactor’s 

licensed life for operation. The long-term timeframe assumes a repository is not available for an 

additional 100 years beyond the short-term timeframe, which means a repository would be 

available 160 years after the end of a reactor’s licensed life for operation. In recognition of the 

uncertainty in reaching a national consensus on repository site selection, the third timeframe 

assumes that a repository does not become available and the spent fuel continues to be stored 

indefinitely. 

In the 2010 Waste Confidence decision, the Commission assessed the length of time that would 

be needed to site, license, construct, and open a repository. This analysis moved away from 

the Commission’s historical practice of specifying a “target date” and instead concluded that a 

repository would be available “when necessary.” The Commission’s reluctance to select a 

target date was not indicative of an inability to predict the length of the process for siting, 

constructing, licensing, and opening a repository, but rather that identification of a specific year 

as a starting point was uncertain. In sum, based on experience in licensing similarly complex 

facilities in the United States and national and international experience with repositories already 

in progress, the NRC concludes a reasonable period of time for the development of a repository 

is approximately 25 to 35 years. 

B.3 Technical Feasibility of Safe Storage 

Spent fuel removed from a reactor is initially placed in a spent fuel pool for cooling. After 

several years (about 5 years for low-burnup fuel and up to 20 years for high-burnup fuel), the 

spent fuel is sufficiently cooled that it can be placed in dry cask storage assuming current 
Appendix B 

NUREG-2157 B-10 September 2014 

storage configurations and heat loads.2 After the end of a reactor’s licensed life for operations, 

spent fuel is stored in onsite spent fuel pools or in an at-reactor or away-from-reactor dry cask 

storage system. 

Continued storage of spent fuel at at-reactor or away-from-reactor sites will be necessary until a 

repository is available for permanent disposal. The storage of spent fuel in any combination of 

storage (spent fuel pools or dry casks) will continue as a licensed activity under regulatory 

controls and oversight. Nonetheless, the conclusions reached by the NRC in this GEIS 

regarding the technical feasibility of continued storage do not rely solely on NRC’s regulatory 

framework governing these activities. Rather, these conclusions are also based on NRC’s 

experience with the actual storage of spent fuel under this regulatory framework and the 

continued application of proven fuel storage methodologies. Continued safe storage of spent 

fuel requires both the technical feasibility of storage methods and a regulatory framework that 

provides for monitoring and oversight to address the potential for evolving issues. The technical 

feasibility of wet storage in spent fuel pools and dry casks is discussed separately in 

Sections B.3.1 and B.3.2. The regulatory framework applicable to both wet and dry storage is 

discussed in Section B.3.3. The continuation of the institutional controls necessary to maintain 

safe storage is discussed in Section B.3.4. 

B.3.1 Technical Feasibility of Wet Storage 

The technical feasibility of continued storage in spent fuel pools is supported by a number of 

technical considerations. First, the integrity of spent fuel and cladding within the benign 

environment of the spent fuel pool’s controlled water chemistry is supported by operational 

experience and a number of scientific studies, some of which are summarized below. Further, 

the spent fuel pool’s robust structural design protects against a range of natural and humaninduced challenges, which are discussed in detail in the following sections and in the body of 

the GEIS. 

B.3.1.1 Integrity of Spent Fuel and Cladding in Spent Fuel Pools 

In 1984, the NRC provided information supporting the low degradation rates of spent fuel in 

spent fuel pools based on national and international storage experience, which at that time 

totaled 18 years of experience with zirconium-clad fuel3 and 12 years of experience with 

stainless-steel-clad fuel (49 FR 34658). Examples of the cited information are: 

 

2 Appendix I provides additional information on the characteristics, storage, and transportation of highburnup uranium oxide (UOX) spent fuel and mixed uranium-plutonium oxide (MOX) spent fuel. 

3 In 1984, only two commercial light water reactor nuclear power plants used stainless-steel-clad fuel, 

whereas most used zirconium-clad fuel (49 FR 34658). 
Appendix B 

September 2014 B-11 NUREG-2157 

1. In Behavior of Spent Nuclear Fuel in Water Pool Storage, Johnson (1977) reported on 

corrosion studies of irradiated fuel at 20 reactor pools in the United States, finding no 

detectable degradation of zirconium cladding. 

2. At the American Nuclear Society’s Executive Conference on Spent Fuel Policy and its 

Implications, presented in Buford, Georgia, April 2 to 5, 1978, Johnson (1978) presented 

“Utility Spent Fuel Storage Experience,” which reported that no degradation has been 

observed in commercial power reactor fuel stored in onsite pools in the United States and 

that extrapolation of corrosion data suggests that less than a tenth of a percent of the 

thickness of the zirconium clad would be corroded after 100 years. 

3. In The Long-Term Storage of Irradiated CANDU Fuel Under Water, Walker (1979) 

concluded that “50 to 100 years under water should not significantly affect their [spent fuel 

bundles] integrity.” 

Almost 30 years of additional experience has been gained since the completion of the first 

Waste Confidence proceeding in 1984, during which time the technical basis for very slow 

degradation rates of spent fuel in spent fuel pools has continued to grow and now includes the 

wet storage of high-burnup fuel. Examples of this additional experience include the following: 

1. In Durability of Spent Nuclear Fuels and Facility Components in Wet Storage, the IAEA 

(1998) summarized the durability of materials in wet storage, stating: “The zirconium alloys 

represent a class of materials that is highly resistant to degradation in wet storage, including 

some experience in aggressive waters. The only adverse experience involves Zircaloy clad 

metallic uranium where mechanical damage to the cladding was a prominent factor during 

reactor discharge, exposing the uranium metal fuel to aqueous corrosion. Otherwise, the 

database for the zirconium alloys supports a judgment of satisfactory wet storage in the time 

frame of 50 to 100 years or more.” 

2. In Spent Fuel Performance Assessment and Research: Final Report of a Co-Ordinated 

Research Project on Spent Fuel Performance Assessment and Research (SPAR) 

1997–2001, the IAEA (2003b), while discussing spent fuel storage experience, reported on 

a detailed review of the degradation mechanisms of spent fuel cladding under wet storage 

and stated that “wet storage of spent fuel only appears to be limited by adverse pool 

chemistry or the deterioration of the fuel storage pool structure.” 

3. In Understanding and Managing Ageing of Materials in Spent Fuel Storage Facilities, the 

IAEA reported that “over more than 40 years of experience with several million LWR [light 

water reactor] rods, power reactor fuel with zirconium alloy cladding has had an excellent 

durability in wet storage” (IAEA 2006). The IAEA went on to state that “destructive and 

non-destructive examinations of fuel rods, visual evidence and coupon studies [IAEA 2006; 

pp. 11, 13, 54–58] all support resistance to aqueous corrosion. There have been no reports 

of fission gas evolution, indicative of cladding failure in wet storage. Rod consolidation 

campaigns have been conducted without any indication of storage-induced degradation. 
Appendix B 

NUREG-2157 B-12 September 2014 

There is a sufficient database to indicate that wet storage of fuel with zirconium alloy 

cladding can be extended for at least several decades.” 

4. In Impact of High Burnup Uranium Oxide and Mixed Uranium-Plutonium Oxide Water 

Reactor Fuel on Spent Fuel Management, No. NF-T-3.8, (IAEA 2011a) the IAEA stated that 

because wet storage is associated with low temperatures, the clad material property 

degradation is expected to be low. However, the IAEA also recognized that high-burnup 

uranium oxide and MOX spent fuel storage in pools will increase the heat load and 

potentially cause radioactive releases, which may require an upgrade of the pool facility with 

respect to heat removal, pool cleanup systems, and additional neutron poison material in the 

pool water or in storage racks. In addition, the IAEA suggested that reevaluation of criticality 

and regulatory aspects may also be required for high-burnup fuel. 

Based on available information and operational experience, degradation of the fuel cladding 

occurs very slowly over time in the spent fuel pool environment. Degradation of the spent fuel 

should be minimal over the short-term storage timeframe. The NRC expects that only routine 

maintenance will be needed over the short-term storage timeframe. However, it is possible that 

future evaluations and experience with high-burnup fuel could identify upgrades and 

enhancements to pool storage that would need to be implemented in the future (see discussion 

on regulatory framework in Section B.3.3). Although the NRC assumes in the GEIS that the 

spent fuel pool will be decommissioned before the end of the short-term storage timeframe, it is 

not aware of any information that would call into question the technical feasibility of continued 

safe storage of spent fuel in spent fuel pools beyond the short-term storage timeframe. 

B.3.1.2 Robust Structural Design of Spent Fuel Pools

As described in Section 2.1.2.1 of the GEIS, spent fuel pools are massive, seismically designed 

structures that are constructed from thick, reinforced concrete walls and slabs that vary between 

0.7 and 3 m (2 and 10 ft) thick. All spent fuel pools currently in operation are lined with 

stainless-steel liners that vary in thickness from 6 to 13 mm (0.25 to 0.5 in.).4 NUREG–1738 

(NRC 2001), Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear 

Power Plants indicates that spent fuel pool structures are designed to be seismically robust (i.e.,

it is expected that a seismic event with peak spectral acceleration significantly larger than that of 

the safe shutdown earthquake would be required to produce catastrophic failure of the 

structure) (NRC 2001). Further, in evaluating the seismic risk to spent fuel pools, NRC (2001) 

stated that “[i]n boiling-water reactor (BWR) plants, the pool structures are located in the reactor 

building at an elevation several stories above the ground. In pressurized-water reactor (PWR) 

 

4 Dresden Unit 1 and Indian Point Unit 1 have no liner plates, but neither pool is currently operating. Both 

plants were permanently shut down more than 20 years ago and no safety-significant degradation of their 

concrete pool structures has been reported. At present, no spent fuel remains in either reactor’s spent 

fuel pool. 
Appendix B 

September 2014 B-13 NUREG-2157 

plants, the [spent fuel pool] structures are outside the containment structure and supported on 

the ground or partially embedded in the ground. The location and supporting arrangement of 

the pool structures affect their capacity to withstand seismic ground motion beyond their design 

basis. The dimensions of the pool structure are generally derived from radiation shielding 

considerations rather than seismic demand needs. Spent fuel structures at nuclear power 

plants are able to withstand loads substantially beyond those for which they were designed.” In 

Spent Fuel Storage Operation—Lessons Learned (IAEA 2013), the IAEA reported that pool 

storage is a mature technology and the latest storage pools have come through an evolutionary 

process and incorporate the learning from 50+ years of operating experience. 

In the initial Waste Confidence proceeding, the Commission found that the risks of major 

accidents at spent fuel pools resulting in offsite consequences were remote because of the 

secure and stable character of the spent fuel in the spent fuel pool environment and the 

absence of reactive phenomena that might result in dispersal of radioactive material. The 

Commission noted that storage pools and independent spent fuel storage installations (ISFSIs) 

are designed to safely withstand accidents caused by either natural or man-made phenomena 

(49 FR 34658). By 1990, the NRC had spent several years studying the potential for a 

catastrophic loss of reactor spent fuel pool water, which could cause a spent fuel fire in a dry 

pool. The NRC concluded that, because of the large inherent safety margins in the design and 

construction of a spent fuel pool, no action was needed to further reduce the risk (55 FR 38472). 

On March 11, 2011, an earthquake and subsequent tsunami resulted in significant damage to 

the nuclear facilities at Fukushima Dai-ichi. Subsequent analysis and inspections performed by 

Tokyo Electric Power Company personnel determined that the spent fuel pool water levels did 

not drop below the top of fuel in any spent fuel pool and that no significant fuel damage 

occurred (INPO 2011). Appendix F contains further discussion of the Fukushima event with 

respect to spent fuel pools. 

The NRC has continued its examination of spent fuel pool storage to ensure that adequate 

safety is maintained and that there are no adverse environmental effects from the storage of 

spent fuel in spent fuel pools. The Office of Nuclear Reactor Regulation and the former Office 

for Analysis and Evaluation of Operational Data independently evaluated the safety of spent fuel 

pool storage, and the results of these evaluations were documented in a pair of memoranda to 

the Commission: Resolution of Spent Fuel Storage Pool Action Plan Issues (NRC 1996a) and 

Assessment of Spent Fuel Pool Cooling (NRC 1996b) (later published as NUREG–1275, 

Vol. 12, “Operating Experience Feedback Report: Assessment of Spent Fuel Cooling” 

[NRC 1997a]). As a result of these studies, the NRC and industry identified a number of 

follow-up activities, which are described by the NRC in a memorandum to the Commission 

Follow-up Activities on the Spent Fuel Pool Action Plan (NRC 1997b). These evaluations 

subsequently became part of the investigation of Generic Safety Issue 173, Spent Fuel Pool 
Appendix B 

NUREG-2157 B-14 September 2014 

Cooling for Operating Plants, which found that the relative risk posed by loss of spent fuel 

cooling is low compared with the risk of events not involving the spent fuel pool (NRC 2000). 

The safety and environmental effects of spent fuel pool storage were also addressed in 

conjunction with regulatory assessments of permanently shutdown nuclear plants and 

decommissioning nuclear power plants. NUREG/CR–6451, A Safety and Regulatory 

Assessment of Generic BWR and PWR Permanently Shutdown Nuclear Power Plants

(Travis et al. 1997), addressed the appropriateness of regulations (e.g., requirements for 

emergency planning and insurance) associated with spent fuel pool storage. The study also 

provided reasonable bounding estimates for offsite consequences for the most severe 

accidents, which would involve draining of the spent fuel pool (e.g., complete draining of the 

spent fuel pool occurs 12 days after shutdown of the reactor). 

In 2001, the NRC issued NUREG–1738 (NRC 2001), Technical Study of Spent Fuel Pool 

Accident Risk at Decommissioning Nuclear Power Plants, which found that a postulated 

accident causing zirconium cladding fires could result in unacceptable offsite doses. 

Appendix F of this GEIS presents some results from NUREG–1738, including the largest 

number of early fatalities calculated (191). The large number of calculated fatalities was due, in 

part, to conservative assumptions for the ruthenium release (i.e., the release fraction is for a 

volatile fission product in an oxidic [rather than metallic] form), time of the accident (i.e., 30 days 

after shutdown of the reactor), and late evacuation of the public (i.e., evacuation is started after 

the release). More realistic assumptions (e.g., low ruthenium release, event occurs one year 

after shutdown), reduce the largest number of early fatalities from 191 to approximately two 

(NRC 2001). Although early fatalities are unacceptable, the annual likelihood for such an 

accident was estimated to be less than three chances in one million (NRC 2001). NUREG–

1738 further states that “the risk at decommissioning plants is low and well within the 

Commission's safety goals. The risk is low because of the very low likelihood of a zirconium fire 

even though the consequences from a zirconium fire could be serious.” In arriving at this 

conclusion, NUREG–1738 considered a wide range of initiating events, including but not limited 

to, events that might lead to rapid loss of pool water (e.g., seismic events, cask drop, aircraft 

impact, and missiles generated by tornados). The low probability for these varied events to 

initiate a rapid loss of water from the pool is a direct result of the robustness of the structural 

design of the spent fuel pool. 

As noted, spent fuel pools are massive structures constructed from thick, reinforced concrete 

walls and slabs designed to be seismically robust. Thus, the likelihood of major accidents at 

spent fuel pools resulting in offsite consequences is very remote. In particular, Appendix F 

determines that the environmental impacts from spent fuel pool fires are SMALL during the 

short-term storage timeframe based on the low risk of a spent fuel pool fire. The NRC is not 

aware of any additional studies that would cause it to question the low risk of spent fuel pool 
Appendix B 

September 2014 B-15 NUREG-2157 

accidents and thereby question the technical feasibility of continued safe storage of spent fuel in 

spent fuel pools for the short-term timeframe considered in the GEIS. 

B.3.2 Technical Feasibility of Dry Cask Storage 

The technical feasibility of dry cask storage is supported by years of experience and technical 

studies and NRC reviews that examined and confirmed the integrity of spent fuel and cladding 

under the controlled and benign environment within dry cask storage systems. The technical 

feasibility of these systems is further supported by the robustness of the structural design of the 

dry cask storage system against a variety of natural and human-induced challenges. 

B.3.2.1 Low Degradation Rates of Spent Fuel in Dry Cask Storage 

In the United States, spent fuel has been safely stored in dry casks for more than 25 years. In 

1986, Virginia Power received a license for an at-reactor dry storage facility located at Surry 

Nuclear Power Plant. As of June 2014, there are operational ISFSIs at 64 sites in the United 

States. One operational ISFSI, at the GEH-Morris site, is a wet facility. The remaining ISFSIs 

are storing spent fuel in over 1,900 loaded dry casks. (see Section 2.1.2 in the GEIS for further 

details). As with wet storage, the overall experience with dry cask storage of similar fuel types, 

including the cladding, has been similar—slow degradation. In addition, spent fuel is cooled for 

a lengthy period in a spent fuel pool before being transferred into dry cask storage. NRC 

guidance regarding dry cask storage recommends a maximum cladding temperature of 400°C 

(752°F) and a dry, inert atmosphere to reduce the potential for significant degradation 

(NRC 2010c). Recent studies, including the following, have confirmed dry cask storage 

reliability: 

1. A dry cask storage characterization project (Bare et al. 2001) examined and tested a dry 

cask storage system, the CASTOR V/21, and found “there was no evidence of cask, 

shielding, or fuel rod degradation during long-term (14 years) storage that would affect 

cask performance or fuel integrity.” The project examined zirconium-clad fuel applicable 

for spent fuel with a burnup of 35 GWd/MTU. A subsequent study (Einziger et al. 2003), 

which examined spent fuel from the Bare et al. (2001) project, suggests that the spent 

fuel cladding could remain a viable barrier to fission product release during extended 

storage up to 100 years in a dry cask environment. 

2. The IAEA status report Understanding and Managing Ageing of Materials in Spent fuel 

Storage Facilities (IAEA 2006) stated “[P]ower reactor fuel with zirconium alloy cladding 

has been placed into dry storage in approximately a dozen countries. The technical 

basis for satisfactory dry storage of fuel clad with zirconium alloys includes hot cell tests 

on single rods, whole assembly tests, demonstrations using casks loaded with irradiated 

fuel assemblies and theoretical analysis.” 
Appendix B 

NUREG-2157 B-16 September 2014 

3. The Electric Power Research Institute (EPRI 1998) evaluated the data needs for longterm storage and reported that during normal storage of low-burnup spent fuel, “the 

lower radiation fields and estimated temperatures of 100–125qC after 20 years favor 

acceptable fuel behavior for extended storage.” 

The NRC is aware that high-burnup and MOX fuel may be subject to increased degradation of 

the spent fuel and cladding that could cause further problems with handling, storing, and 

transporting spent fuel. With this increased usage, research has continued to improve 

understanding of degradation mechanisms affecting storage of spent fuel. Recent reports 

(e.g., NRC 2014; Hanson et al. 2012; IAEA 2011a; and Sindelar et al. 2011) have identified a 

variety of degradation mechanisms and discussed their potential effects on storage. For 

example, the mechanical integrity of the spent fuel cladding and assembly is important to 

ensure that handling and transportation of spent fuel can be conducted with relative ease. The 

mechanical designs of lower-burnup UOX and higher-burnup UOX or MOX fuel are very similar, 

but some of the after-irradiation properties of higher-burnup UOX and MOX are potentially 

significant in determining the rate of degradation or differences in performance. Differences in 

after-irradiation properties between lower-burnup UOX and higher-burnup UOX and MOX 

include higher fuel rod internal pressures and thinner cladding due to more cladding oxidation 

and hydride layer buildup causing higher cladding stress, higher decay heat, higher specific 

activity, and finer grain structure of the fuel pellet, potentially increasing the likelihood and 

consequences of an accident. Appendix I provides further discussion on the characteristics, 

storage, and transportation of high-burnup UOX and MOX spent fuel. 

Although NRC regulations for dry cask storage allow for a licensing period of up to 40 years for 

both initial and renewed licenses, licensing periods approved for storage casks for high-burnup 

fuel have been limited to 20 years due to the more limited data available for high-burnup fuel. 

These storage times are sufficiently short and the degradation rates of spent fuel sufficiently 

slow that (1) significant storage, handling, and transportation issues are not expected to arise 

during a single license period and (2) should information collected during a license period 

identify any emerging issues and concerns, there would be sufficient time to develop regulatory 

solutions and incorporate them into future licensing periods. 

Ongoing research into the extended storage of spent fuel is part of the NRC’s effort to 

continuously evaluate and update its safety regulations. As part of this effort, the NRC is 

examining the technical needs and potential changes to the regulatory framework that may be 

needed to continue licensing of spent fuel storage facilities over periods beyond 120 years. In 

2014, the NRC published Identification and Prioritization of the Technical Information Needs 

Affecting Potential Regulation of Extended Storage and Transportation of Spent Nuclear Fuel

(NRC 2014). This report considered high-burnup UOX fuel and MOX fuel. Further, international 

efforts are evaluating degradation mechanisms affecting handling, storage, and transportation of 

spent fuel (e.g., IAEA 2011a). The NRC, the DOE, other regulators, and the commercial power 
Appendix B 

September 2014 B-17 NUREG-2157 

industry have formed the Extended Storage Collaboration Program. The goal of this program is 

to better understand the degradation processes that could impact the storage of spent fuel. As 

new information becomes available, it will be considered in the development of canister design 

criteria and aging management requirements for the safe storage of spent fuel. Currently, EPRI 

is leading a multi-year research project, the majority of which is funded by DOE, to evaluate the 

safe storage of spent fuel in dry storage casks. EPRI will design and demonstrate dry cask 

technology at full scale for evaluating the condition of “high-burnup” spent fuel during storage. 

As research continues, if the NRC were to identify a concern with the safe storage of spent fuel, 

the NRC would evaluate the issue and take whatever action or make whatever change in its 

regulatory program necessary to protect public health and safety. 

Based on available information and operational experience, degradation of the spent fuel 

should be minimal over the short-term storage timeframe if conditions inside the canister are 

appropriately maintained (i.e., consistent with the technical specifications for storage). Thus, 

the NRC expects that only routine maintenance will be needed over the short-term storage 

timeframe. Repackaging of spent fuel may be needed if storage continues beyond the shortterm storage timeframe. In the GEIS, the NRC assumes that the dry casks would need to be 

replaced if storage continues beyond the short-term storage timeframe. Accidents associated 

with repackaging spent fuel are evaluated in Section 4.18 and the environmental impacts are 

SMALL because the accident consequences would not exceed the NRC accident dose standard 

contained in 10 CFR 72.106. 

Spent fuel transfer operations can present challenges to operators and, in part, because of 

these challenges, transfer operations are conducted in enclosed, heavily shielded buildings with 

filters to reduce any potential releases. Although transfer operations at a current reactor would 

be conducted in the spent fuel pool and the dry transfer system would involve dry transfer, spent 

fuel transfer operations in either facility would occur within an enclosed, shielded building. 

Therefore, releases to the environment from handling operations within the spent fuel pool and 

the dry transfer system are expected to be similar. These operations routinely maintain public 

and occupational doses well within existing requirements. This is done despite variations in the 

facilities and equipment and the characteristics of the spent fuel being transferred. While these 

characteristics may vary, the safety regulations do not. In addition, the NRC requires that 

facilities and equipment be maintained to ensure safety functions are not compromised. 

Further, the NRC inspects operating facilities to verify compliance with requirements. As 

described in Section B.3.3.3 of this appendix, after the end of the reactor’s licensed life for 

operation, the licensee would continue to store spent fuel onsite under either its 10 CFR Part 72 

general license granted to 10 CFR Part 50 or Part 52 reactor licensees or a specific 

10 CFR Part 72 license. During this time, the licensee would remain under the NRC’s 

regulatory control and NRC inspections and oversight of storage facilities would continue. 

The NRC monitors the performance of ISFSIs (at decommissioned and shutdown reactor 

sites and at operating reactor sites) by conducting periodic inspections. 
Appendix B 

NUREG-2157 B-18 September 2014 

The opportunity to inspect spent fuel that has been placed into dry cask storage would occur 

during repackaging of the fuel. During the short-term timeframe, repackaging would occur, if 

needed, in the spent fuel pool, which would provide shielding and allow licensees to safely 

repackage the fuel. In the long-term and indefinite timeframes, repackaging would occur in the 

dry transfer system, which would be a shielded building. The NRC assumes replacement of dry 

casks after 100 years of service life; however, replacement times will depend on actual 

degradation observed during continued regulatory oversight for maintaining safety during 

continued storage. Studies and experience to date do not preclude a dry cask service life longer 

than 100 years. In addition, as described in Section 2.2.1.3 of the GEIS, in accordance with 

10 CFR 72.42, ISFSI license renewal applications must include, among other things, (1) timelimited aging analyses that demonstrate that structures, systems, and components important to 

safety will continue to perform their intended safety function for the requested period of 

extended operation and (2) a description of the aging management program for management of 

issues associated with aging that could adversely affect structures, systems, and components 

important to safety. These requirements enhance confidence that spent fuel, including bare 

fuel, fuel in canisters, or damaged fuel that has been canned and stored in dry casks, could be 

retrieved for repackaging, if needed. Finally, regulatory experience shows that licensees have 

successfully dealt with damaged fuel. In the most extreme example, the damaged fuel from the 

core of Three Mile Island, Unit 2 (TMI-2), was removed and safely placed into storage. If this 

type of fuel can be successfully moved and managed, then it is reasonable to assume that 

damaged spent fuel in casks can be handled, if necessary. Although a commercial dry transfer 

system is currently not operating in the United States, construction and operation of a dry 

transfer system, including the handling of damaged fuel, can be accomplished with current 

technology (further information provided in Section 2.2.2.1 – Construction and Operation of a 

Dry Transfer System). 

B.3.2.2 Robust Design of Dry Cask Storage Systems 

Dry cask storage systems are passive systems (i.e., relying on natural air circulation for cooling) 

that are inherently robust, massive, and highly resistant to damage. To date, the NRC and 

licensee experience with ISFSIs and cask certification indicates that spent fuel can be safely 

and effectively stored using dry cask storage technology. There have not been any safety 

issues with dry cask storage. 

In addition, the NRC’s technical review supporting issuance of Materials License No. 

SNM–2513 for the Private Fuel Storage, LLC (PFS) facility has confirmed the technical 

feasibility of continuing storage at an away-from-reactor ISFSI under 10 CFR Part 72 (NRC 

2006a). While issues extraneous to safety and protection of the environment have, to date, 
Appendix B 

September 2014 B-19 NUREG-2157 

prevented the licensee from going forward with the project,5 the NRC’s extensive review of 

safety and environmental issues associated with construction and operation of the PFS facility 

provides further information supporting the technical feasibility of safe spent fuel storage at an 

away-from-reactor ISFSI for long periods following storage at a reactor site (i.e., in a spent fuel 

pool or at-reactor ISFSI). 

The NRC has renewed three specific ISFSI licenses for an extended 40-year period. Because 

at that time Part 72 only provided for a renewal period of 20 years, an exemption was granted 

as part of the NRC’s review of the safety of renewing Part 72 license for 40 years. The NRC 

published a final rule on February 16, 2011, to clarify the processes for the renewal of ISFSIs 

operated under the general license provisions of 10 CFR Part 72, for renewal of the Certificate 

of Compliance for dry cask storage systems, and for extending the license and renewal terms to 

40 years (76 FR 8872). In these cases, the NRC’s technical review has encompassed the 

applicant’s evaluation of aging effects on the structures, systems, and components important to 

safety, supplemented by the applicant’s aging management program. These comprehensive 

reviews support the technical feasibility of continued safe storage of spent fuel in these ISFSIs 

and thus reaffirm the technical feasibility of safe, interim dry storage for an extended period. 

While these license renewal cases address storage at an ISFSI for a period of up to 80 years 

(i.e., up to 40-year initial license, plus 40-year renewal), studies performed to date (e.g., 

Einziger et al. 2003; EPRI 2002; 55 FR 38472) have not identified any issues that would call into 

question the technical feasibility of long-term use of dry storage for low-burnup spent fuel. 

In 2007, the NRC published a pilot probabilistic risk assessment methodology (NRC 2007) that 

identified the dominant contributors to risk associated with a welded-canister dry-spent-fuelstorage system at a specific boiling water reactor site. The NRC study developed and assessed 

a comprehensive list of initiating events, including dropping the cask during handling and 

external events during onsite storage (e.g., earthquakes, floods, high winds, lightning strikes, 

accidental aircraft crashes, and pipeline explosions) and reported that the analysis indicates that 

the overall risk of dry cask storage was found to be extremely low. (The NRC determined that 

the estimated aggregate risk is an individual probability of a latent cancer fatality of 1.8×10í12

during the period encompassing the initial cask loading and first year of service and 3.2×10í14

per year during subsequent years of storage [NRC 2007]). 

Several characteristics of dry cask storage contribute to the low risk determined by the NRC 

study. First, these systems are passive. Second, they rely on natural air circulation for cooling. 

 

5 Although a license was issued, the PFSF has not yet been constructed. However, the NRC 

determined, based on its review of the application, that there is reasonable assurance that if the PFSF is 

constructed (1) the activities authorized by the license can be conducted without endangering the health 

and safety of the public and (2) these activities will be conducted in compliance with the applicable 

regulations of 10 CFR Part 72 (NRC 2006a). 
Appendix B 

NUREG-2157 B-20 September 2014 

Third, their inherently robust, massive concrete and steel structure is highly resistant to damage. 

The robustness of these dry cask storage systems has been tested by significant challenges 

(e.g., the August 23, 2011 Mineral, Virginia earthquake that affected the North Anna Nuclear 

power plant and the March 11, 2011 earthquake and subsequent tsunami that damaged the 

Fukushima Dai-ichi nuclear power plant). Neither event resulted in significant damage to the 

dry cask storage containers or the release of radionuclides (VEPCO 2011; INPO 2011). 7

Thus, technical studies and practical operating experience to date confirm the physical integrity 

of dry cask storage structures and thereby demonstrate the technical feasibility of continued 

safe storage of spent fuel in dry cask storage systems for the time periods considered in the 

GEIS. Further, the NRC expects that only routine maintenance will be needed over the 

short-term storage timeframe. Repackaging of spent fuel may be needed if storage continues 

beyond the short-term storage timeframe. The NRC is not aware of any issue that would cause 

it to question the technical feasibility of continued safe storage of spent fuel in dry casks for the 

timeframes considered in the GEIS. Further, the NRC continues to evaluate aging management 

programs and to monitor dry cask storage so that it can update its service life assumptions as 

necessary and consider any circumstances that might require repackaging of spent fuel earlier 

than anticipated. 

B.3.3 Regulatory Oversight of Wet and Dry Spent Fuel Storage 

A strong regulatory framework that includes both regulatory oversight and licensee compliance 

is important to the continued safe storage of spent fuel. As part of its oversight, the NRC can 

issue orders and new or amended regulations to address emerging issues that could impact the 

safe storage of spent fuel. This section provides a discussion of how the NRC’s regulatory 

program has addressed potential safety and security concerns and routine operations. The 

environmental impact analysis in the GEIS relies upon the current regulatory framework, which 

includes whatever license amendments, orders, and rulemaking becomes necessary to protect 

public health and safety. These ongoing improvements to the NRC’s regulatory structure are 

reflected in the NRC’s upgrade of safety, environmental, and security requirements following 

historic events, (e.g., the regulatory changes following the TMI-2 accident in 1979; safety and 

security upgrades following the September 11, 2001 terrorist attacks; and the Task Force 

recommendations and improvements to safety following the March 11, 2011 earthquake and 

subsequent tsunami that crippled the Fukushima Dai-ichi nuclear power plant). These 

regulatory changes demonstrate the NRC’s capability for prompt and vigorous response to new 

developments that warrant increased regulatory attention. Thus, the vitality and evolution of the 

NRC’s regulatory requirements support a reasonable conclusion that continued storage, even 

 

7 Dry casks at the Fukushima Dai-ichi nuclear power plant are stored in a shared dry cask storage 

building. 
Appendix B 

September 2014 B-21 NUREG-2157 

over extended periods of time beyond those regarded as most likely, will continue to be safe 

with the same or fewer environmental impacts.

B.3.3.1 Regulatory Actions for Routine Operations, Accidents, and Terrorist Activity 

As part of its oversight, the NRC can issue orders and new or amended regulations to address 

emerging issues that could impact the safe storage of spent fuel. An example of the NRC’s 

regulatory oversight is the NRC’s actions following the TMI-2 accident in 1979. First, the NRC 

created a Bulletin and Orders Task Force to assure the immediate safety of all other operating 

power reactors. Next, the NRC established the TMI-2 Lessons Learned Task Force to identify 

and evaluate safety concerns requiring prompt licensing actions for operating reactors, beyond 

the immediate actions announced by the earlier Task Force. A set of short-term 

recommendations was published as NUREG–0578 in July 1979 (NRC 1979). The NRC then 

assessed recommendations that “would provide a comprehensive and integrated plan for all 

actions necessary to correct or improve the regulation and operation of nuclear facilities.” This 

“TMI-2 Action Plan” was published as NUREG–0660 in May 1980 (NRC 1980a). These action 

items led NRC to issue a list of “Requirements for New Operating Licenses,” published in 

NUREG–0694 (NRC 1980b), which was later clarified and superseded by NUREG–0737 

(NRC 1980c). Finally, after issuance of TMI-2 Action Plan requirements, the NRC codified 

new reactor requirements by regulation (46 FR 26491). 

Another example, following the terrorist attacks of September 11, 2001, the NRC undertook an 

extensive reexamination of spent fuel safety and security issues. In 2002, the NRC issued 

orders to licensees that required power reactors in decommissioning, spent fuel pools, and 

ISFSIs to enhance security and improve their capabilities to respond to, and mitigate the 

consequences of, a terrorist attack. For example, these orders required additional security 

measures, including increased patrols, augmented security forces and capabilities, and more 

restrictive site-access controls to reduce the likelihood of a successful terrorist attack. In 2007, 

the NRC issued a final rule revising the Design Basis Threat,8 which also increased the security 

requirements for power reactors and their spent fuel pools (72 FR 12705). More recently, in 

2009, the NRC issued a final rule to further improve security measures at nuclear power 

reactors, including at spent fuel pools (74 FR 13926). This rule included improvements to 

security measures, such as enhancements to cyber security plans, facilitation of consistent 

application of preparatory actions with respect to air attacks, integration of the access 

authorization and security program requirements, and additional requirements for unarmed 

security personnel to ensure these personnel meet the minimum physical requirements 

commensurate with their duties. 

 

8 A design basis threat provides a general description of the attributes of potential adversaries who might 

attempt to commit radiological sabotage or theft or diversion against which licensee's physical protection 

systems must defend with high assurance. 
Appendix B 

NUREG-2157 B-22 September 2014 

Section 4.19 of the GEIS describes the environmental impacts of potential acts of sabotage or 

terrorism involving the continued storage of spent fuel. This section acknowledges that as the 

immediate hazard posed by the high radiation levels of spent fuel diminishes over time, 

depending on burnup, so does the deterrent to handling by unauthorized persons. The NRC will 

consider this type of information in evaluating whether additional security requirements are 

warranted in the future. 

The most recent examples of the NRC’s response to unexpected developments are the 

additional requirements that the NRC has already imposed or is considering in response to the 

March 11, 2011 earthquake and subsequent tsunami that resulted in extensive damage to the 

six-unit Fukushima Dai-ichi nuclear power plant in Japan. On March 12, 2012, the NRC issued 

multiple orders and a request for information to all of its nuclear power plant licensees 

(NRC 2012a). The request for information was issued to all licensees to determine whether 

nuclear plant licenses should be modified, suspended, or revoked. The purpose of the request 

for information was to re-evaluate seismic and flooding hazards at operating reactor sites and to 

determine whether appropriate staffing and communication can be relied upon to coordinate 

event response during a prolonged station blackout event, as was experienced at Fukushima 

Dai-ichi. Section 4.18 and Appendix F provide further details regarding the NRC’s orders and 

requests for information in response to the Fukushima event. 

Another aspect of the NRC’s regulatory program for continued storage at reactors and other 

licensed facilities involves generic communications. Generic communications include, but are 

not limited to, generic letters, bulletins, information notices, safeguards advisories, and 

regulatory issue summaries. Generic letters request licensee actions or information to address 

issues regarding emergent or routine matters of safety, security, safeguards, or environmental 

significance. Bulletins request licensee actions or information to address significant issues 

regarding matters of safety, security, safeguards, or environmental significance that have great 

urgency. Information notices are used to communicate operating or analytical experience to the 

nuclear industry. The industry is expected to review the information for applicability and 

consider appropriate actions to avoid similar problems. Regulatory issue summaries are used 

to communicate and clarify the NRC’s technical or policy positions on regulatory matters. 

For example, Information Notice 2012–20 (NRC 2012b) informed licensees about the potential 

for chloride-induced stress corrosion cracking of austenitic stainless steel and maintenance of 

dry cask storage system canisters. Although an immediate safety concern did not exist, the 

NRC alerted its licensees and certificate holders that their monitoring programs need to address 

this concern as part of an aging management program so that appropriate actions (e.g., 

maintenance) would be taken before there were any impacts. 

Another example is Information Notice 2009-26, Degradation of Neutron-Absorbing Materials in 

the Spent Fuel Pool, with respect to criticality safety for pool storage (NRC 2009a). NRC 

licensees use various methods to meet subcriticality requirements in the spent fuel pool 
Appendix B 

September 2014 B-23 NUREG-2157 

specified by 10 CFR 50.68 or 10 CFR Part 50 Appendix A, General Design Criterion 62. Most 

spent fuel pools now store spent fuel assemblies in high-density racks, which incorporate 

neutron absorber materials into the rack walls. These neutron absorber materials, especially 

boraflex, can degrade enough to lose their neutron-absorbing capabilities and challenge 

subcriticality requirements (requirements to prevent an uncontrolled chain reaction). Due to this 

degradation, many licensees now employ other means to meet subcriticality requirements 

(e.g., spent fuel loading patterns, fuel burnup credit, control rods or other neutron poisons 

contained within spent fuel bundles, soluble boron in the pool water, or some combination of 

these methods). The NRC issued Information Notice 2009-26 to all operating reactors 

licensees and construction permit holders in October 2009 (NRC 2009a). The NRC continues 

to monitor how licensees are addressing the degradation issue. Most recently, on March 11, 

2014, the NRC issued a draft generic letter for public comment that, if finalized, would request 

information from licensees to allow the NRC to “determine if the degradation of the neutronabsorbing materials in the SFP is being managed to maintain reasonable assurance that the 

materials are capable of performing their intended safety function, and if the licensees are 

incompliance with the regulations” (79 FR 13685). 

B.3.3.2 Regulatory Oversight of Spent Fuel Pool Leaks 

Spent fuel pool design and operational control requirements in NRC regulations make it unlikely 

that a leak will remain undetected long enough to result in public health and safety or 

environmental concerns. Long-standing design requirements include but are not limited to 

general design criteria in 10 CFR Part 50, Appendix A that focus on fuel storage and handling 

and radioactivity control (e.g., General Design Criterion 61). Operational controls include 

requirements for control of effluents and release of radioactive materials such as dose limits 

found in 10 CFR 20.1301 and design objectives found in 10 CFR Part 50, Appendix I. 

There are also requirements that are new or have been updated in response to recent 

operational experience and related studies by NRC task forces. For example, a 2006 report by 

NRC’s Liquid Radioactive Release Lessons Learned Task Force made 26 specific 

recommendations for improvements to NRC regulatory programs (NRC 2006b). In 2010, the 

NRC Groundwater Task Force reevaluated the recommendations of the 2006 Task Force 

(NRC 2010d). A review of the Groundwater Task Force recommendations by NRC senior 

management concluded that further action was warranted (NRC 2011d). These studies have 

influenced specific changes to NRC requirements and guidance. For example: 

x In June 2008, the NRC issued Regulatory Guide 4.21, Minimization of Contamination 

and Radioactive Waste Generation: Life-Cycle Planning (NRC 2008). The purpose of 

this regulatory guide is to present guidance that will assist applicants covered by 

10 CFR 20.1406, “Minimization of contamination,” in effectively implementing this 

licensing requirement. 
Appendix B 

NUREG-2157 B-24 September 2014 

x In June 2009, the NRC issued revision 2 to Regulatory Guide 4.1 (NRC 2009b) provides 

guidance to licensees for detecting, evaluating, and monitoring releases from operating 

facilities via unmonitored pathways; to ensure consistency with current industry standards 

and commercially available radiation detection methodology; to clarify when a licensee’s 

radiological effluent and environmental monitoring programs should be expanded based on 

data or environmental conditions; and to ensure that leaks and spills are detected before 

radionuclides migrate offsite via an unmonitored pathway. 

x In July 2011, the NRC promulgated its Decommissioning Planning Rule, which added 

10 CFR 20.1406(c) and modified 10 CFR 20.1501(a) and (b) (76 FR 35512). This rule 

requires all licensees to establish operational practices to minimize site contamination and 

perform reasonable subsurface radiological surveys and sets forth new financial assurance 

requirements. 

x In December 2012, the NRC published Regulatory Guide 4.22, Decommissioning Planning 

During Operations, which provides methods acceptable to the NRC to use in implementing 

portions of the Decommissioning Planning Rule (NRC 2012c). 

Appendix E of the GEIS provides a detailed description and evaluation of the historical data on 

spent fuel pool leaks, discusses ongoing and future monitoring activities and corrective actions, 

and analyzes potential environmental impacts that may occur during the short-term timeframe 

during which spent fuel storage in pools will continue. Appendix E concludes that the potential 

environmental impacts from spent fuel pool leakage would be SMALL. 

B.3.3.3 Dry Cask Storage 

Consistent with the NRC’s regulatory framework for continued safe spent fuel storage in dry 

casks, reactor and ISFSI licensees have acted prudently to safely manage their spent fuel. In 

the late 1970s and early 1980s, the need for alternative storage began to grow as spent fuel 

pools at many nuclear reactors began to reach their licensed capacity. License amendments to 

allow spent fuel pool re-racking, fuel-pin consolidation, and specific or general licenses for 

onsite dry cask storage have been successfully employed to increase onsite storage capacity. 

As discussed previously, there are currently operational ISFSIs at 64 sites. The NRC is 

successfully regulating seven fully decommissioned reactor sites that contain ISFSIs licensed 

under either the general or specific license provisions of 10 CFR Part 72.11 

After the end of a reactor’s licensed life for operation, the licensee would continue to store spent 

fuel onsite under either the 10 CFR Part 72 general license granted to 10 CFR Part 50 and 

Part 52 reactor licensees or a specific 10 CFR Part 72 license. During this time, the licensee 

 

11 These reactor sites include Maine Yankee, Yankee Rowe, Connecticut Yankee (also known as 

Haddam Neck), Fort St. Vrain, Rancho Seco, Trojan, and Big Rock Point. 
Appendix B 

September 2014 B-25 NUREG-2157 

would remain under the NRC’s regulatory control and NRC inspections and oversight of storage 

facilities would continue. The NRC monitors the performance of ISFSIs (at both 

decommissioned and shutdown reactor sites and operating reactor sites) by conducting periodic 

inspections. When conducting inspections at these ISFSIs, NRC inspectors follow the guidance 

in NRC Inspection Manual Chapter 2690, Inspection Program for Dry Storage of Spent Reactor 

Fuel at Independent Spent Fuel Storage Installations and for 10 CFR Part 71 Transportation 

Packages (NRC 2012d). 

The current regulatory framework for storage of spent fuel allows for multiple license renewals, 

subject to aging management analysis and planning. In early 2011, the Commission published 

a final rule that amended 10 CFR Part 72 to increase the initial and renewal terms for specific 

ISFSI licenses from “not to exceed 20 years” to “not to exceed 40 years” (76 FR 8872). The 

Commission concluded that, with appropriate aging management and maintenance programs, 

license terms not to exceed 40 years are reasonable and adequately protect public health and 

safety. An applicant for a storage license renewal must provide appropriate technical bases for 

identifying and addressing aging-related effects and must develop specific aging management 

plans to justify extended operations of ISFSIs. The regulatory framework for storage is 

supported by well-developed regulatory guidance; voluntary domestic and international 

consensus standards; research and analytical studies; and processes for implementing 

licensing reviews, inspection programs, and enforcement oversight. 

B.3.3.4 Summary of Information on Regulatory Oversight 

The NRC will continue its regulatory control and oversight of spent fuel storage at both 

operating and decommissioned reactor sites under both specific and general 10 CFR Part 72 

licenses. Decades of operating experience and ongoing NRC inspections demonstrate that 

these reactor and ISFSI licensees continue to meet their obligation to safely store spent fuel in 

accordance with the NRC’s requirements. If the NRC were to find noncompliance with these 

requirements or otherwise identify a concern with the safe storage of the spent fuel, the NRC 

would evaluate the issue and take necessary action or change its regulatory program to protect 

the public health and safety and the environment. 

As noted in the preceding paragraphs, licensees have continued to develop and successfully 

use onsite spent fuel storage capacity in the form of spent fuel pool and dry cask storage in a 

safe and environmentally sound fashion. Based on the preceding discussion, the NRC believes 

that for the storage timeframes considered in the GEIS, regulatory oversight will continue in a 

manner consistent with NRC’s regulatory actions and oversight in place today to provide for 

continued safe storage of spent fuel as long as spent fuel needs to be stored. 
Appendix B 

NUREG-2157 B-26 September 2014 

B.3.4 Continued Institutional Controls 

As discussed in the previous sections of this appendix, continued safe storage of spent fuel 

requires both the technical feasibility of safe storage and a regulatory framework that provides 

for monitoring and oversight to address the potential for evolving issues. To ensure adequate 

protection of public health and safety, the institutional controls provided by the NRC’s regulatory 

structure and that of sister agencies, as well as by Federal, State and local governments in 

general, must be maintained over time. The GEIS takes the following approach to institutional 

controls: 

1. the GEIS’s evaluation of reasonably foreseeable environmental impacts of continued 

storage requires an assumption that institutional controls will be maintained; 

2. the most reasonably foreseeable assumption is that institutional controls will continue; 

3. accidents provide a helpful surrogate for analysis of a temporary lapse in institutional 

controls, including perspectives on the environmental implications of such a lapse; and 

4. although too remote to calculate meaningfully, a permanent loss of institutional controls 

would likely have catastrophic consequences. 

A detailed discussion for each of these topics is provided below. 

1. An evaluation of reasonably foreseeable environmental impacts in the GEIS requires 

an assumption that institutional controls will be maintained 

In New York v. NRC, the Court of Appeals held that because the NRC had not demonstrated 

that the unavailability of a repository was “remote and speculative,” the National Environmental 

Policy Act (NEPA) required the NRC to analyze the environmental impacts of continued storage 

in the absence of a repository. The NRC believes that, if geologic disposal were not possible, 

national spent fuel policy would change but would not default to relying on the storage facilities 

as they currently exist—the design of facilities and the regulations governing those facilities 

would change to accommodate the new policy. Further, the NRC is not in a position to predict 

how the policy would change or what technical advancements would become available to serve 

a new national policy if geologic disposal were not feasible or achievable by consensus. 

Analyzing the consequences of failing to secure a repository requires assumptions about what 

indefinite continued storage would encompass. Because the current methods of continued 

storage employ institutional controls, the NRC considered whether it was reasonable to assume 

that institutional controls would remain in place in the timeframes being considered, and, as 

explained below, concluded that the assumption is reasonable for the purposes of this GEIS. 

While the NRC does not believe that the indefinite storage scenario described in the GEIS is 

likely, the NRC has analyzed this scenario in the GEIS to provide a conservative picture of the 

environmental impacts should a repository not become available by the end of the long-term 

timeframe. 
Appendix B 

September 2014 B-27 NUREG-2157 

As stated in Chapter 1 of this GEIS, the Federal government, by national policy set forth in the 

Nuclear Waste Policy Act, has assumed responsibility for the permanent disposal of high-level 

radioactive waste and spent fuel. The Nuclear Waste Policy Act specifies that the cost of both 

interim storage and permanent disposal is the responsibility of the generators and owners of the 

waste. Further, the Nuclear Waste Policy Act defines the current national strategy for disposition 

of spent fuel as disposal in a geologic repository; the geologic repository strategy was recently 

reaffirmed by the Blue Ribbon Commission on America’s Nuclear Future (BRC 2012). 

In response to the Blue Ribbon Commission’s report (BRC 2012), the DOE expressed its intent 

to provide a repository by 2048 (DOE 2013), which is about 10 years before the end of the 

short-term timeframe for the oldest spent fuel storage facility within the scope of this analysis. 

In this GEIS, the NRC concludes that a repository is most likely to be available by the end of the 

short-term timeframe, and failing that, likely to be available by the end of the long-term 

timeframe. In the event a repository could not be sited by the end of the long-term timeframe, 

the NRC has concluded that it is not reasonable to assume that national policy would default to 

complete inaction so as to leave spent fuel in dry casks unprotected, much less unattended or 

ultimately forgotten. However, because an alternate path forward is unknown at this point, the 

NRC has not attempted to forecast a different solution and assumes that continued storage 

continues indefinitely. 

Should the national policy change from geologic disposal to permanent storage (i.e., onsite or 

away-from-reactor “disposal” in facilities that resemble ISFSIs), the NRC expects that planning 

and decision-making for permanent storage of spent fuel would take into account the 

appropriate balance of engineering design and institutional controls to address the challenges 

presented by permanent storage. There is no national historic precedent and, more particularly, 

no regulatory history of nuclear materials to suggest that the Federal government, including the 

NRC in its assigned role under the Atomic Energy Act, would not engage in planning and 

decision-making regarding whatever further changes or enhancements would be necessary to 

accommodate permanent storage, in the unlikely event that option was adopted. Should 

national policy change to a policy of permanent storage, the NRC believes that significant 

regulatory changes and design modifications would be required to transfer spent fuel to offsite 

facilities or convert onsite continued storage facilities to onsite permanent storage facilities. 

Further, even if a repository does not become available, the NRC believes that, based on the 

factors discussed in the next section, institutional controls will be maintained as long as the 

spent fuel needs to be stored. 

With respect to costs, the NRC acknowledges that, because of delays in the siting and licensing 

of a repository, the Federal government bears an increasing share of the financial responsibility 

for storage costs. Although the annual costs for continued storage are manageable, cumulative 

costs will continue to increase. The Federal government has estimated it will pay a total of 

approximately $20 billion in damage awards and settlements by the year 2020 and $500 million 
Appendix B 

NUREG-2157 B-28 September 2014 

per year after that if DOE does not accept fuel by 2021 and spent fuel continues to accumulate 

at reactor sites (GAO 2013). Thus, the escalating costs of continued storage provide incentive 

for the Federal government to implement the national policy for disposal of spent fuel in a deep 

geologic repository. 

The assumption that institutional controls will continue enables an appropriate and reasonable 

evaluation of the environmental impacts of continued storage over an indefinite timeframe. 

Absent the stability and predictability that follows from institutional controls, including but not 

limited to NRC licensing and regulatory controls, few impacts could be reliably forecast. The 

“hard look” required by NEPA would quickly become unfocused, highly speculative, and illdefined. Analyzing the impacts that might result from a permanent and total loss of institutional 

controls would require NRC to reach unsupportable conclusions about how and when our 

nation, and its government, institutions, and social cohesiveness might degrade or even 

collapse. Such speculation would preclude meaningful calculations of impacts for the 

timeframes envisioned in the GEIS. 

2. The assumption that institutional controls continue is reasonable 

Consistent with NEPA’s rule of reason, which provides that agencies conduct an analysis 

according to the usefulness of the information to the decision-maker and full disclosure to the 

public of predictable benefits and impacts, this GEIS assumes that institutional controls at any 

storage site are maintained. This assumption is reasonable for two reasons: First, in any 

timeframe it would be illogical for any government at any level to abandon the storage facilities, 

given the particular hazards of the fuel. Continued storage is designed to allow the eventual 

transport of the spent fuel to a repository, not to permanently sequester the material from the 

environment without continued active oversight and maintenance. Second, these highly visible 

storage facilities are much less likely than buried geologic repositories to simply be forgotten. 

Spent fuel is highly hazardous, requiring robust containment structures to minimize exposure 

risks. Spent fuel in storage facilities on the surface of the earth presents a visible hazard that 

requires active oversight to ensure safety and security measures are maintained and functioning 

as designed. Storage facilities remain under license and have aging management programs to 

support their continued maintenance and monitoring. Thus, the visibility of storage facilities and 

the hazards of spent fuel strongly support the reasonableness of assuming the continuation of 

institutional controls throughout all of the timeframes analyzed in the GEIS. While changes may 

occur over time to governments or society, highly visible, hazardous facilities are unlikely to be 

left abandoned or forgotten. As a result, it is a reasonable assumption that any government 

would, in the interest of its citizenry, ensure that appropriate oversight (e.g., monitoring, 

maintenance, and replacement of facilities as needed) remains in place, consistent with 

radiation protection principles and regulatory restrictions, until final disposition of the spent fuel 

occurs. Accordingly, the NRC has determined that the assumption of continued institutional 

controls is reasonable in each of the timeframes considered in the GEIS. 
Appendix B 

September 2014 B-29 NUREG-2157 

In contrast, consideration of the loss of institutional controls in the context of disposal of spent 

fuel—as in DOE’s Yucca Mountain environmental impact statement (EIS), for example—is not 

directly applicable to storage: NRC regulations for deep geologic disposal of spent fuel 

recognize there is a point when the repository ceases operation, is permanently closed, and the 

license terminated. After permanent closure, regulations specify institutional controls (e.g., the 

requirements to place markers to identify what is buried deep below the surface of the earth and 

to maintain records regarding the hazard). However, these institutional controls are part of a 

defense-in-depth approach to disposal; the facility design is not permitted to rely on those 

institutional controls to meet postclosure safety requirements. 

Additionally, as identified in the public comments for this proceeding (see Appendix D of the 

GEIS), a repository applicant is required to prepare a stylized calculation to evaluate the 

consequences should humans inadvertently disrupt the repository (see 10 CFR 63.322). These 

requirements for disposal address the situation where human activities could occur at a disposal 

site that is no longer recognizable at the earth’s surface following waste burial, permanent 

closure of the facility, and license termination. However, in contrast to underground disposal 

facilities, aboveground storage installations are not designed to be abandoned and will remain 

highly visible on the earth’s surface. As explained previously, the visibility and purpose of 

temporary storage facilities differ significantly from those of permanent disposal facilities, 

supporting the reasonableness of assuming that institutional controls over continued storage 

facilities will be maintained. 

The NRC recognizes information presented by the National Academies National Research 

Council and others regarding the durability of institutional controls (e.g., NAS 1995, 2000). The 

NRC is also aware of international reports that discuss the durability of institutional controls 

(e.g., NEA 2006, IAEA 2011b). However, this commentary does not conclude that a permanent 

loss of institutional controls is likely or that effective government and governmental oversight of 

continued storage will cease in the distant future. Rather, these documents focus on developing 

plans and strategies regarding what should be done today to address future uncertainty due, in 

part, to institutional controls. 

For example, the Board on Radioactive Waste Management, in its study on long-term 

institutional management, stated: “No plan developed today is likely to remain protective for the 

duration of the hazards. Instead, long-term institutional management requires periodic, 

comprehensive reevaluation of those legacy waste sites still presenting risk to the public and the 

environment to ensure that they do not fall into neglect and that advantage is taken of new 

opportunities for their further remediation” (NAS 2000). While regulations may need to be 

updated over time, the NRC does not view possible future regulatory updates as an impediment 

to a current understanding of likely environmental impacts of continued storage. Further, future 

regulatory development would be expected to be undertaken to enhance and improve the 

effectiveness of regulatory oversight. 
Appendix B 

NUREG-2157 B-30 September 2014 

3. Accident analysis provides a perspective on the environmental impacts of a 

temporary lapse of institutional controls 

The GEIS considers the environmental impacts of accidents during continued storage (e.g., 

certain cask drop events) in Section 4.18. These accidents, for the purposes of this NEPA 

analysis may serve as a surrogate or proxy for the temporary loss of institutional controls, and 

the impacts of these accidents are representative of impacts from a temporary loss of 

institutional controls. An accident condition approximates a limited period during which 

institutional controls are less than effective, after which the NRC expects that institutional 

controls and oversight would resume. Consequences from accidents resulting in small releases 

represent a lapse in more routine maintenance tasks, whereas accidents resulting in significant 

radioactive releases constitute a reasonable surrogate to evaluate consequences that might 

result from hypothetical acts of radiological sabotage or terrorism in the indefinite timeframe. 

Consideration of accident consequences thereby provides a reasonable basis for understanding 

the consequences of continued storage should institutional controls prove temporarily 

ineffective. 

Given the physical characteristics of spent fuel, in most cases, the level of institutional controls 

necessary for safety would diminish over time and the consequences associated with accidents 

made possible by lapses in institutional controls would be expected to decrease with the 

passage of time. The thermal output of spent fuel decreases by approximately a factor of ten in 

the first 100 years after it is removed from the reactor, which means that maintenance activities 

and related institutional controls could be adjusted, as appropriate, to account for lower thermal 

loads. Therefore, the consequences of ineffective institutional controls will diminish over time 

because lower thermal loads should reduce the need for maintenance activities to maintain 

safety and lower radioactivity should reduce the consequences of releases of spent fuel. In 

contrast, institutional controls with respect to security many not diminish. As discussed in 

Section 4.19.2 of the GEIS, because spent fuel radiation levels will decrease over time, spent 

fuel could become more susceptible to theft or diversion (i.e., a more attractive target to 

individuals with malevolent intent). For this reason, additional security requirements may be 

necessary in the future if spent fuel remains in storage, to ensure that risk posed due to theft or 

diversion remains very low. 

4. Impacts of loss of institutional controls 

Some comments recommended that the NRC consider the evaluation of the loss of institutional 

controls based, in part, on DOE’s Yucca Mountain EIS (DOE 2008b), which included an 

analysis for the loss of institutional controls for storage facilities under the no-action alternative. 

The NRC notes that DOE’s proposed action in that instance was the construction of a repository 

and that, as a result, analysis of the no-action alternative was required by NEPA. Permanent 

disposal of spent fuel is a DOE responsibility, and DOE’s analysis was designed to evaluate the 

environmental impacts of not meeting that responsibility. DOE evaluated the storage of the total 
Appendix B 

September 2014 B-31 NUREG-2157 

volume of high-level waste (i.e., 70,000 MTU) that would be disposed at the repository and, as a 

means of evaluating what would happen if it took no action, it considered the consequences of a 

simultaneous loss of institutional controls at 72 commercial and 5 DOE storage sites. In 

contrast, this GEIS considers the environmental impacts of continued storage at a single 

generically profiled commercial facility. While the DOE analysis may have sufficed for DOE’s 

Yucca Mountain EIS, the NRC does not believe that the passive scenario assumed as part of 

the no-action alternative there provides a meaningful method of analyzing the consequences of 

indefinite storage for purposes of analyzing continued storage in this GEIS. 

DOE’s analysis evaluates degradation of the storage structures in the absence of human 

intervention (i.e., that neither government nor local residents, or even malevolent forces, would 

respond to the degradation in any fashion over a 10,000-year period). DOE did not state that its 

analysis of the loss of institutional controls represents the reasonably foreseeable impacts of 

permanent aboveground storage. To the contrary, DOE stated that neither of the no-action 

scenarios is likely to occur (DOE 2002). However, DOE’s Yucca Mountain EIS (DOE 2008b) 

concluded that the consequences of the potential loss of institutional controls could be 

“catastrophic” in some resource areas. 

As discussed previously, merely assuming loss of institutional controls in the distant, but 

undefined, future is not enough for the NRC to reasonably foresee when and how the loss of 

institutional controls might occur, and the consequences of that loss, with the kind of detailed 

and scientifically supportable analysis of resource impacts that the GEIS provides in every other 

respect for decision-makers and the public. Rather, the NRC would need to hypothesize the 

extent to which controls must fail before spent fuel would be effectively abandoned. The 

difficulty in predicting future consequences is further compounded by the lack of any credible 

way to foresee the combination of human and natural forces that might act on abandoned 

storage casks and cause a release. In addition, the baseline human environment becomes 

increasingly unpredictable the further out in time projections are made. 

Nevertheless, the NRC can state broadly that, if institutional controls should be lost through a 

gradual dissolution of government or an apocalyptic event, unmitigated physical deterioration of 

spent fuel casks and cladding over decades, if not centuries, would eventually expose 

radionuclides to the environment. While the consequences—as explained above—are 

unpredictable, the NRC can state qualitatively that the consequences of such a catastrophe to 

the environment and public health could be similar to the impacts DOE analyzed for the noaction alternative (scenario 2—permanent loss of institutional controls) in its Yucca Mountain 

EIS (assuming a similar number of facilities were considered). Thus, in the event of a 

permanent loss of institutional controls, the resulting consequences to the environment across 

nearly all resource areas would be clearly noticeable and destabilizing. 
Appendix B 

NUREG-2157 B-32 September 2014 

B.3.5 Summary of Technical Feasibility of Continued Storage 

As discussed previously, the NRC believes that it is reasonable to assume that the storage of 

spent fuel in any combination of storage in spent fuel pools or dry casks will continue as a 

licensed activity under regulatory controls and oversight. Licensees have continued to develop 

and successfully use onsite spent fuel storage capacity in the form of spent fuel pool and dry 

cask storage in a safe and environmentally sound fashion. Technical understanding and 

operational experience continues to support the technical feasibility of safe storage of spent fuel 

in spent fuel pools and in dry casks over long periods of time (e.g., slow degradation of spent 

fuel during storage in spent fuel pools and dry casks; engineered features of storage pools and 

dry casks to safely withstand accidents caused by either natural or man-made phenomena). In 

addition, regulatory oversight has been shown to enhance safety designs and operations as 

concerns and information evolve over time (e.g., safety enhancements made after the Three 

Mile Island accident in 1979, the September 11, 2001 terrorist attacks, and the March 11, 2011 

Fukushima Dai-ichi disaster. 

Based on the technical information and the national and international experience with wet and 

dry storage of spent fuel, the NRC concludes it is technically feasible to safely store spent fuel in 

either wet or dry storage for the short-term storage timeframe with only routine maintenance 

(i.e., no large-scale replacement of spent fuel pools or dry cask storage systems). 

In the GEIS, the NRC assumes that after the short-term storage timeframe, spent fuel is stored 

in dry casks. Further, as discussed previously, the NRC concludes that there is no technical 

reason that spent fuel cannot be safely stored in dry casks beyond the short-term storage 

timeframe. As discussed in this appendix, the degradation rates of spent fuel are low under dry 

storage conditions and the probability of accidents with large consequences are very low. 

Storage of spent fuel beyond the short-term storage timeframe would continue under an 

approved aging management program to ensure that monitoring and maintenance are 

adequately performed. Repackaging of spent fuel may be needed if storage continues beyond 

the short-term storage timeframe. In the GEIS, the NRC assumes the replacement of dry casks 

after 100 years of service life; however, actual replacement times will depend on actual 

degradation observed during continued regulatory oversight for maintaining safety during 

continued storage. Studies and experience to date do not preclude a dry cask service life 

longer than 100 years. Accidents associated with repackaging spent fuel are evaluated in 

Section 4.18 and the environmental impacts are SMALL because the accident consequences 

would not exceed the NRC accident dose standard contained in 10 CFR 72.106. The NRC 

concludes it is technically feasible to continue to store spent fuel beyond the short-term storage 

timeframe, which may include activities to repackage spent fuel. 

Section 4.19 of the GEIS describes the environmental impacts of potential acts of sabotage or 

terrorism involving the continued storage of spent fuel. This section acknowledges that as the 

immediate hazard posed by the high radiation levels of spent fuel diminishes over time so does 
Appendix B 

September 2014 B-33 NUREG-2157 

the deterrent to handling by unauthorized persons. The Blue Ribbon Commission’s report noted 

that “over long time periods (perhaps a century or more, depending on burnup and the level of 

radiation that is deemed to provide adequate self-protection), the fuel could become more 

susceptible to possible theft or diversion (although other safeguards would remain in 

place). This in turn could require changes to the security requirements for older spent 

fuel. Extending storage to timeframes of more than a century could thus require increasingly 

demanding and expensive security protections at storage sites.” If necessary, the NRC will 

issue orders or enhance its regulatory requirements for ISFSI security, as appropriate, to 

provide adequate protection of public health and safety and the common defense and security. 

B.4 Conclusions 

This appendix evaluates the technical feasibility of continued storage and repository availability, 

including national and international experience with storage and disposal of spent fuel. Based 

on the information and experience presented in this appendix, the NRC concludes that (1) a 

geologic repository is technically feasible; (2) the time period needed to develop a repository is 

approximately 25 to 35 years; (3) continued safe storage of spent fuel in spent fuel pools for the 

short-term timeframe is technically feasible; and (4) continued safe storage of spent fuel in dry 

casks for the timeframes considered in the GEIS is technically feasible. Further, the NRC 

concludes that a strong regulatory framework including both regulatory oversight and licensee 

compliance is important to the continued safe storage of spent fuel. As discussed in this 

appendix, the regulatory framework for storage is supported by well-developed regulatory 

guidance; voluntary domestic and international consensus standards; research and analytical 

studies; and processes for implementing licensing reviews, inspection programs, and 

enforcement oversight. 

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Available at http://www-pub.iaea.org/MTCD/publications/PDF/TRS413_web.pdf. 

IAEA (International Atomic Energy Agency). 2003b. Spent Fuel Performance Assessment and 

Research: Final Report of a Co-Ordinated Research Project on Spent Fuel Performance 

Assessment and Research (SPAR) 1997–2001. IAEA–TECDOC–1343, Vienna, Austria. 

Available at http://www-pub.iaea.org/MTCD/Publications/PDF/TE_1343_web.pdf. 

IAEA (International Atomic Energy Agency). 2005. Radioactive Waste Management Studies 

and Trends. IAEA/WMDB/ST/4, Vienna, Austria. Available at http://wwwpub.iaea.org/MTCD/publications/PDF/WMDB-ST-4.pdf. 

IAEA (International Atomic Energy Agency). 2006. Understanding and Managing Ageing of 

Materials in Spent Fuel Storage Facilities. Technical Reports Series No. 443, Vienna, Austria. 

Available at http://www-pub.iaea.org/MTCD/Publications/PDF/TRS443_web.pdf. 

IAEA (International Atomic Energy Agency). 2011a. Impact of High Burnup Uranium Oxide and 

Mixed Uranium-Plutonium Oxide Water Reactor Fuel on Spent Fuel Management. IAEA 

Nuclear Energy Series No. NF-T-3.8, Vienna, Austria. Available at http://wwwpub.iaea.org/MTCD/Publications/PDF/Pub1490_web.pdf. 

IAEA (International Atomic Energy Agency). 2011b. Disposal of Radioactive Wastes Specific 

Safety Requirements. SSR-5, Vienna, Austria. Available at: http://wwwpub.iaea.org/MTCD/publications/PDF/Pub1449_web.pdf. 

IAEA (International Atomic Energy Agency). 2013. Spent Fuel Storage Operation—Lessons 

Learned. IAEA TECDOC Series No. 1725, Vienna, Austria. Available at http://wwwpub.iaea.org/MTCD/Publications/PDF/TE-1725_web.pdf.

INPO (Institute of Nuclear Power Operations). 2011. Special Report on the Nuclear Accident at 

the Fukushima Dai-ichi Nuclear Power Station. INPO 11–005, Revision 0, Atlanta, Georgia. 

Available at http://www.wano.info/Documents/Lessons%20Learned.pdf.

In re Aiken County. 725 F.3d 255 (D.C. Cir. 2013). 
Appendix B 

NUREG-2157 B-38 September 2014 

Johnson, A.B. 1977. Behavior of Spent Nuclear Fuel in Water Pool Storage. BNWL–2256, 

Battelle–Pacific Northwest Laboratories, Richland, Washington. Available at 

http://www.ntis.gov/search/product.aspx?ABBR=BNWL2256. 

Johnson, A.B., Jr. 1978. “Utility Spent Fuel Storage Experience.” In Schumacher, J.F., ed. 

Executive Conference on Spent Fuel Policy and Its Implications. American Nuclear Society 

Executive Conference, April 2–5, 1978; Pineisle Resort, Buford, Georgia. University of 

Wisconsin, Madison, Wisconsin. 

MRWS (West Cumbria Managing Radioactive Waste Safely Partnership). 2012. The Final 

Report of the West Cumbria Managing Radioactive Waste Safely Partnership. Copeland 

Borough Council, Cumbia, United Kingdom. Available at 

http://www.westcumbriamrws.org.uk/images/final-report.pdf. 

NAS (National Academy of Sciences). 1995. Technical Bases for Yucca Mountain Standards. 

National Academy of Sciences/National Research Council of Board on Radioactive Waste 

Management, Committee on the Remediation of Buried and Tank Waste, National Academy 

Press, Washington, D.C. 

NAS (National Academy of Sciences). 2000. Long-Term Institutional Management of the U.S. 

Department of Energy Legacy Waste Sites. National Academy of Sciences/National Research 

Council of Board on Radioactive Waste Management, Committee on the Remediation of Buried 

and Tank Waste, National Academy Press, Washington, D.C. 

National Environmental Policy Act of 1969 (NEPA), as amended. 42 USC 4321 et seq.

NEA (Nuclear Energy Agency). 1997. Lessons Learnt from Ten Performance Assessment 

Studies. Organisation for Economic Co-Operation and Development, Paris, France. Available 

at http://www.oecd-nea.org/rwm/reports/1997/ipag.pdf. 

NEA (Nuclear Energy Agency). 2006. The Roles of Storage in the Management of Long-Lived 

Radioactive Waste. Organization for Economic Cooperation and Development, Paris, France. 

Available at https://www.oecd-nea.org/rwm/reports/2006/nea6043-storage.pdf. 

NEA (Nuclear Energy Agency). 2012. The Post-Closure Radiological Safety Case for a Spent 

Fuel Repository in Sweden. NEA/RWM/PEER(2012)2. Organization for Economic Cooperation 

and Development, Paris, France. Available at 

http://www.stralsakerhetsmyndigheten.se/Global/Slutförvar/NEA/SSM%202010-4132-

95%20Final%20Report_NEA_RWM_PEER_2012_2.pdf%20564893_1_1.pdf. 

New York v. NRC (State of New York et al. v. U.S. Nuclear Regulatory Commission). 681 F.3d 

471 (D.C. Cir. 2012). Accession No. ML12191A407. 
Appendix B 

September 2014 B-39 NUREG-2157 

NRC (U.S. Nuclear Regulatory Commission). 1979. TMI-2 Lessons Learned Task Force Status 

Report and Short Term Recommendations. NUREG–0578. Washington, D.C. Accession No. 

ML090060030. 

NRC (U.S. Nuclear Regulatory Commission). 1980a. NRC Action Plan Developed as a Result 

of the TMI-2 Accident. NUREG–0660, Washington, D.C. Accession Nos. ML072470526, 

ML072470524. 

NRC (U.S. Nuclear Regulatory Commission). 1980b. TMI-Related Requirements for New 

Operating Licenses. NUREG–0694, Washington, D.C. Accession No. ML072500081. 

NRC (U.S. Nuclear Regulatory Commission). 1980c. Clarification of TMI Action Plan 

Requirements. NUREG–0737, Washington, D.C. Accession No. ML051400209. 

NRC (U.S. Nuclear Regulatory Commission). 1996a. Memorandum from J.M. Taylor to NRC, 

dated July 26, 1996, regarding “Resolution of Spent Fuel Storage Pool Action Plan Issues.” 

Washington, D.C. Accession No. ML003706364. 

NRC (U.S. Nuclear Regulatory Commission). 1996b. Memorandum from J.M. Taylor to NRC, 

dated October 3, 1996, regarding “Assessment of Spent Fuel Cooling.” Washington, D.C. 

Accession No. ML003706381. 

NRC (U.S. Nuclear Regulatory Commission). 1997a. Operating Experience Feedback Report: 

Assessment of Spent Fuel Cooling. NUREG–1275, Volume 12, Washington, D.C. Accession 

No. ML010670175. 

NRC (U.S. Nuclear Regulatory Commission). 1997b. Memorandum from L.J. Callan to NRC 

dated September 30, 1997, regarding “Followup Activities on the Spent Fuel Pool Action Plan.” 

Washington, D.C. Accession No. ML003706412. 

NRC (U.S. Nuclear Regulatory Commission). 2000. Memorandum from J.T. Larkins to G.M. 

Holohan, dated May 2, 2000, regarding “Resolution of GSI-173, Spent Fuel Pool Cooling for 

Operating Plants.” Washington, D.C. Accession No. ML003710695. 

NRC (U.S. Nuclear Regulatory Commission). 2001. Technical Study of Spent Fuel Pool 

Accident Risk at Decommissioning Nuclear Power Plants. NUREG–1738, Washington, D.C. 

Accession No. ML010430066. 

NRC (U.S. Nuclear Regulatory Commission). 2006a. Letter from NRC to J. Parkyn, dated 

February 21, 2006, regarding “Issuance of Materials License No. SNM–2513 for the Private 

Fuel Storage Facility (TAC No. L23821).” Washington, D.C. Accession No. ML060450412. 
Appendix B 

NUREG-2157 B-40 September 2014 

NRC (U.S. Nuclear Regulatory Commission). 2006b. Liquid Radioactive Release Lessons 

Learned Task Force Final Report. Washington, D.C. Accession No. ML062650312. 

NRC (U.S. Nuclear Regulatory Commission). 2007. A Pilot Probabilistic Risk Assessment of a 

Dry Cask Storage System at a Nuclear Power Plant. NUREG–1864, Washington, D.C. 

Accession No. ML071340012. 

NRC (U.S. Nuclear Regulatory Commission). 2008. Minimization of Contamination and 

Radioactive Waste Generation: Life-Cycle Planning. Regulatory Guide 4.21, Washington, D.C. 

Accession No. ML080500187. 

NRC (U.S. Nuclear Regulatory Commission). 2009a. Degradation of Neutron-Absorbing 

Materials in the Spent Fuel Pool. IN 2009–26, Washington, D.C. Accession No. ML092440545. 

NRC (U.S. Nuclear Regulatory Commission). 2009b. “Radiological Environmental Monitoring 

For Nuclear Power Plants.” Regulatory Guide 4.1, Revision 2, Washington, D.C. Accession 

No. ML091310141. 

NRC (U.S. Nuclear Regulatory Commission). 2010a. U.S. Department of Energy’s Motion to 

Withdraw [Yucca Mountain]. ASLBP No. 09–892–HLW–CAB04., Washington, D.C. Accession 

No. ML100621397. 

NRC (U.S. Nuclear Regulatory Commission). 2010b. Safety Evaluation Report Related to 

Disposal of High-Level Radioactive Wastes in a Geologic Repository at Yucca Mountain, 

Nevada—Volume 1: General Information. NUREG–1949, Volume 1, Washington, D.C. 

Accession No. ML102440298. 

NRC (U.S. Nuclear Regulatory Commission). 2010c. Standard Review Plan for Spent Fuel Dry 

Storage Systems at a General License Facility. NUREG–1536, Revision 1, Washington, D.C. 

Accession No. ML101040620. 

NRC (U.S. Nuclear Regulatory Commission). 2010d. Groundwater Task Force Final Report. 

Washington, D.C. Accession No. ML101740509. 

NRC (U.S. Nuclear Regulatory Commission). 2011a. Technical Evaluation Report on the 

Content of the U.S. Department of Energy’s Yucca Mountain Repository License Application—

Preclosure Volume: Repository Safety Before Permanent Closure. NUREG–2108, 

Washington, D.C. Accession No. ML11250A093. 
Appendix B 

September 2014 B-41 NUREG-2157 

NRC (U.S. Nuclear Regulatory Commission). 2011b. Technical Evaluation Report on the 

Content of the U.S. Department of Energy’s Yucca Mountain Repository License Application—

Postclosure Volume: Repository Safety After Permanent Closure. NUREG–2107, 

Washington, D.C. Accession No. ML11223A273. 

NRC (U.S. Nuclear Regulatory Commission). 2011c. Technical Evaluation Report on the 

Content of the U.S. Department of Energy’s Yucca Mountain Repository License Application—

Administrative and Programmatic Volume. NUREG–2109, Washington, D.C. Accession No. 

ML11255A002. 

NRC (U.S. Nuclear Regulatory Commission). 2011d. Senior Management Review of Overall 

Regulatory Approach to Groundwater Protection. SECY–11–0019, Washington, D.C. 

Accession No. ML12338A692. 

NRC (U.S. Nuclear Regulatory Commission). 2012a. Letter to All Power Reactor Licensees 

and Holder of Construction Permits in Active or Deferred Status, dated March 12, 2012, 

regarding “Request for Information Persuant to Title 10 of the Code of Federal Regulations

50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review 

of Insights from the Fukushima Dai-Ichi Accident.” Washington, D.C. Accession No. 

ML12053A340. 

NRC (U.S. Nuclear Regulatory Commission). 2012b. Potential Chloride-Induced Stress 

Corrosion Cracking of Austenitic Stainless Steel and Maintenance of Dry Cask Storage System 

Canisters. IN 2012–20, Washington, D.C. Accession No. ML12319A440. 

NRC (U.S. Nuclear Regulatory Commission). 2012c. Decommissioning Planning During 

Operations. Regulatory Guide 4.22, Washington, D.C. Accession No. ML12158A361. 

NRC (U.S. Nuclear Regulatory Commission). 2012d. “Inspection Program for Dry Storage of 

Spent Reactor Fuel at Independent Spent Fuel Storage Installations and for 10 CFR Part 71 

Transportation Packages.” Chapter 2690 in NRC Inspection Manual. Washington, D.C. 

Accession No. ML120390415. 

NRC (U.S. Nuclear Regulatory Commission). 2013. “Memorandum and Order in the Matter of 

U.S Department of Energy (High Level Waste Repository).” CLI-13-08, Rockville, Maryland. 

Accession No. ML13322A744. 

NRC (U.S. Nuclear Regulatory Commission). 2014. Identification and Prioritization of the 

Technical Information Needs Affecting Potential Regulation of Extended Storage and 

Transportation of Spent Nuclear Fuel. Washington, D.C. Accession No. ML14043A423. 

Nuclear Waste Policy Act of 1982 (NWPA), as amended. 42 USC 10101 et seq.
Appendix B 

NUREG-2157 B-42 September 2014 

NWMO (Nuclear Waste Management Organization). 2008. Annual Report 2007: Moving 

Forward Together. Toronto, Ontario. Available at 

http://www.nwmo.ca/uploads_managed/MediaFiles/327_NWMO_2007_Annual_Report_E.pdf. 

NWMO (Nuclear Waste Management Organization). 2013. Annual Report 2012: Learning 

More Together. Toronto, Ontario. Available at 

http://www.nwmo.ca/uploads_managed/MediaFiles/2089_ar2012_english_web.pdf. 

Sindelar, R.L., A.J. Duncan, M.E. Dupont, P.-S. Lam, M.R. Louthan, Jr., and T.E. Skidmore. 

2011. Materials Aging Issues and Aging Management for Extended Storage and Transportation 

of Spent Nuclear Fuel. NUREG/CR–7116, Savannah River National Laboratory, Aiken, South 

Carolina. Accession No. ML11321A182.

Travis, R.J., R.E. Davis, E.J. Grove, and M.A. Azarm. 1997. Safety and Regulatory 

Assessment of Generic BWR and PWR Permanently Shutdown Nuclear Power Plants. 

NUREG/CR–6451, Brookhaven National Laboratory, Upton, New York. Accession No. 

ML082260098. 

VEPCO (Virginia Electric and Power Company). 2011. Virginia Electric and Power Company 

(Dominion) North Anna Power Station Units 1 and 2 North Anna Independent Spent Fuel 

Storage Installation Summary Report of August 23, 2011 Earthquake Response and Restart 

Readiness Determination Plan. Richmond, Virginia. Accession No. ML11262A151. 

Walker, J.F. 1979. Long-Term Storage of Irradiated CANDU Fuel Under Water. Whiteshell 

Nuclear Research Establishment, Pinawa, Manitoba. Available at 

http://www.ntis.gov/search/product.aspx?ABBR=N7932999. 
Appendix C 

–

Outreach and Correspondence 

September 2014 C-1 185(*௅

Appendix C 

Outreach and Correspondence 

This appendix provides a description of outreach activities and agencies and groups that the 

U.S. Nuclear Regulatory Commission (NRC) contacted during the preparation of this Generic 

Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel (GEIS), and a 

listing of correspondence related to the NRC’s environmental review. The NRC did not identify 

any cooperating agencies for the environmental review or receive any formal requests for 

cooperating agency status. 

C.1 Outreach 

The NRC staff conducted extensive outreach efforts during the preparation of the GEIS and 

Rule. 

WCOUTREACH E-mail: The NRC staff used an e-mail account, WCOutreach@nrc.gov, to 

distribute information to subscribers regarding Waste Confidence. Through this e-mail account, 

the NRC staff provided periodic updates on activities, links to new information published in the 

NRC's Agencywide Document Access and Management Systems (ADAMS), and links to 

inforPDWLRQRQWKH15&ZHEVLWH2Q2FWREHUZKHQWKH15&VWDIIH-mailed the 

scoping notice to subscribers, the NRC’s WCOutreach@nrc.gov e-mail distribution list consisted 

RIDSSUR[LPDWHO\LQGLYLGXDOVLQFOXGLQJLQGLYLGXDOVZKRH[SUHVVHGLQWHUHVW in previous 

spent nuclear fuel (spent fuel) studies and efforts; members of the public on mailing lists for new 

reactor and license renewal environmental reviews; representatives from Federal, Tribal, State, 

and local governments; and representatives from industry and public advocacy groups and 

environmental organizations. In the months following publication of the draft GEIS and 

proposed Rule, the e-mail distribution list expanded to approximately 3,200 subscribers. 

Public Meetings and Webinars: DXULQJWKH-day scoping comment period, the NRC 

conducted two webcast public scoping meetings and two webinars. The meetings and webinars 

each began with a slide presentation by NRC staff, which was followed by a question-andanswer period and a block of time dedicated to listening to and transcribing public scoping 

comments. During the 98-day public comment period on the draft GEIS and proposed Rule, the 

NRC conducted 13 public meetings on the draft documents. More information on the public 

comment period and meetings for the draft GEIS and proposed Rule can be found in 

Appendix D. Notices for all public meetings were published in the Federal Register, e-mailed, 

posted on the NRC website, and advertised by the NRC’s Office of Public Affairs through press 

releases. 
Appendix C 

185(*௅ C-2 September 2014 

NRC Website: Throughout the rulemaking process, the NRC maintained a Waste Confidence 

webpage at www.nrc.gov/waste/spent-fuel-storage/wcd.html. The NRC regularly updated the 

website, which contained a specific section titled “Public Involvement in Waste Confidence,” 

with related documents, new information, and frequently asked questions. The NRC will not 

maintain the Waste Confidence webpage after the revised Rule becomes effective. All 

documents posted on the Waste Confidence webpage are publicly available and all official 

agency records will continue to be available in ADAMS. 

Monthly Status Update Public Teleconferences: In the months following closure of the 

scoping period and through publication of the draft GEIS, the NRC staff held monthly public 

status teleconferences to provide an update on activities related to the Waste Confidence 

rulemaking and GEIS. One final teleconference was held following the closure of the draft GEIS 

and proposed Rule comment period. These were Category 3 meetings (the type of NRC 

meetings where public participation is actively sought)—the public was invited to attend via 

telephone and ask questions of the NRC staff. Status update teleconferences were for 

informational purposes only and any comments made and questions asked during the 

teleconferences were not counted as comments on draft GEIS and proposed Rule. Transcripts 

and summaries of the teleconferences were posted to the Waste Confidence Directorate “Public 

Involvement in Waste Confidence” webpage and are available in ADAMS. 

Tribal Contact: The scoping notice was mailed and e-mailed, when possible, to all Federally 

recognized Native American Tribes (1) located within 80 km (PL) of a nuclear power plant, 

(2) registered with the NRC for advance notification of shipments of irradiated reactor fuel and 

nuclear waste under Title 10 of the Code of Federal Regulations &)53DUWVDQGRU

(3) previously expressing interest in the NRC’s Yucca Mountain application activities (see 

ADAMS Accession No. ML12311A464 for an example of the Tribal outreach letter that 

transmitted the scoping notice and the tribal distribution list). Fifty-eight Tribal contacts were 

mailed a copy of the Waste Confidence scoping notice. In addition, the NRC corresponded with 

the Northern Chumash Tribal Council (recognized by the state of California) and the Santa Ynez 

Band of Chumash Indians (Federally recognized), which are both located near the Diablo 

Canyon Nuclear Plant. 

The NRC also distributed the draft GEIS, proposed Rule, and public meeting notices to Tribal 

contacts. A CD-ROM copy of the draft GEIS, a hardcopy of the proposed Rule, and public 

meeting information was PDLOHGWR6 Tribal contacts, and e-mail notification of the upcoming 

NRC mailing was also sent to those contacts with e-mail addresses. See ADAMS Accession 

1R0/$IRUDQH[DPSOH of the Tribal outreach letter that transmitted the draft GEIS, 

proposed Rule, and public meeting information. 

The NRC also initiated government-to-government consultation with the Prairie Island Indian 

Community. The Prairie Island Indian reservation is located adjacent to the Prairie Island 

Nuclear Generating Plant in Welch, Minnesota. Government-to-government meetings were 
Appendix C 

September 2014 C-3 185(*௅

held between the NRC and Tribal representatives on June 13, 2013 DQG'HFHPEHU. 

The Prairie Island Indian Community provided both oral and written comments during both the 

scoping and draft GEIS and proposed Rule comment periods. 

State Contact: The NRC provided the scoping notice and notice of publication of the draft 

GEIS, proposed Rule, and scheduled public comment meetings to state liaison officers in all 

agreement and nonagreement states. The NRC also provided notification of the public status 

teleconferences. 

U.S. Environmental Protection Agency (EPA) Contact: The NRC met with representatives of 

WKH(3$RQ1RYHPEHU7KHSXUSRVHRIWKHPHHWLQJZDVWRSURYLGHKLVWRULFDO

information on the Waste Confidence rule, to discuss the status of the environmental review and 

rulemaking, to discuss how the NRC was conducting new reactor and license renewal reviews 

in the interim while Waste Confidence was addressed, and to receive advice on the NRC’s 

approach. The EPA provided comments on the scope of the GEIS (Accession No. 

ML13028A469) and comments on the proposed Rule and draft GEIS (Accession No. 

ML14016A089). 

C.2 Correspondence 

This section contains a chronological listing of correspondence related to the NRC’s 

environmental review in preparation of this GEIS. The documents listed below can be found 

online through ADAMS at http://www.nrc.gov/reading-rm/adams.html. The ADAMS accession 

numbers for each document are included below. 

October 24, 2012 NRC to Hold Public Scoping Meetings for Waste Confidence 

Environmental Study Nov. 14 in Rockville, MD. Press Release 

No. 12-11$FFHVVLRQ1R0/$

2FWREHU Federal Register Notice of Intent to Prepare an Environmental Impact 

6WDWHPHQWDQG1RWLFHRI3XEOLF0HHWLQJV)5. Accession 

No. 0/$

2FWREHU E-mail from WCOutreach@nrc.gov, Federal Register Notice 

 FRN IRU:DVWH&RQILGHQFH(,6DQG6FRSLQJ. Accession 

No. 0/$

October 31, 2012 Forthcoming Waste Confidence Scoping Meetings for the Environmental 

Impact Statement (November 14, 2012). Accession No. ML12306A224. 
Appendix C 

185(*௅ C-4 September 2014 

October 31, 2012 Notification of the Scoping Process for the Environmental Impact 

Statement for the Waste Confidence Decision and Rule Update and 

Notice of Public Meetings and Webinars (FSME–12–$FFHVVLRQ

No. 0/$

November 6, 2012 E-mail from WCOutreach@nrc.gov, Link to Meeting Notice for Nov. 14 

Waste Confidence Scoping Meetings. Accession No. ML13120A483. 

November 8, 2012 E-mail from WCOutreach@nrc.gov, Federal Register Notice 

 FRN IRU:DVWH&RQILGHQFH(,6DQG6FRSLQJ—and Nov. 14 

Public Meeting Notice. Accession No. ML13120A481. 

November 8, 2012 Letter to NRC Commissioners, from G. Fettus, M. Goldstein, and 

D. Curran, Notice of Intent to Prepare Waste Confidence EIS. 

$FFHVVLRQ1R0/$

November 13, 2012 Letter to NRC Commissioners, from D. Brancato, Riverkeeper, Waste 

Confidence Scoping Meetings and Opportunity to Comment. Accession 

No. 0/$. 

November 13, 2012 E-mail from WCOutreach@nrc.gov, Direct Comment Link and Waste 

Confidence Scoping Meeting Slides. Accession No0/$

November 21, 2012 Forthcoming Webinars for the Environmental Impact Statement to 

6XSSRUWDQ8SGDWHG:DVWH&RQILGHQFH'HFLVLRQDQG5XOH'HFHPEHU

and 6, 2012). Accession No. ML12326A911. 

1RYHPEHU E-mail from WCOutreach@nrc.gov, 8SFRPLQJ'HFHPEHUDQG:DVWH

&RQILGHQFH:HELQDUV$FFHVVLRQ1R0/$

November 28, 2012 Letter to NRC Commissioners, from F. Collins, Tribal Administrator, 

Northern Chumash Tribal Council, Notice of Intent to Prepare Waste 

Confidence EIS. Accession No. ML13184A149. 

'HFHPEHU Letter to D. Curran, Harmon, Curran, Spielberg & Eisenberg, L.L.P., 

from A. Macfarlane, Chairman, NRC, regarding the Waste Confidence 

Scoping Process. Accession No. ML12319A309. (Identical letters sent 

to G. Fettus and M. Goldstein.) 

December 6, 2012 Summary of Public Scoping Meetings for Environmental Impact 

Statement to Support Waste Confidence Rulemaking (November 14, 

2012). Accession No. ML12339A281. 

December 26, 2012 Summary of Public Scoping Webinars for the Environmental Impact 

6WDWHPHQWWR6XSSRUWWKH:DVWH&RQILGHQFH5XOHPDNLQJ'HFHPEHU

and 6, 2012). $FFHVVLRQ1R0/$. 
Appendix C 

September 2014 C- 185(*௅

December 31, 2012 E-mail from WCOutreach@nrc.gov, Waste Confidence Scoping Meeting 

Summaries and Transcripts. Accession No. ML13120A480. 

December 31, 2012 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

Confidence Environmental Impact Statement and Rulemaking 

(January 16, 2013). Accession No. ML12366A201. 

January 2, 2013 Letter to F. Collins, Tribal Administrator, Northern Chumash Tribal 

Council, from K. McConnell, Director, Waste Confidence Directorate, 

NRC, regarding the Waste Confidence Scoping Process. Accession 

No. ML13002A221. 

January 6, 2013 Letter to NRC Commissioners, from S. Cohen, Government and Legal 

Specialist, Santa Ynez Band of Chumash Indians, Notice of Intent to 

3UHSDUH:DVWH&RQILGHQFH(,6$FFHVVLRQ1R0/

January 9, 2013 E-mail from WCOutreach@nrc.gov, Waste Confidence Monthly Public 

Teleconferences. Accession No. ML13120A484. 

January 11, 2013 Letter to S. Cohen, Government and Legal Specialist, Santa Ynez Band 

of Chumash Indians, from K. McConnell, Director, Waste Confidence 

Directorate, NRC, regarding the Waste Confidence Scoping Process. 

$FFHVVLRQ1R0/$

January 11, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

Confidence Environmental Impact Statement and Rulemaking 

(FSME–13–$FFHVVLRQ1R0/$

January 31, 2013 Summary of Public Teleconference to Discuss Status of Waste 

Confidence Environmental Impact Statement and Rulemaking 

(January 16, 2013). Accession No. ML13032A100. 

January 31, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

Confidence Environmental Impact Statement and Rulemaking 

(February 20, 2013). Accession No. ML13031A063. 

)HEUXDU\ Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

Confidence Environmental Impact Statement and Rulemaking 

(FSME-13–016). AccessLRQ1R0/$

)HEUXDU\ E-mail from WCOutreach@nrc.gov, Waste Confidence teleconference 

meeting summary, transcript and upcoming meeting. Accession 

No. 0/$
Appendix C 

185(*௅ C-6 September 2014 

March 1, 2013 Summary of Public Teleconference to Discuss Status of Waste 

Confidence Environmental Impact Statement and Rulemaking 

(February $FFHVVLRQ1R0/$

March 4, 2013 Summary Report for the Waste Confidence Generic Environmental 

Impact Statement Scoping Process. Accession No. ML13060A136. 

0DUFK E-mail from WCOutreach@nrc.gov, Waste Confidence scoping 

summary report and upcoming teleconference information. Accession 

1R0/$

0DUFK Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

Confidence Generic Environmental Impact Statement and Rulemaking 

0DUFK$FFHVVLRQ1R0/$

March 8, 2013 Letter to K. McConnell and A. Imboden, Waste Confidence Directorate, 

NRC, from D. Brancato, Riverkeeper, NRC Waste Confidence Update—

Request for Public Meeting. $FFHVVLRQ1R0/$

March 8, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

Confidence Environmental Impact Statement and Rulemaking 

(FSME–13–024). Accession No. ML13063A491. 

March 28, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

Confidence Generic Environmental Impact Statement and Rulemaking 

$SULO$FFHVVLRQ1R0/$

$SULO Summary of Public Teleconference to Discuss Status of Waste 

Confidence Environmental Impact Statement and Rulemaking 

(March $FFHVVLRQ1R0/$

$SULO Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

Confidence Environmental Impact Statement and Rulemaking 

(FSME-13–034). Accession No. ML13091A344. 

April 11, 2013 E-mail from WCOutreach@nrc.gov, Upcoming April public 

teleconference and March meeting summary and transcript. 

Accession No. ML13120A482. 

May 2, 2013 Summary of Public Teleconference to Discuss Status of Waste 

Confidence Environmental ,PSDFW6WDWHPHQWDQG5XOHPDNLQJ$SULO

$FFHVVLRQ1R0/$
Appendix C 

September 2014 C- 185(*௅

May 6, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

Confidence Generic Environmental Impact Statement and Rulemaking 

(May 29, 2013). Accession No. 0/$

May 8, 2013 E-PDLOIURP:&2XWUHDFK#QUFJRY:DVWH&RQILGHQFH$SULOPHHWLQJ

summary and transcript, and May 29 meeting notice. Accession 

No. 0/$

May 14, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

Confidence Generic Environmental Impact Statement and Rulemaking 

(FSME-13-$FFHVVLRQ1R0/$

May 14, 2013 Letter to D. Brancato, Riverkeeper, from K. McConnell, NRC, regarding 

NRC Waste Confidence Update—Request for Public Meeting. 

Accession No. ML13126A214. 

May 23, 2013 Letter to NRC Commissioners, from K. Landis-Marinello, Assistant 

Attorney General, State of Vermont, States’ Petition for Review of NRC 

6WDII6FRSLQJ'HFLVLRQ6SHQW)XHO6WRUDJH(,65,1-AJ20; 

NRC-2012-0246). Accession No. ML13149A446. 

May 24, 2013 Letter to A. Vietti-Cook, Secretary of the Commission, NRC, from 

K. Landis-Marinello, Assistant Attorney General, State of Vermont, 

Distributing States’ Petition for Review of NRC Staff Scoping Decision; 

Spent Fuel Storage E,65,1-AJ20; NRC-2012-0246). Accession 

No. ML13149A446. 

May 30, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

Confidence Generic Environmental Impact Statement and Rulemaking 

-XQH$FFHVVLRQ1R0/$

June 4, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

Confidence Generic Environmental Impact Statement and Rulemaking 

(FSME-13-$FFHVVLRQ1R0/$

June 6, 2013 Summary of Public Teleconference to Discuss Status of Waste 

Confidence Generic Environmental Impact Statement and Rulemaking 

0D\$FFHVVLRQ1R0/$

June 13, 2013 E-mail from WCOutreach@nrc.gov, Waste Confidence June 19th status 

teleconferencing notice, and May 29th meeting summary and transcript. 

$FFHVVLRQ1R0/$
Appendix C 

185(*௅ C-8 September 2014 

June 24, 2013 E-mail from WCOutreach@nrc.gov, Waste Confidence Commission 

UHYLHZGUDIWGRFXPHQWVQRZDYDLODEOH$FFHVVLRQ1R0/$

-XO\ E-mail from WCOutreach@nrc.gov, Waste Confidence June 19th Status 

Teleconference Meeting Summary and Transcript. Accession 

No. ML13219A201. 

July 23, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

Confidence Generic Environmental Impact Statement and Rulemaking 

(August 14, 2013). AccessLRQ1R0/$

July 23, 2013 Letter to W. Sorrell, Attorney General, State of Vermont, from A. 

Macfarlane, Chairman, NRC, regarding the Petition for Review of Staff 

6FRSLQJ'HFLVLRQ$FFHVVLRQ1R0/$,GHQWLFDOOHWWHUVVHQW

to D. Springer, G. Jepsen, M. Coakley, and E. Schneiderman.) 

July 31, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

Confidence Generic Environmental Impact Statement and Rulemaking 

(FSME-13-$FFHVVLRQ1R0/$

$XJXVW E-mail from WCOutreach@nrc.gov, Commission Approves Publication of 

Proposed Waste Confidence Rule and Draft Generic EIS. Accession 

No. ML13219A211. 

August 20, 2013 Letter to A. Macfarlane, Chairman, NRC, from D. Kraft, Director, Nuclear 

Energy Information Service, regarding TIME SENSITVE—request for 

NRC to hold waste confidence meeting in Chicago. Accession No. 

ML13233A338. 

August 21, 2013 Summary of August Public Teleconference to Discuss Status of Waste 

Confidence Generic Environmental Impact Statement and Rulemaking 

(August 14, 2013). Accession No. ML13234A111. 

August 22, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

Confidence Generic Environmental Impact Statement and Rulemaking 

(September 12, 2013$FFHVVLRQ1R0/$

August 29, 2013 Letter to D. Kraft, Director, Nuclear Energy Information Service, from A. 

Vietti-Cook, Secretary of the Commission, NRC, regarding letter to 

Chairman A. Macfarlane dated August 20, 2013. Accession No. 

ML13241A442. 
Appendix C 

September 2014 C-9 185(*௅

September 3, 2013 Notice of Public Meeting to Receive Comments on the Waste 

Confidence Draft Generic Environmental Impact Statement and 

Proposed Rule (Rockville, MD; October 1, 2013). Accession No. 

0/$

September 3, 2013 Notice of Public Meeting to Receive Comments on the Waste 

Confidence Draft Generic Environmental Impact Statement and 

Proposed Rule (Denver, CO; October 3, 2013). Accession No. 

ML13246A461. 

September 4, 2013 Letter to Senator B. Boxer, Chairman, Committee on Environment and 

Public Works, U.S. Senate, from A. Powell, Office of Congressional 

Affairs, NRC, regarding Waste Confidence Draft Generic Environmental 

Impact Statement and Proposed 5XOH$FFHVVLRQ1R0/$ 

(Identical letters sent to Senators F. Upton, E. Whitfield, J. Shimkus, and 

T. Carper, with cc to Representatives H. Waxman, B. Rush, P. Tonko, 

and J. Sessions.) 

September 4, 2013 E-mail from WCOutreach@nrc.gov, Important Waste Confidence Public 

Participation Information. Accession No. 0/$. 

6HSWHPEHU NRC Schedules 12 Meetings Nationwide on Waste Confidence 

Proposed Rule and Environmental Study. Press Release No. 13-

$FFHVVLRQ1R0/$

September , 2013 Notice of Public Meeting to Receive Comments on the Waste 

Confidence Draft Generic Environmental Impact Statement and 

3URSRVHG5XOH6DQ/XLV2ELVSR&$2FWREHU—postponed). 

Accession No. ML13248A323. 

6HSWHPEHU Notice of Public Meeting to Receive Comments on the Waste 

Confidence Draft Generic Environmental Impact Statement and 

Proposed Rule (Carlsbad, CA; October 9, 2013—postponed). Accession 

No. ML13248A338. 

6HSWHPEHU Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

Confidence Generic Environmental Impact Statement and Rulemaking 

(FSME-13-$FFHVVLRQ1R0/$

September 6, 2013 Federal Register Notice of public meetings, Proposed Waste Confidence 

5XOHDQG'UDIW*HQHULF(QYLURQPHQWDO,PSDFW6WDWHPHQW)5

Accession No. ML14141A269. 
Appendix C 

185(*௅ C-10 September 2014 

September 6, 2013 E-mail from WCOutreach@nrc.gov, Waste Confidence Draft Generic 

Environmental Impact Statement now available. Accession No. 

0/$. 

September 6, 2013 Notice of Public Meeting to Receive Comments on the Waste 

Confidence Draft Generic Environmental Impact Statement and 

3URSRVHG5XOH3HUU\VEXUJ2+2FWREHU—postponed). 

Accession No. ML13249A443. 

September 6, 2013 Notice of Public Meeting to Receive Comments on the Waste 

Confidence Draft Generic Environmental Impact Statement and 

Proposed Rule (Minnetonka, MN; October , 2013—postponed). 

Accession No. ML$. 

September 6, 2013 Notice of Public Meeting to Receive Comments on the Waste 

Confidence Draft Generic Environmental Impact Statement and 

Proposed Rule (Chelmsford, MA; October 28, 2013). Accession No. 

ML132$. 

September 6, 2013 Notice of Public Meeting to Receive Comments on the Waste 

Confidence Draft Generic Environmental Impact Statement and 

Proposed Rule (Tarrytown, NY; October 30, 2013). Accession No. 

ML1$. 

September 6, 2013 Notice of Public Meeting to Receive Comments on the Waste 

Confidence Draft Generic Environmental Impact Statement and 

Proposed Rule (Charlotte, NC; November 4, 2013). Accession No. 

0/$

September 6, 2013 Notice of Public Meeting to Receive Comments on the Waste 

Confidence Draft Generic Environmental Impact Statement and 

Proposed Rule (Orlando, FL; November 6, 2013). Accession No. 

0/$. 

September 6, 2013 Notice of Public Meeting to Receive Comments on the Waste 

Confidence Draft Generic Environmental Impact Statement and 

Proposed Rule (Rockville, MD; November 14, 2013). Accession No. 

ML13249A. 
Appendix C 

September 2014 C-11 185(*௅

September 6, 2013 Notice of Public Meeting to Receive Comments on the Waste 

Confidence Draft Generic Environmental Impact Statement and 

Proposed Rule (Oak Brook, IL; October 24, 2013—postponed). 

Accession No. ML$. 

September 12, 2013 NRC Seeks Public Comment on Proposed Rule and Environmental 

Study of Extended Storage of Spent Nuclear Fuel. Press Release No. 

13-$FFHVVLRQ1R0/$

September 13, 2013 Federal Register Notice of proposed rule, Waste Confidence—

Continued 6WRUDJHRI6SHQW1XFOHDU)XHO)5 Accession 

No. 0/$

September 13, 2013 Federal Register Notice of draft generic environmental impact statement; 

public meetings and request for comment, Draft Waste Confidence 

*HQHULF(QYLURQPHQWDO,PSDFW6WDWHPHQW)5$FFHVVLRQ1R

0/$. 

September 13, 2013 Opportunity to Comment on Draft Generic Environmental Impact 

6WDWHPHQWDQG3URSRVHG5XOHWR$PHQG&)53DUW—Waste 

Confidence—Continued Storage of Spent Nuclear Fuel (FSME-13-094). 

Accession No. 0/$

September 13, 2013 E-mail from WCOutreach@nrc.gov, Announcing the start of the Waste 

Confidence public comment period. Accession No. 0/$. 

September 16, 2013 Letter to F. Collins, Tribal Administrator, Northern Chumash Tribal 

Council, from K. McConnell, Waste Confidence Directorate, NRC, 

Opportunity to Comment on Draft Generic Environmental Impact 

6WDWHPHQWDQG3URSRVHG5XOHWR$PHQG&)5—Waste 

Confidence—Continued Storage of Spent Nuclear Fuel. Accession No. 

0/$,GHQWLFDOOHWWHUVVHQWWR additional Tribal contacts 

and the National Congress of American Indians.) 

September 18, 2013 E-mail from S. Lopas, Waste Confidence Directorate, NRC, Notification 

of upcoming Nuclear Regulatory Commission mailing. Accession No. 

ML$. (E-PDLOVHQWWRTribal contacts.) 

September 19, 2013 Federal Register Notice of public meetings, Proposed Waste Confidence 

5XOHDQG'UDIW*HQHULF(QYLURQPHQWDO,PSDFW6WDWHPHQW)5

Accession No. ML14160B249. 
Appendix C 

185(*௅ C-12 September 2014 

September 19, 2013 Letter to A. Macfarlane, NRC, from Representative H. Johnson, 

U.S. House of Representatives, regarding request for a Waste 

Confidence public meeting in Atlanta, Georgia. Accession No. 

ML13263A063. 

September 24, 2013 Summary of September Public Teleconference to Discuss Status of 

Waste Confidence Generic Environmental Impact Statement and 

Rulemaking (6HSWHPEHU$FFHVVLRQ1R0/$

6HSWHPEHU E-mail from WCOutreach@nrc.gov, Confirming our October 3 Denver 

meeting and meeting registration instructions. Accession No. 

0/$. 

September 30, 2013 E-mail from WCOutreach@nrc.gov, This week's Waste Confidence 

meetings will be held. Accession No. 0/$. 

October 4, 2013 E-mail from WCOutreach@nrc.gov, Waste Confidence California 

Meetings have been Postponed. Accession No. ML14141A163. 

October 4, 2013 NRC Postpones California Meetings on Waste Confidence Because of 

Government Shutdown. Press Release No. 13-083. Accession No. 

0/$

October 4, 2013 Letter to A. Macfarlane, Chairman, NRC, from D. Curran, Harmon, 

Curran, Spielberg & Eisenberg, L.L.P., regarding Government Shutdown 

and Waste Confidence Meetings. Accession No. ML13281A829. 

(Identical letter sent to M. Goldstein.) 

2FWREHU Letter to Secretary, Commissioners, NRC, from M. Olson, Nuclear 

Information and Resource Service, Southeast, regarding Public 

&RPPHQWRQWKH*(,6RQ:DVWH&RQILGHQFH185(*DQG

SURSRVHG:DVWH&RQILGHQFH5XOH&)5$FFHVVLRQ1R

ML13281A840. 

October 9, 2013 Summary of October 1 Public Meeting in Rockville, Maryland, to Receive 

Comments on the Waste Confidence Draft Generic Environmental 

Impact Statement and Proposed Rule. Accession No. ML13282A611. 

October 9, 2013 E-mail from WCOutreach@nrc.gov, POSTPONED: Perrysburg and 

Minnetonka Waste Confidence Meetings. Accession No. ML14141A166. 
Appendix C 

September 2014 C-13 185(*௅

October 9, 2013 E-mail from WCOutreach@nrc.gov, POSTPONED: Oak Brook Waste 

Confidence Meeting. Accession No. 0/$. 

October 9, 2013 NRC Postpones Ohio, Minnesota Meetings on Waste Confidence 

Because of Government Shutdown. Press Release No. 13-

$FFHVVLRQ1R0/$

October 18, 2013 Notice of Public Meeting to Receive Comments on the Waste 

Confidence Draft Generic Environmental Impact Statement and 

Proposed Rule (Oak Brook, IL; November 12, 2013—new date). 

Accession No. ML13291A322. 

October 18, 2013 Notice of Public Meeting to Receive Comments on the Waste 

Confidence Draft Generic Environmental Impact Statement and 

Proposed Rule (Carlsbad, CA; November 18, 2013—new date). 

Accession No. ML13294A063. 

October 18, 2013 Notice of Public Meeting to Receive Comments on the Waste 

Confidence Draft Generic Environmental Impact Statement and 

Proposed Rule (San Luis Obispo, CA; November 20, 2013—new date). 

$FFHVVLRQ1R0/$

October 18, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

Confidence Generic Environmental Impact Statement and Rulemaking 

(October 30, 2013$FFHVVLRQ1R0/$

October 21, 2013 E-mail from WCOutreach@nrc.gov, Announcing new dates for Oak 

Brook, Carlsbad, and San Luis Obispo meetings. Accession No. 

0/$. 

October 22, 2013 Summary of October 3 Public Meeting in Denver, Colorado, to Receive 

Comments on the Waste Confidence Draft Generic Environmental 

,PSDFW6WDWHPHQWDQG3URSRVHG5XOH$FFHVVLRQ1R0/$

October 23, 2013 Letter to Representative H. Johnson, U.S. House of Representatives, 

from A. Macfarlane, Chairman, NRC, regarding letter dated September 

19, 2013, requesting a Waste Confidence public meeting in Atlanta, 

*HRUJLD$FFHVVLRQ1R0/4$

2FWREHU NRC Schedules Nov. 4 Meeting in Charlotte to Take Comments on 

Proposed Spent Nuclear Fuel Rule and Environmental Study. Press 

Release No. II-13-$FFHVVLRQ 1R0/$
Appendix C 

185(*௅ C-14 September 2014 

October , 2013 Notice of Public Meeting to Receive Comments on the Waste 

Confidence Draft Generic Environmental Impact Statement and 

Proposed Rule (Perrysburg, OH; December 2, 2013—new date). 

Accession No. ML13298A120. 

2FWREHU Notice of Public Meeting to Receive Comments on the Waste 

Confidence Draft Generic Environmental Impact Statement and 

Proposed Rule (Minnetonka, MN; December 4, 2013—new date). 

Accession No. ML13298A118. 

October 28, 2013 NRC Extends Public Comment Period for Proposed Rule and 

Environmental Study on Extended Storage of Spent Nuclear Fuel. Press 

Release No. 13-$FFHVVLRQ1R0/$

October 28, 2013 NRC Schedules Nov. 6 Meeting in Orlando to Take Comments on 

Proposed Spent Nuclear Fuel Rule and Environmental Study. Press 

Release No. II-13-060. Accession No. ML$. 

October 28, 2013 E-mail from WCOutreach@nrc.gov, Waste Confidence comment period 

extension and important public meeting information. Accession No. 

0/$. 

October 28, 2013 Letter to B. Rafter, Executive Director, Georgia Women’s Action for New 

Directions, from K. McConnell, Waste Confidence Directorate, NRC, 

regarding Request for Waste Confidence Public Meeting in Atlanta. 

$FFHVVLRQ1R0/$

October 29, 2013 Federal Register Notice of rescheduling of public meeting, Proposed 

Waste Confidence Rule and Draft Generic Environmental Impact 

6WDWHPHQW)5$FFHVVLRQ1R0/$. 

October 29, 2013 Federal Register Notice of rescheduling of public meetings, Proposed 

Waste Confidence Rule and Draft Generic Environmental Impact 

6WDWHPHQW)5$FFHVVLRQ1RML14141A266. 

October 29, 2013 Notice of Public Teleconference to Receive Comments on the Waste 

Confidence Draft Generic Environmental Impact Statement and 

Proposed Rule (December 9, 2013). Accession No. ML13%. 

October 31, 2013 E-mail from WCOutreach@nrc.gov, Important correction for Waste 

Confidence December 9th teleconference. Accession No. 

0/$. 
Appendix C 

September 2014 C- 185(*௅

November 4, 2013 Federal Register Notice of rescheduling of public meetings, Proposed 

Waste Confidence Rule and Draft Generic Environmental Impact 

6WDWHPHQW)5$FFHVVLRQ1R0/$. 

1RYHPEHU Letter to D. Curran, Harmon, Curran, Spielberg & Eisenberg, L.L.P., from 

A. Macfarlane, Chairman, NRC, regarding Government Shutdown and 

Waste Confidence MeeWLQJV$FFHVVLRQ1R0/$3. 

1RYHPEHU Federal Register Notice of proposed rule, extension of comment period, 

Waste Confidence—Continued Storage of Spent Nuclear Fuel. 

)5Accession No. 0/$. 

November 18, 2013 E-mail from WCOutreach@nrc.gov, Availability of transcripts, meeting 

handouts and the remaining public meetings. Accession No. 

ML14141A162. 

November 19, 2013 Summary of October 28 Public Meeting in Chelmsford, Massachusetts, 

to Receive Comments on the Waste Confidence Draft Generic 

Environmental Impact Statement and Proposed Rule. Accession No. 

0/%

November 19, 2013 Summary of October 30 Public Meeting in Tarrytown, New York, to 

Receive Comments on the Waste Confidence Draft Generic 

Environmental Impact Statement and Proposed Rule. Accession No. 

ML13323B. 

November 19, 2013 Summary of October Public Teleconference to Discuss Status of Waste 

Confidence Generic Environmental Impact Statement and Rulemaking. 

Accession No. ML13323B491. 

1RYHPEHU Summary of November 4 Public Meeting in Charlotte, North Carolina, to 

Receive Comments on the Waste Confidence Draft Generic 

Environmental Impact Statement and Proposed Rule. Accession No. 

ML$. 

1RYHPEHU Summary of November 6 Public Meeting in Orlando, Florida, to Receive 

Comments on the Waste Confidence Draft Generic Environmental 

,PSDFW6WDWHPHQWDQG3URSRVHG5XOH$FFHVVLRQ1R0/$ 
Appendix C 

185(*௅ C-16 September 2014 

December 10, 2013 Summary of November 12 Public Meeting in Oak Brook, Illinois, to 

Receive Comments on the Waste Confidence Draft Generic 

Environmental Impact Statement and Proposed Rule. Accession No. 

ML13343A161. 

December 12, 2013 Summary of November 14 Public Meeting in Rockville, Maryland, to 

Receive Comments on the Waste Confidence Draft Generic 

Environmental Impact Statement and Proposed Rule. Accession No. 

ML$. 

December 12, 2013 E-mail from WCOutreach@nrc.gov, Availability of Meeting Summaries 

and Transcripts. Accession No. 0/$. 

'HFHPEHU E-mail from WCOutreach@nrc.gov, Reminder: Waste Confidence public 

comment period closes this Friday, December 20. Accession No. 

0/$. 

'HFHPEHU Letter to A. Macfarlane, Chairman, NRC, from B. Gibson, Board of 

Supervisors, San Luis Obispo County, regarding Waste Confidence Rule 

and Diablo Canyon Power Plant. Accession No. ML14008A021. 

December 18, 2013 Letter to M. Olson, Nuclear Information and Resource Service, 

Southeast, from A. Macfarlane, Chairman, NRC, regarding Public 

Comment on the *(,6RQ:DVWH&RQILGHQFH185(*DQG

SURSRVHG:DVWH&RQILGHQFH5XOH&)5$FFHVVLRQ1R

ML13282A228. 

December 18, 2013 Summary of November 18 Public Meeting in Carlsbad, California, to 

Receive Comments on the Waste Confidence Draft Generic 

Environmental Impact Statement and Proposed Rule. Accession No. 

0/$

December 18, 2013 Summary of November 20 Public Meeting in San Luis Obispo, California, 

to Receive Comments on the Waste Confidence Draft Generic 

Environmental Impact Statement and Proposed Rule. Accession No. 

0/$. 

December 18, 2013 Summary of December 2 Public Meeting in Perrysburg, Ohio, to Receive 

Comments on the Waste Confidence Draft Generic Environmental 

Impact Statement DQG3URSRVHG5XOH$FFHVVLRQ1R0/$. 
Appendix C 

September 2014 C- 185(*௅

December 18, 2013 Summary of December 4 Public Meeting in Minnetonka, Minnesota, to 

Receive Comments on the Waste Confidence Draft Generic 

Environmental Impact Statement and Proposed Rule. Accession No. 

0/$486. 

December 20, 2013 Summary of December 9 Public Teleconference to Receive Comments 

on the Waste Confidence Draft Generic Environmental Impact Statement 

DQG3URSRVHG5XOH$FFHVVLRQ1R0/&

January 8, 2014 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

Confidence Generic Environmental Impact Statement and Rulemaking 

(January 29, 2014). Accession No. ML14008A104. 

January 8, 2014 E-mail from WCOutreach@nrc.gov, Waste Confidence January 29th 

status teleconference meeting notice. Accession No. ML14141A180. 

January 16, 2014 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

Confidence Generic Environmental Impact Statement and Rulemaking. 

(FSME-14-0). Accession No. ML14016A389. 

January 23, 2014 NRC Revises Review Schedule for Waste Confidence Environmental 

Study and Final Rule. Press Release No. 14-003. Accession No. 

0/$

January 23, 2014 E-mail from WCOutreach@nrc.gov, Waste Confidence schedule 

adjustment. Accession No. ML14141A181. 

February 14, 2014 Summary of January 29 Public Teleconference to Discuss Status of 

Waste Confidence Generic Environmental Impact Statement and 

Rulemaking. Accession No. 0/$

February 18, 2014 Letter to B. Gibson, Board of Supervisors, San Luis Obispo County, from 

A. Vietti-Cook, Secretary of the Commission, NRC, regarding letter to 

Chairman Allison M. Macfarlane, GDWHG'HFHPEHU. Accession 

1R0/$

0DUFK E-mail from WCOutreach@nrc.gov, Waste Confidence Public 

Commission Meeting—March 21, 2014, at 1:00p EDT. Accession No. 

0/$. 
Appendix C 

NUREG௅2157 C-18 September 2014 

March 13, 2014 Notification of the NRC Staff's Commission Paper SECY-14-0025 on 

Waste Confidence and Upcoming Commission Meeting (FSME-14-025). 

Accession No. ML14071A441. 

March 19, 2014 E-mail from WCOutreach@nrc.gov, How to access this Friday's 

Commission meeting on Waste Confidence. Accession No. 

ML14141A160. 

March 26, 2014 E-mail from WCOutreach@Nrc.gov, Waste Confidence Commission 

meeting transcript, slides, and archived webcast. Accession No. 

ML14141A161. 

April 24, 2014 Letter to A. Imboden, NRC, from the States of Vermont and Connecticut, 

and the Commonwealth of Massachusetts, Need for a supplemental 

waste confidence DGEIS (Docket NRC-2012-0246). Accession No. 

ML14118A077. 

References 

10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, "Packaging and 

Transportation of Radioactive Material." Washington, D.C. 

10 CFR Part 73. Code of Federal Regulations, Title 10, Energy, Part 73, “Physical Protection of 

Plants and Materials.” Washington, D.C. 
Appendix D 

–

Draft GEIS and Proposed Rule 

Comment Summaries and Responses 

September 2014 D-1 185(*௅

Appendix D 

Draft GEIS and Proposed Rule 

Comment Summaries and Responses 

See NUREG-9ROXPHIRU$SSHQGL[''UDIW*(,6DQG3URSRVHG5XOH&RPPHQW

6XPPDULHVDQG5HVSRQVHV

Appendix E 

–

Analysis of Spent Fuel Pool Leaks 

September 2014 E-1 185(*௅

Appendix E 

Analysis of Spent Fuel Pool Leaks 

This appendix describes the environmental impacts of spent fuel pool leaks during the shortterm storage timeframe.1

 For the analysis presented in this Generic Environmental Impact 

Statement for Continued Storage of Spent Nuclear Fuel (GEIS), the U.S. Nuclear Regulatory 

Commission (NRC) assumes that spent nuclear fuel (spent fuel) is removed from the pool within 

60 years of the end of the reactor’s licensed life for operation. Once removed from the spent 

fuel pool, the spent fuel will be transferred to dry casks for storage in an independent spent fuel 

storage installation or shipment to a repository. 

As described in Section E.2, this appendix evaluates the potential offsite (i.e., outside the 

owner-controlled area) environmental impacts of spent fuel pool leaks. The environmental 

consequences of accidents, (e.g., cask drops) and natural events (e.g., earthquakes) that 

damage the spent fuel pool structure and result in a catastrophic loss of water volume in the 

spent fuel pool are discussed in Section 4.18 and Appendix F.

Section E.1 provides a historical overview of information pertaining to spent fuel pool leaks, 

including information on spent fuel pool designs, operation, and the history of spent fuel pool 

leaks at commercial nuclear power plants. Section E.2 describes the potential offsite 

environmental impacts of spent fuel pool leaks to groundwater, surface water, soils, and public 

health. Section E.3 presents historical data on spent fuel pool leaks. 

E.1 Background 

As of May 2014, 100 commercial nuclear reactors are licensed to operate in the United States, 

and DGGLWLRQDOXQLWVare under construction. These operating reactors are located at 62 sites 

in 30 states (Figure E-1). Of these 100 reactors, 6 are pressurized water reactorVDQGDUH

boiling water reactors. Because some of these reactors share spent fuel pools, there are 

SUHVVXUL]HGZDWHUUHDFWRUDQG boiling water reactor spent fuel pools. In addition to operating 

UHDFWRUVSHQWIXHOSRROVWKHUHDUHVL[VSHQWIXHOSRROVSUHVVXUL]HGZDWHUUHDFWRUERLOLQJ

water reactor) located at five decommissioning reactors sites. 

 

1

 As discussed in Section 1.8, the NRC assumes that all spent fuel is removed from the pools and placed 

in dry-cask storage by the end of the short-term storage timeframe. This appendix, therefore, does not 

analyze the impacts of a spent fuel pool leak after the short-term storage timeframe because a spent fuel 

pool will not be used to store spent fuel after that time. 
Appendix E 

185(*௅ E-2 September 2014 

Figure E-1. Locations of U.S. Nuclear Power Plants (NRC 2013a)

E.1.1 Spent Fuel Pools 

Figure E-2 shows diagrams of generic pressurized water reactor and boiling water reactor spent 

fuel pools. In general, spent fuel pools for boiling water reactor plants are elevated structures 

within the containment building and are filled with demineralized water. Spent fuel pools at 

pressurized water reactors are generally located in an auxiliary building adjacent to the reactor 

building and contain borated water (e.g., 2,200 to 2,400 ppm boron, pH ~4.8). A typical spent 

fuel pool for a pressurized water reactor is about 12 m [40 ft] deep and 12 m [40 ft] or more in 

each horizontal direction (Copinger et al. 2012). Water is maintained at a minimum depth of at 

least 6 m [20 ft] above the spent fuel bundles to ensure sufficient shielding of the spent fuel 

bundles. Water levels are maintained by periodically adding water to the pool to compensate 

for evaporation. Typically, the reinforced concrete walls are between 0.6 and 3 m [2 and 10 ft] 

thick and the inside surfaces are lined by welded stainless-steel plates to form a leak-tight 

barrier. These plates are generally about 6 to 13 PP>WRLQ.] thick and joined by fullpenetration seam welds. The liner plates may also be plug welded between the seams to studs 

embedded in the concrete. In addition, all licensees actively monitor spent fuel pools for 

leakage, either directly though leak-detection systems or through various procedural controls. 

Leak-detection systems typically consist of several channels installed over the seams formed 

when spent fuel pool liner plates are welded together. These channels often can be monitored 

individually and are designed so leaked water empties into drains (i.e., “tell-tale” drains) where it 

can be monitored and returned to either sumps or other cleanup or collection systems 

(NRC D). 
Appendix E 

September 2014 E-3 185(*௅

(a) 

(b) 

Figure E-2. Generic Layouts of Spent Fuel Pools and Transfer Systems for (a) Pressurized 

:DWHU5HDFWRUVDQGE%RLOLQJ:DWHU5HDFWRUV15&D
Appendix E 

185(*௅ E-4 September 2014 

In addition, spent fuel pools are serviced by spent fuel pool cooling and purification systems. 

These systems provide cooling to the spent fuel in the pool, provide makeup water to the pool, 

maintain water chemistry, and remove fission products from the spent fuel pool water. 

There is also one standalone spent fuel pool facility in the United States, the GE-Hitachi Nuclear 

Energy Americas, LLC, Morris wet storage facility (GEH Morris) in Morris, Illinois (DOE 2003). 

Though GEH Morris was originally designed as a commercial reprocessing facility, only the 

storage facility was completed and remains in operation. GEH Morris currently holds 

 spent fuel assemblies from commercial nuclear power plants. These spent fuel 

assemblies are stored in two pools. As with spent fuel pools at nuclear power plants, the GEH 

Morris spent fuel pools are stainless-steel-lined reinforced concrete structures with leakdetection systems (GE 2004). 

Spent Fuel Pool Maintenance 

Even though the reactor is no longer operating during the short-term storage timeframe, a 

licensee is still bound by the terms and conditions of its operating license until the license is 

terminated. The safety of spent fuel storage is established for each facility through a safety 

analysis report prepared by the licensee to support its application for an operating license and 

reviewed by the NRC. Each safety analysis report includes a number of operational conditions 

and limitations important to safe spent fuel storage. These conditions and limitations are 

subject to regulations that restrict the changes that can be implemented without prior NRC 

approval. Among these regulations are requirements to implement managerial and 

administrative controls to ensure safe operation through implementation of the facility’s quality 

assurance program (Title 10 of the Code of Federal Regulations >&)5@D(1)) and 

requirements for licensees to obtain a license amendment prior to implementing changes to the 

facility or facility procedures that do not meet certain criteria (10 CFR ,QDGGLWLRQWR

these regulations, administrative technical specifications for nuclear power plants typically 

include a requirement to establish, implement, and maintain a broad range of procedures for 

safe operation of the facility. The design basis of the various facility structures, systems, and 

components and the licensee’s NRC-approved quality assurance program, change control 

processes, and plant procedures ensure that the facility structures, systems, and components 

will operate and be maintained within established safety parameters to accomplish their 

functions during normal operating as well as accident conditions. 

Licensees are required to monitor the performance and condition of structures, systems, and 

components important to safety &)50RQLWRULQJSURYLGHVreasonable assurance 

that the structures, systems, and components are capable of fulfilling their intended functions. 

Often referred to as the “Maintenance Rule,” 10 CFR IXUWKHUUHTXLUHVWKHOLFHQVHHWRWDNH

appropriate corrective action when the performance or condition of a structure, system, or 

component important to safety does not conform to established performance criteria. The main 

objective of the Maintenance Rule is to monitor the overall continuing effectiveness of 
Appendix E 

September 2014 E- 185(*௅

maintenance programs used by the licensees to ensure that safety-related (and certain 

nonsafety-related) structures, systems, and components are capable of performing their 

intended functions. All nuclear power plants have specific aging management programs to 

inspect, monitor, detect, and trend the aging of spent fuel structure concrete, liner plate and 

structural steel. The aging management programs also include acceptance criteria that can be 

used to evaluate the inspection results and determine if the spent fuel pool structure can 

perform its intended function or if corrective action is needed. The inspections are performed 

SHULRGLFDOO\DWDIUHTXHQF\RIWR\HDUV

For nuclear power plants that have undergone license renewal, the existing aging management 

program for the spent fuel pool concrete structure and liner plate is enhanced for the period of 

extended operation to monitor for leakage from the spent fuel pool. The enhancement requires 

monitoring to ensure that leak-chase channels embedded in the concrete as a part of the liner 

plate are open, unclogged, and allow free flow of water from the spent fuel pool liner plate. This 

leaked water is then collected, analyzed, treated, and disposed of properly. This approach 

helps ensure that the water from the spent fuel pool does not leak to the environment through 

cracks in the concrete. These inspections and monitoring activities help ensure that issues 

associated with aging of spent fuel pools will be identified and addressed in a timely manner, 

decreasing the likelihood that a spent fuel pool would develop a long-term, undetected leak due 

to aging-related degradation mechanisms. After shutdown, licensees may modify the aging 

management programs implemented as part of license renewal, through the appropriate 

regulatory mechanism (e.g., a license amendment request) or in accordance with the NRC’s 

UHTXLUHPHQWVDW&)5F. However, as discussed above, licensees are still bound by 

the requirements at 10 &)5 to maintain structures, systems, and components related to 

the spent fuel pool. 

E.1.2 Groundwater Monitoring and Licensee Response to Leaks at Nuclear 

Power Plants 

This section describes the NRC’s requirements for identifying subsurface contamination and the 

nuclear industry’s implementation of groundwater monitoring at nuclear power plant sites. 

2Q-XQHWKHNRC issued its Decommissioning Planning Rule ()5). The 

SXUSRVHRIWKLVUXOHZKLFKDPHQGHGUHJXODWLRQVDW&)53DUWVDQGLV

to “improve decommissioning planning and thereby reduce the likelihood that facilities under the 

NRC’s MXULVGLFWLRQZLOOEHFRPHOHJDF\VLWHV ́)5$OHJDF\VLWHLVRQHZLWKFRPSOH[

issues that is in a decommissioning status and whose owner cannot complete the 

GHFRPPLVVLRQLQJZRUNIRUWHFKQLFDORUILQDQFLDOUHDVRQV)57KH'HFRPmissioning 

3ODQQLQJ5XOHWKURXJKDPHQGHGUHJXODWLRQVDW&)5DQGUHTXLUHV

licensees of operating facilities to “minimize the introduction of significant residual radioactivity 

into the site, including the subsurface, and to perform radiological surveys to identify the extent 

of significant residual radioactivity at their sites, including the subsurface” (NRC 2012). The 
Appendix E 

185(*௅ E-6 September 2014 

NRC has found that, in general, groundwater monitoring conducted in accordance with the 

Groundwater Protection Initiative developed by the Nuclear Energy Institute, a nuclear industry 

consortium, is adequate to comply with these regulations (NRC 2012). While licensees are not 

required to implement groundwater monitoring in accordance with the Groundwater Protection 

Initiative, they must still demonstrate compliance with the regulations at &)5 to 

perform subsurface surveys to identify contamination. For new nuclear power plants, licensees 

are subject to the additional requirements of 10 CFR 20.1406(a)-(b), of which “monitoring and 

routine surveillance programs are an important part of minimizing potential contamination” 

(NRC 2008). 

The Nuclear Energy Institute developed its Groundwater Protection Initiative in 2006 in 

response to leaks containing radioactive material at several plants. The Initiative is described in 

NEI –Industry Ground Water Protection Initiative – Final Guidance Document 1(,

All operating and decommissioning power reactor licensees have committed to follow the 

Initiative, which identifies actions to improve licensee response to inadvertent releases, 

including releases from spent fuel pools that may result in low, but detectible, levels of plantrelated radioactive materials in subsurface soils and water. The Initiative identifies the actions 

licensees are expected to take, including the development of written groundwater protection 

programs, improved stakeholder communications, and program oversight. An important 

objective of the Initiative is to detect leaks well before radionuclide concentrations approach 

regulatory limits (e.g., the NRC’s 10 CFR Part 20 dose limits) for radioactive releases 

(NEI . The Initiative also addresses detection and remediation of leaks. The Electric 

Power Research Institute, another industry organization, has published guidance to licensees 

on the design and implementation of a groundwater-monitoring program (EPRI 2008). 

As part of these efforts, the nuclear power industry has committed to improving communication 

with external stakeholders, including members of the public as well as local, State, and Federal 

government officials. This includes: (i) periodic briefings on their site-specific groundwater 

protection programs; (ii) prompt notice to the cognizable authorities whenever significant onsite 

spills or leaks into groundwater occur or onsite or offsite monitoring results exceed monitoring 

standards; (iii) a written 30-day report to the NRC for any monitoring result for onsite 

groundwater that is, or may be used as, a source of drinking water that exceeds monitoring 

criteria; and (iv) an annual radiological environmental operating report or the annual radioactive 

effluent release report that documents onsite groundwater sample results and a description of 

any significant onsite leaks or spills into groundwater 1(,

Licensees might perform additional site-specific monitoring and reporting, based on State or 

local requirements, or agreements between the licensee and other interested parties. For 

example, as part of its settlement of spent fuel pool issues raised by parties to the Indian Point 

Units 2 and 3 relicensing proceeding, the licensee committed to publish the results of 
Appendix E 

September 2014 E- 185(*௅

groundwater monitoring at Indian Point on a quarterly basis to a publicly available website and 

to conduct additional fish sampling in accordance with its monitoring plan (Entergy 2012). 

In April 2011, the NRC evaluated industry performance in Summary of Results from Completion 

of NRC’s Temporary Instruction on Groundwater Protection, TI–2515/173 Industry Groundwater 

Protection Initiative (NRC 2011a). This report was based on inspections conducted between 

August 2008 and August 2010 at all nuclear power plant sites. The report found that 

groundwater-monitoring programs had been implemented at virtually all nuclear power plant 

VLWHVDQGWKDWOLFHQVHHVDFKLHYHGDQDJJUHJDWHSHUFHQWFRPSOHWLRQRIWKH1(, –

Hydrology and Geology, and Site Assessment objectives. For the onsite groundwatermonitoring objective, the completion rate was 92 percent (NRC 2011a). Based on a subsequent 

one-time inspection of licensees from the April 2011 report with five or more incomplete 

program elements, the NRC found that all elements of the Groundwater Protection Initiative had 

been implemented at all but three sites. For the three remaining sites, the remaining program 

elements had been added to the licensees’ corrective action program (NRC 2014). The NRC 

continues to monitor the implementation and maintenance of licensees’ groundwater-monitoring 

programs through routine inspections performed at all nuclear power plant sites. 

Licensee responses to leaks are dictated by the requirements of various NRC regulations. If a 

spent fuel pool leaks and has the potential to result in onsite or offsite contamination, a licensee 

ZRXOGEHUHTXLUHGE\WKH15&¶VUHJXODWLRQVDW&)5DWRSHUIRUPVXUYH\VWKDW

are reasonable under the circumstances to evaluate the magnitude, extent, and potential 

radiological hazard of contamination. Based on the circumstances of the leak, a licensee may 

need to adjust its monitoring program (e.g., add more monitoring wells) to adequately 

characterize the extent of the contamination (NRC 2009). $VUHTXLUHGE\&)5E

licensees must document the location and amount of residual subsurface radioactivity in their 

decommissioning records. Further, as described earlier in this section, licensees have 

committed to providing a description of any significant onsite leaks or spills to groundwater in 

their annual radiological environmental operating reports or the annual radioactive effluent 

release reports UHTXLUHGE\&)5D. For leaks to groundwater, Regulatory Guide 

(RG) 1.21, Measuring, Evaluating, and Reporting Radioactive Material in Liquid and Gaseous 

Effluents and Solid Waste, states that licensees should develop a site conceptual model, using 

standards such as American National Standards Institute/American Nuclear Society report 

2–2010, Evaluation of Subsurface Radionuclide Transport at Commercial Nuclear Power 

Plants (ANSI/ANS 2010) to characterize, model, and monitor groundwater flow and radionuclide 

transport (NRC 2009). This conceptual and subsequent numerical model would be used as the 

basis for estimating the dispersion of radionuclide releases to groundwater. The monitoring 

program would confirm whether remediation programs are effective in precluding offsite impacts 

to groundwater resources. 
Appendix E 

185(*௅ E-8 September 2014 

E.1.3 Remediation Techniques 

Various technologies are currently available to remediate the contaminated groundwater. 

Licensees decide whether and how to remediate a radioactive release to groundwater based on 

a variety of circumstances, including the source and magnitude of the contamination events; the 

local and regional groundwater systems (as reflected in the site conceptual model); the NRC’s 

regulatory requirements (e.g., the radiological criteria for license termination in 10 CFR Part 20, 

Subpart E); and other Federal, State, and local requirements (e.g., U.S. Environmental 

Protection Agency [EPA] drinking-water standards). 

As described in Ferry et al. (1999) groundwater contamination can be limited and mitigated 

through hydraulic isolation and capture, using groundwater extraction methods such as lowdischarge pumping wells and interceptor trenches or a funnel and gate system for near-surface 

plumes. The extracted groundwater can be treated to remove highly absorptive radionuclides 

(e.g., strontium-90 and cesium- using appropriate separation technologies (e.g., ionexchange systems). However, tritium cannot be absorbed in those systems. 

Various separation technologies can be applied to remove contaminants from the extracted 

groundwater. For radioisotopes of elements such as barium, cesium, cobalt, iodide, 

manganese, plutonium, and strontium, various treatment technologies are commonly used in 

the chemical- and wastewater-treatment industries. Most of these technologies can be broadly 

classified into two groups, depending on the reaction mechanism involved (i.e., precipitation or 

sorption [including ion exchange]) (IAEA 1999). 

Using remediation techniques to reduce tritium concentrations to levels below concentrations 

exceeding EPA drinking-water standards is more difficult than for other groundwater 

contaminants because tritium cannot be chemically absorbed. In general, the method used to 

remediate tritium is monitored natural attenuation with selective groundwater extraction for highconcentration areas. Monitored natural attenuation is a proven approach for addressing 

radiological contamination that has been accepted by the EPA (1999) and many State 

environmental regulatory agencies, such as the New York Department of Environmental 

Conservation (NYSDEC 2010). Nevertheless, treatment technologies that have potential 

application for reducing very high tritium levels in groundwater include water distillation, 

combined electrolysis and catalytic exchange, bithermal hydrogen-water process, girdler sulfide 

process, palladium membrane reactor, and the GE-Hitachi Nuclear Energy integrated systems 

(Geniesse and Stegen 2009). 

E.2 Environmental Impacts of Spent Fuel Pool Leaks 

This section addresses the environmental impacts of spent fuel pool leaks that might occur 

during the short-term storage timeframe. The NRC’s Decommissioning Planning Rule, 
Appendix E 

September 2014 E-9 185(*௅

discussed in Section E.1.2, requires licensees to identify the extent of significant residual 

radioactivity at their sites, including the subsurface (NRC 2012). Any significant radioactivity 

identified by licensees must be addressed during the decommissioning process to meet the 

license-termination requirements of 10 CFR Part 20, Subpart E. Consequently, the impacts 

from spent fuel pool leaks that result in contamination that remains onsite are addressed as part 

of the decommissioning and license-termination processes and are outside the scope of this 

GEIS. The environmental impacts resulting from both normal operations and accidents during 

decommissioning activities and all onsite or offsite residual radioactive material that may remain 

after license termination are addressed in Generic Environmental Impact Statement on 

Decommissioning of Nuclear Facilities (NRC 2002) and Generic Environmental Impact 

Statement in Support of Rulemaking on Radiological Criteria for License Termination of 

NRC-Licensed Nuclear Facilities 15&EUHVSHFWLYHO\

E.2.1 Factors that Influence the Impacts of Spent Fuel Pool Leaks 

A combination of factors minimizes the likelihood that a spent fuel pool leak occurring during the 

short-term storage timeframe will result in significant offsite environmental impacts. The 

combination of spent fuel pool design and maintenance; operational practices (e.g., spent fuel 

pool leakage monitoring and groundwater monitoring), site hydrogeological characteristics; and 

radionuclide-transport properties together make the likelihood very low that an undetected leak 

from the spent fuel pool will migrate offsite. These factors, plus NRC oversight and regulatory 

controls, will ensure that licensees identify and diminish potential consequences should a leak 

that results in an offsite release occur. 

E.2.1.1 Spent Fuel Pool Design, Operation and, Monitoring 

As noted below in Section E.3, spent fuel pool leaks have been documented at 13 nuclear 

power plant sites, and at two additional sites where the spent fuel pool was identified as a 

potential source of onsite contamination. Spent fuel pool leaks, while unpredictable, seldom 

occur. Stringent design features and operational controls minimize these occurrences. As 

discussed, all operating spent fuel pools are lined with stainless-steel liners that form a leaktight barrier between the water in the pool and the concrete walls of the pool. In addition, all 

licensees actively monitor for leaks from spent fuel pools and will continue to do so throughout 

the short-term storage timeframe. In most cases, the combination of the spent fuel pool liner 

and leakage monitoring prevent spent fuel pool water from leaking undetected into the 

environment. Further, as described in Section E.1.1, the licensee is required to continuously 

ensure the integrity of the spent fuel pool liner and structure by maintaining a low-corrosive 

environment in the spent fuel pool water through proper water chemistry control. 

Nonetheless, relatively small cracks can occur in the stainless-steel liner due to intergranular 

stress-corrosion cracking and crevice corrosion of the stainless-steel liner, seam or plug weld 

defects, or damage to the liner, resulting in leakage from the spent fuel pool (Copinger et al. 
Appendix E 

185(*௅ E-10 September 2014 

2012). For spent fuel pools with leakage-collection systems installed, these systems could 

become clogged or obstructed, which could cause the water to back up in the space between 

the liner and concrete. Spent fuel pool water that bypasses the collection system can migrate 

through construction joints and cracks in the concrete due to shrinkage, creep, or alkali silica 

reaction, resulting in release of contaminated water outside the pool. Whether resulting from 

leakage through the liner or clogging in the leakage-collection system, spent fuel pool leaks are 

uncommon and unpredictable. However, knowledge and techniques gained from earlier 

industry and NRC studies of spent fuel pool leaks have resulted in heightened awareness of 

leaks and earlier detection and mitigation. 

Significant short-term water loss from a spent fuel pool is likely to be identified by licensee 

monitoring of spent fuel pool water levels. Further, because of NRC requirements to identify 

and minimize contamination (see Section E.1.2), licensees would likely identify and mitigate, if 

necessary, the impacts from any significant short-term water loss before noticeable offsite 

environmental impacts would occur (e.g., the releases at Hatch and Turkey Point which resulted 

in no noticeable offsite environmental impacts and are described in Section E.3). As a result, 

the NRC’s analysis in this GEIS considers a long-term, low-volume undetected leak from a 

spent fuel pool as the most probable scenario in which spent fuel pool leakage would lead to an 

offsite environmental impact. To go undetected, the leak rate would have to be sufficiently low 

as to not exceed the fluctuations in water level of a spent fuel pool lost to evaporation. This is 

so because the spent fuel pool water level is constantly measured by instrumentation and 

routinely monitored by licensees. Also, licensees must perform routine inspections of leakdetection systems and physically inspect the spent fuel pool area for leakage. 

Based on operational experience, the model leak used for analysis here is assumed to 

correspond to a leak rate of approximately 380 L/d [100 gpd] (NRC 2004). In analyzing the 

impacts of a spent fuel pool leak, the NRC assumed a leak rate similar to the rate of water lost 

due to evaporation, which would effectively double the makeup rate to the spent fuel pool. A 

leak of this magnitude would likely be identified in an expeditious manner because of licensee 

monitoring and surveillance. 

In addition to spent fuel pool design and operational controls, as described in Section E.1.2, 

nuclear power plant licensees have implemented onsite groundwater-monitoring programs that 

satisfy the subsurface survey UHTXLUHPHQWVRI&)5 Onsite groundwater monitoring 

makes it unlikely that leakage from the spent fuel pool would remain undetected long enough for 

any contamination to migrate offsite. In addition, a groundwater-monitoring program based on a 

site characterization that conforms to standards (e.g., ANSI/ANS –2010) and a 

configuration of monitoring wells that takes into account the most likely leakage pathway (i.e., 

the spent fuel pool) would further reduce the likelihood that a leak would remain undetected long 

enough for contamination to migrate offsite. 
Appendix E 

September 2014 E-11 185(*௅

E.2.1.2 Radionuclides in Spent Fuel Pools and Radionuclide Transport 

Impacts from spent fuel pool leakage occur from radionuclide contaminants present in spent fuel 

pool water. The sources of radionuclide contaminants in spent fuel pool water are activation 

products and fission products. Activation products are elements formed from the neutron 

bombardment of a stable element and fission products are elements formed as a byproduct of a 

nuclear reaction and radioactive decay of other fission products. The sources of activation 

products are corrosion and wear deposits (including corrosion films on the fuel bundle surfaces). 

Fission products come from bundles with rods that failed in-reactor or from intact bundles that 

adsorbed circulating fission products (JohnVRQ

Table E-1 lists radionuclides of concern expected to be present in the spent fuel pool water. 

The initial concentration column represents the concentration of radionuclides assumed to be 

present at the start of the short-term storage timeframe. The final concentration column 

represents those radionuclides at the end of the short-term storage timeframe, assuming only 

radioactive decay. Actual concentrations would vary based on the efficiency of the spent fuel 

pool purification system and the integrity of the spent fuel assemblies stored in the pool. 

Because of radioactive decay and the spent fuel pool purification system, spent fuel pool leaks 

that occur later in the short-term storage timeframe will likely have less impact on onsite soil and 

groundwater quality due to the lower concentration of radionuclides present in the leaked spent 

fuel pool water. 

Table E-1. Spent Fuel Pool Radionuclides of Concern 

Nuclide Half-Life(a)

Initial Concentration 

(μCi/mL)(b)

Final Concentration 

(μCi/mL) 

Co- GD\V × 10í4 – 

Co-60 \HDUV 8.0 × 10í4 3.1× 10í

Cs-134 2.1 years 8.6 × 10í4

 – 

Cs- 30 years 1.3 × 10í3

 3.3 × 10í4

H-3 12.3 years 2.9 × 10í2

 1.0 × 10í3

Sr-90 28.8 years  × 10í6

 1.4 × 10í6

(a) -RKQVRQ

(b) NRC (2006a). 

As discussed in the preceding section, spent fuel pool water with radioactive contaminants 

could leak through small, intergranular stress-corrosion or crevice-corrosion cracks in the 

stainless-steel liner into the space between the liner and the concrete. Because concrete has a 

very low permeability, it serves as an additional barrier between leaked spent fuel pool water 

and the environment. However, contaminated water could migrate to the environment through 

construction joints and cracks in the concrete if the water backs up in the space between the 
Appendix E 

185(*௅ E-12 September 2014 

liner and concrete and a sufficient hydraulic head is developed. As radionuclides migrate 

through the concrete structure, their concentrations in the leaked water and the volume released 

to the environment could be reduced by sorption onto the concrete material. Sorption, a 

process by which a substance in solution attaches onto a solid material, can retard the 

movement of radionuclides and thus reduce radionuclide concentrations in the leaked water. 

Spent fuel pool water will likely leave the concrete structure at or near the ground surface and 

above the local unconfined water table. The initial migration of radionuclides from the spent fuel 

pool leak is usually vertically downward through the vadose zone (i.e., the surrounding and 

underlying unsaturated soil, backfill, or other near-surface, disturbed materials). However, the 

direction, rate, and volume of the leaked spent fuel pool water migration in the vadose zone is 

influenced by the zone’s ambient water content, the moisture and pressure gradients within the 

material, and the associated volume of the liquid released that may cause local saturation (or 

perching of the released fluid) due to the material’s inability to transmit water at the rate 

released (i.e., insufficient permeability). 

If a sufficient leak volume is released or the unsaturated material underlying the pool has 

hydrologic conditions to transmit the leaked water, the soil “wetting event” associated with the 

spent fuel pool leak can cause vertical radionuclide migration to reach an underlying shallow 

water table or unconfined aquifer (i.e., a saturated hydrogeological unit) and thus contaminate 

the aquifer. The rate of water movement would depend on the existing water content of the 

porous media and the permeability (an intrinsic property of the porous media related to pore 

sizes). For low water contents, the rate of water movement downward would be slow. 

Consequently, it is possible that the water would initially be contained within the site area, but if 

the leak continues to be undetected, it will flow downwards in the direction of the aquifer. Once 

in the aquifer, the travel time to the environment outside the controlled boundary would depend 

upon the hydraulic gradient, the hydraulic properties of the aquifer, and the distance to the site 

boundary. 

Various hydrologic and chemical processes could reduce the environmental impacts of 

radionuclides associated with leaked spent fuel pool water. As the contaminant plume evolves, 

the radionuclide concentrations may continue to decrease due to mixing, dilution, and 

radioactive decay. Different radioisotopes decay at different rates depending on their half-lives 

(see Table E-1). In addition, adsorption of radionuclides onto the aquifer matrix material may 

significantly delay the transport of radionuclides in the subsurface environment and keep 

radionuclide concentrations at low levels in groundwater. Further, adsorption may retard the 

movement of radionuclides because radionuclide mass is adsorbed on solid surfaces and 

becomes unavailable for transport by water. Although desorption of radionuclides from the 

aquifer matrix material back into the groundwater may eventually occur, concentrations will be 

much less than if no sorption occurred. Different radionuclides have different degrees of 

adsorptive interaction with geologic media due to the geologic materials and water chemistry. 

Some radionuclides (e.g., tritium) do not adsorb onto soil and bedrock and, therefore, move 
Appendix E 

September 2014 E-13 185(*௅

generally at the same rate and direction as groundwater. Other radionuclides (e.g., strontium90 and cesium-) strongly adsorb onto geologic media and, thus, move much slower than the 

groundwater velocity and at reduced concentrations compared to the source of a leak. The 

degree of radionuclide adsorption and retardation depends on the properties of the geologic 

media (e.g., mineralogy, reactive surface area, and presence of organic matter) and 

groundwater chemistry (e.g., pH, oxidation-reduction potential, and complexing ion 

concentration). 

E.2.1.3 Influence of Site Hydrological Conditions 

Although it is unlikely that a leak from a spent fuel pool of sufficient magnitude and duration 

would go undetected long enough to result in offsite consequences, several factors mitigate any 

potential impacts should a leak occur. In particular, characteristics of groundwater flow and 

transport of radionuclides in groundwater would limit the amount of radioactivity that would 

travel offsite and reduce its concentration. A review of Final Safety Analysis Reports for existing 

and proposed nuclear power plants, licensee Radioactive Effluent and Environmental Reports, 

and other relevant reports indicates that nuclear power plants have certain common hydrologic 

characteristics such as being located near large bodies of water and being sited in areas where 

the presence of a vadose zone would tend to reduce the amount of radioactive material leaving 

the site and lessen the concentration. Because of the siting criteria of 10 CFR Part 100 spent 

fuel pools are often located, and will continue to be located, in areas with certain similar 

hydrologic characteristics. 

By their nature, nuclear power plants require large volumes of water to provide cooling to plant 

systems. As a result, nuclear power plants, which include spent fuel pools, are typically located 

adjacent to, or near, large surface waterbodies (e.g., rivers, lakes, and oceans). Regional 

groundwater flow in the vicinity of most spent fuel pools, particularly shallow water table or 

unconfined aquifer flow, is toward these large surface waterbodies. Localized water table flow 

around spent fuel pools can be influenced by a variety of physical features and hydrological 

conditions. Subsurface features (e.g., basements) or surface features (e.g., buildings and 

paved areas) can result in localized disturbances to shallow groundwater flow directions and 

velocities. In addition, short-term (transient) factors (e.g., droughts, floods, and daily tidal 

influences) can induce a temporary change in shallow groundwater flow directions and rates. 

Nevertheless, despite these localized or short-term effects, the NRC’s assessment of hydrologic 

conditions at existing nuclear power plant sites indicates that the water table aquifers at these 

sites typically have a predominantly horizontal flow component with ultimate discharge into an 

adjacent or nearby large waterbody. 

Because most nuclear power plants are located at sites where the shallow unconfined 

groundwater at the site flows into the nearby surface waterbody, leaked water from the spent 

fuel pool at these sites would travel toward, and ultimately discharge into, the nearby surface 

waterbody. However, this travel time is often significant because the typical spent fuel pool 
Appendix E 

185(*௅ E-14 September 2014 

location adjacent to or in the vicinity of a large surface waterbody coincides with a relatively flat 

(i.e., small) hydraulic gradient in the shallow water table. Significant radiological decay of spent 

fuel pool contaminants occurs over the long travel times produced from a flat hydraulic gradient, 

resulting in reduced concentrations in the shallow water table. 

Given the typical location of nuclear power plants near large surface waterbodies, the siting of 

reactors typically in areas of lower population density, and the typically large size of the 

licensee-controlled area surrounding the spent fuel pool and entire facility, it is unlikely that 

groundwater users will be located between the spent fuel pool and the nearest receiving surface 

waterbody. Put differently, it is unlikely that groundwater users will draw groundwater 

downgradient of the spent fuel pool, but upgradient of the surface waterbody. As a result, it is 

unlikely that local groundwater users would be situated in the downgradient path of a spent fuel 

pool related groundwater contaminant plume. The same site factors likewise make it unlikely 

that local groundwater pumping will have a significant influence on shallow groundwater flow 

conditions near the spent fuel pools (i.e., capture the spent fuel pool related plume due to 

pumping). In sum, for nuclear power plant sites with typical hydrological conditions, it is unlikely 

that any shallow water table aquifer users in the vicinity of the nuclear power plant would be 

affected by water leaked from a spent fuel pool. Rather, for spent fuel pools located at sites 

with these typical characteristics, any environmental impacts of spent fuel pool leakage would 

result from the discharge of contamination to the surface waterbody. 

In many cases, groundwater users located outside the licensee-controlled area surrounding 

spent fuel pool locations use deeper confined aquifers (i.e., deeper aquifers separated from the 

shallow water table by one or more horizontally continuous low-permeability layers). Potable 

water supply wells are often intentionally placed in deeper aquifer units because of the 

sensitivity of shallow water table aquifers to surface sources of contamination (e.g., septic 

systems) and the impacts to shallow water supplies from climate variability. In addition, as with 

the shallow groundwater users discussed above, the typically large size of the licenseecontrolled area surrounding the facility makes it unlikely that local groundwater pumping in the 

deeper confined aquifer would significantly influence shallow aquifer horizontal or vertical 

gradients at the spent fuel pool location. Moreover, it would be improbable for local deep 

aquifer potable wells to capture spent fuel pool affected groundwater from a shallow unconfined 

aquifer separated from the deeper system by a low-permeability confining layer. 

Consequently, for nuclear power plant sites that exhibit the hydrologic conditions discussed 

above, the offsite environmental impacts would be minimal because groundwater contamination 

would likely either stay onsite or migrate toward a nearby surface waterbody. For contamination 

that remains onsite, licensees would be required to address any residual contamination as part 

of the license-termination process. Alternatively, if discharged to a large waterbody, as 

discussed in Section E.2.2.2, the quantities of radioactive material discharged to nearby surface 
Appendix E 

September 2014 E- 185(*௅

waters would be comparable to quantities associated with permitted, treated effluent discharges 

from operating nuclear power plants. 

For spent fuel pools located at sites with hydrological conditions different from those described 

above, a leak from a spent fuel pool has the potential to affect nearby groundwater users. 

These potential impacts are discussed in Section E.2.2.1. 

E.2.2 Analysis of the Impacts of Spent Fuel Pool Leaks 

Systems or structures can experience undetected radioactive leaks over a prolonged period and 

those that are buried or in contact with soil (e.g., spent fuel pools) are particularly susceptible to 

undetected leakage (NRC 2006b). An important conclusion of the NRC Lessons Learned Task 

Force report (see Section E.3.1) is that the near-term health of the offsite public has not been 

affected by inadvertent liquid releases to the environment stemming from previous spent fuel 

pool leaks at U.S. nuclear facilities (NRC 2006b). As a result, environmental impacts from past 

leaks to groundwater have been minimal. Further, a senior management review of the NRC 

Groundwater Task Force (see Section E.3.1) concurred with the Groundwater Task Force’s 

conclusion that the NRC is accomplishing its stated mission of protecting public health, safety, 

and the environment through its response to groundwater leaks and spills, consistent with its 

regulatory framework (NRC 2011b). This protection will continue through the short-term 

timeframe and will likely continue to be strengthened based on operating experience. 

In the unlikely event of offsite migration, offsite physical resources that might be adversely 

affected by spent fuel pool leaks are groundwater, surface water, and soils. Potential public 

health impacts through these affected resources must also be considered. As described in 

Sections E.2.1.1–E.2.1.3, a variety of factors work together to make it unlikely that a leak from a 

spent fuel pool would result in offsite consequences. These include design and operational 

controls for the spent fuel pool, which should result in the detection and resolution of a leak 

before it develops sufficient volume to migrate offsite; radionuclide-transport properties, which 

would result in lower contaminant concentrations in the leak volume; and site hydrological 

characteristics, which lessen the likelihood that a leak would migrate offsite. As discussed in 

Section E.1.3, various remediation strategies can be employed in the event of a leak; however, 

the decision about whether and how to remediate a radioactive release to groundwater is based 

on a variety of circumstances including, but not limited to, the magnitude of the contamination, 

the NRC’s regulatory requirements (e.g., the radiological criteria for license termination 

described in 10 CFR Part 20, Subpart E), and other Federal, State and local requirements 

(e.g., EPA drinking-water requirements). 

E.2.2.1 Groundwater 

Historically, radiological contamination from spent fuel pool leaks has remained onsite within 

each licensee’s owner-controlled area or traveled to a nearby surface waterbody (see 
Appendix E 

185(*௅ E-16 September 2014 

Section E.3). Because these leaks have remained onsite or were discharged to large surface 

waterbodies, where significant dilution occurred, there have been no impacts to any offsite 

groundwater wells used as a potable resource. As described in Section E.2.1.3, this is mainly 

because the duration or volume of water leaked from the spent fuel pool was insufficient to 

result in elevated radionuclide concentrations away from the source or because the spent fuel 

pools are sited in areas where the hydrologic conditions either impede the flow of leaked water 

away from the source (e.g., flat hydraulic gradient) or direct flow to the nearby surface 

waterbody. 

In the short-term timeframe, spent fuel pool design (stainless-steel liners and leakage-collection 

systems) and operational controls (monitoring and surveillance of spent fuel pool water levels) 

make it unlikely that a leak will remain undetected long enough such that contamination of the 

offsite environment would exceed any regulatory requirement (e.g., the NRC dose limit or EPAmandated Maximum Contaminant Level). In addition, the onsite groundwater-monitoring 

programs implemented at all sites with spent fuel pools provide added protection with respect to 

identifying a spent fuel pool leak and, if necessary, isolating and remediating contaminated 

groundwater onsite. In addition, a variety of physical processes associated with radionuclide 

transport (see Section E.2.1.2) and hydrologic characteristics associated with typical nuclear 

power plant settings (see Section E.2.1.3) would mitigate the impacts from the offsite migration 

of future spent fuel pool leakage. These physical processes and hydrologic characteristics 

include radionuclide adsorption, dilution, and decay; delayed transport times due to the 

relatively flat hydraulic gradients in the shallow water tables; lengthy distance to local 

groundwater users; and the likelihood that local groundwater usage is in deeper confined 

aquifers. Further, current and future spent fuel pool sites are required to have routine 

environmental monitoring programs in place that should take samples at offsite groundwater 

sources (e.g., potable or irrigation) in areas where the hydraulic gradient or recharge properties 

are suitable for contamination (NRC 1991a,b). Finally, any detection of onsite contamination 

would likely result in additional monitoring, including additional sampling of any nearby private 

wells, as part of an expanded environmental monitoring program. With these measures and 

characteristics in place, it is improbable that offsite migration of spent fuel pool leaks will occur 

or go undetected. 

However, it is possible that a nuclear power plant could be sited in a location in which the 

hydrological conditions would not preclude the offsite migration of contaminated groundwater in 

the event of a leak. In the unlikely event that a leak goes undetected at these sites and the 

resulting groundwater plume reaches the offsite environment, the leak could be of sufficient 

magnitude and duration that contamination of a groundwater source above a regulatory limit 

(e.g., a Maximum Contaminant Level for one or more radionuclide) could occur. The NRC 

acknowledges that, in that unlikely event, the radiological impacts on groundwater quality 

resulting from a spent fuel pool leak during the short-term timeframe could noticeably alter, but 

not destabilize a groundwater resource. However, because of the relatively small size of the 
Appendix E 

September 2014 E- 185(*௅

maximum leak rate likely to escape detection (see Section E.2.1.1), the impacts to groundwater 

would likely be highly localized and would not be expected to impact regional groundwater 

resources. If contamination from a spent fuel pool leak were to exceed a Maximum 

Contaminant Level for one or more radionuclides at a groundwater source that currently 

supplies water to public water supplies or that has the potential to supply a public water supply 

(including private wells), the EPA could take emergency action under the Safe Drinking Water 

Act (EPA 1991). Emergency actions include, but are not limited to, providing alternative water 

supplies, public notification of potentially affected users, and remediation of the contamination 

(EPA 1991). 

The impacts of a spent fuel pool leak on offsite groundwater receptors depend on many factors, 

including the volume and rate of water released from the spent fuel pool, the radionuclide 

content and concentration and water chemistry of the spent fuel pool water, the direction of 

groundwater flow, the distance to an offsite groundwater receptor, the velocity or transport rates 

of radionuclides through the subsurface, and radioactive decay rates. However, as discussed 

previously, it is unlikely that a leak of sufficient quantity and duration could occur without 

detection, or that such a leak would not be impeded by physical processes and hydrologic 

characteristics typical at spent fuel pool locations. Therefore, based on the low probability of a 

leak with sufficient quantity and duration to reach offsite locations, the detection and monitoring 

mechanisms available to licensees and the NRC, physical processes associated with 

radionuclide transport, and the hydrologic characteristics at typical spent fuel pool sites, the 

NRC concludes that the radiological impacts to groundwater quality resulting from a spent fuel 

pool leak during short-term timeframe would be SMALL. 

E.2.2.2 Surface Water 

Spent fuel pool leaks can result in discharges of radionuclides to offsite surface waters. The 

concentrations of radionuclides in offsite surface waters will depend on the rate of release from 

the spent fuel pool, the direction and rate of groundwater flow, the distance to nearby offsite 

surface waters toward which groundwater flows, the velocity or transport rates of radionuclides 

through the subsurface, and radioactive decay rates. For a given rate of release, the 

concentrations of radionuclides and, consequently, the presence of radionuclides in surface 

water would be dependent on the duration of the spent fuel pool leak. 

However, because surface water bodies in the vicinity of nuclear power plants (e.g., oceans, 

lakes, rivers) are large enough to meet reactor cooling requirements, a large volume of surface 

water is usually available, which would dilute any groundwater contaminants that flow into them. 

This dilution ensures that radionuclides present in groundwater with concentrations that might 

exceed the Maximum Contaminant Level for that radionuclide would be diluted well below EPA 

safe drinking-water limits. 
Appendix E 

185(*௅ E-18 September 2014 

To illustrate the low releases that would be associated with leaked spent fuel pool water, the 

NRC estimated the annual discharge rate associated with a leakage of 380 L/d [100 gpd] of 

radionuclides in spent fuel pool water at concentrations shown in Table E-1. The NRC’s 

estimate takes into account groundwater transport considerations, including radioactive decay, 

and conservatively assumes steady-state conditions (i.e., constant flow over time). Based on 

these assumptions, the annual quantity of radionuclides, expressed as S that could reach a 

certain distance from the spent fuel pool can be expressed as a derivation of the decay 

equation: 

ܵ = ܵ௢eିఒ௧

where S = the annual discharge of radionuclides to nearby surface waters (Ci/yr) 

 So = the annual leak of radionuclides from the spent fuel pool (Ci/yr) 

 Ȝ = ln(2)/t1/2 = the radioactive decay constant for the radionuclide (yr-1) 

 t = the travel time for radionuclides to reach nearby surface waters (yr). 

The variable t can be expressed as a ratio of distance traveled to a radionuclide’s retard 

velocity: 

ܴݔ = ݐ

ݑ

where x = the distance between the spent fuel pool leak and the nearby surface water 

(m) 

 R = the retardation factor (dimensionless) 

 u = the groundwater flow velocity (m/yr). 

Therefore, the annual quantity of radionuclides that could reach a certain distance from the 

spent fuel pool can be expressed as 

ܵ = ܵ௢݁ି ఒ௫ோ

௨

The retardation factor, R, is expressed as (NRC 1983): 

௕ߩ + 1൬ = ܴ

݊௘

൰ܭௗ

where ȡb = the average soil density (g/cm3

) 

 ne = the effective porosity of the soil (dimensionless) 

 Kd = the radionuclide distribution coefficient (L/kg). 

The value of the radionuclide distribution coefficient (Kd), which describes the tendency of a 

radionuclide in groundwater to sorb to subsurface soil and rock, is higher for radionuclides that 

are strongly sorbed to soil and rock, and lower for radionuclides that tend to remain dissolved in 
Appendix E 

September 2014 E-19 185(*௅

groundwater. Therefore, the higher the Kd value of a radionuclide or other contaminant, the 

slower it will migrate or be transported through soil and groundwater and into surface water. 

Using the leak rates calculated with the values from Table E-1, the expressions above, 

radioactive decay constants for each radionuclide, and reasonably conservative assumptions for 

the other parameters, it is possible to estimate the discharge of radionuclides from a spent fuel 

pool leak to nearby surface waters. A conservative assumption for groundwater flow velocity, u, 

is 30 cm/d (1 ft/d) or about 100 m/yr (330 ft/yr). Assuming the distance, x, from a spent fuel pool 

to nearby surface water is as little as 100 m (330 ft), the travel time for groundwater from the 

point of release at the spent fuel pool to the nearby surface water could be as little as about 

1 year. A nominal bulk soil density, ȡb, is about 1.6 g/cm3

 and an average value of effective soil 

porosity, ne, is 0.3 (Freeze and Cherry 9DOXHVRI.d for isotopes of cesium are available 

in Table 4.6 of NUREG/CR–3332, Radiological Assessment: A Textbook on Environmental 

Dose Analysis (Till and Meyer 1983). A low value of Kd for cesium in soil is about 189 L/kg. 

Using these conservative assumptions, radioactive cesium isotopes would not reach nearby 

surface water before either decaying in place a short distance from the spent fuel pool or being 

removed during decommissioning activities. Using published values of Kd for cobalt (Kd = 60) 

(Sheppard 1990) and cobalt isotope half-lives (t1/2) from Table E-1, cobalt isotopes would 

remain near the leak source and decay or be removed during decommissioning activities well 

before reaching nearby surface waters. Strontium-90 has a sufficiently long half-life of 28.8 

years, and a low enough Kd LQVRPHVRLOVHJL/kg in sand)(Sheppard 1990) that it could 

reach nearby surface waters. Although tritium has a relatively short half-life (12.3 years), it 

moves at the same rate as water through soil and groundwater strata (i.e., effective Kd = 0). 

Therefore, the only radionuclides that could be expected to reach nearby surface water through 

groundwater are tritium and strontium-90. The tritium leakage values calculated using the 

methodology described above are compared in Table E-2 below to the annual liquid effluent 

discharges in 2008 for boiling water reactors and pressurized water reactors (NRC 2010a). 

Strontium-90 leakage values are compared to detectable strontium-90 releases from boiling 

water reactors and pressurized water reactors from 200 through 2009, which are taken from 

individual plant Radioactive Effluent and Environmental Reports on NRC’s website (see 

http://www.nrc.gov/reactors/operating/ops-experience/tritium/plant-info.html). 

As shown in Table E-2, even in the unlikely event that undetected spent fuel pool leakage 

IORZHGFRQWLQXRXVO\KRXUVSHUGD\GD\VSHU\HDUWRORFDOVXUIDFHZDWHUVWKHTXDQWLWLHV

of radioactive material discharged to nearby surface waters would be comparable to values 

associated with permitted, treated effluent discharges from operating nuclear power plants. 

Based on these considerations, the NRC concludes that the impact of spent fuel pool leaks on 

surface water would be SMALL. 
Appendix E 

185(*௅ E-20 September 2014 

Table E-2. Comparison of Tritium and Strontium-90 Released From a Spent Fuel Pool Leak to 

Radionuclides Discharged During Normal Operations 

Radionuclide 

Spent Fuel Pool 

Leakage 

(Ci/yr) 

Boiling Water Reactor 

Effluent Range 

(Ci/yr) 

Pressurized Water Reactor 

Effluent Range (Ci/yr)

H-3 3.8 0.00113 to   to 1,660 

Sr-90(a) 8.3 x 10- [ 10- to 2.0 x 10-4 [ 10- to 1.6 x 10-3

(a) )RUFDOHQGDU\HDUVWKURXJK

E.2.2.3 Soils 

Spent fuel pool leaks could result in localized radiological contamination of offsite soils. The 

degree of offsite soil contamination would depend on the rate of release from the spent fuel 

pool, the direction of groundwater flow, the distance to offsite locations, the velocity or transport 

rates of radionuclides through soils, and radioactive decay rates. For a given rate of release, 

the soil radionuclide concentrations and mass of soil contaminated would be dependent on the 

duration of the spent fuel pool leak. 

As stated above in Section E.2.2.1, contamination in groundwater is likely to be observed as 

part of a licensee’s radiological environmental monitoring program prior to the contamination 

plume reaching the offsite environment, and corrective action would be taken consistent with 

Federal and State requirements. In addition, most radionuclides move at a much slower rate 

and are much more likely to be adsorbed to the concrete structures of the spent fuel building 

and the soil surrounding the leak location. As a result, most soil contamination from spent fuel 

pool leaks would be expected to remain onsite and, therefore, offsite soil contamination is 

unlikely to occur. Therefore, the NRC concludes that the environmental impact of spent fuel 

pool leaks to offsite soils would be SMALL. 

E.2.2.4 Public Health 

For the purposes of assessing radiological impacts, environmental impacts are considered to be 

SMALL if releases and doses do not exceed permissible levels set by the NRC and the EPA. 

Therefore, the impact to public health would be SMALL if the spent fuel pool leakage was 

detected and remediated before regulatory limits for drinking water (e.g., EPA Maximum 

Contaminant Level) or effluent discharges (NRC dose standards LQ&)53DUW$SSHQGL[,

were exceeded. As described above, should a pool leak continue undetected for a long period, 

a highly localized exceedance of groundwater protection standards could occur. Public health 

concerns related to groundwater contamination would be limited to private wells nearest the 

site. Surface water and regional groundwater resources will not be significantly affected for the 

reasons discussed in Sections E.2.2.1 and E.2.2.2. In the event of uncontrolled and undetected 

discharges associated with long-term spent fuel pool leaks to nearby surface waters, the annual 
Appendix E 

September 2014 E-21 185(*௅

discharge would be comparable to normal discharges associated with operating reactors, and 

would likely remain below the standards set by the NRC for normal operational effluents in 

10 &)53DUW$SSHQGL[,,QWKHXQOLNHO\HYHQWWKDWDSRROOHDNUHPDLQHGXQGHWHFted for a 

long period, public health regulatory limits (e.g., EPA drinking-water standards) could be 

exceeded, and, therefore, the NRC has determined that public health impacts could be 

noticeable, but not destabilizing in these circumstances. However, as discussed in Section 

E.2.2.1, it is unlikely that a leak of sufficient quantity and duration could occur without detection 

or that such a leak would not be impeded by the physical processes associated with 

radionuclide transport and hydrologic characteristics typical of spent fuel pool locations. 

Therefore, based on the low probability of a leak affecting offsite groundwater sources, the NRC 

concludes that impacts to public health resulting from a spent fuel pool leak during the shortterm timeframe would be SMALL. 

E.2.2.5 Summary 

Table E-3 summarizes the NRC impact determinations for the resource areas discussed in 

Sections E.2.2.1 through E.2.2.4. 

Table E-3. Summary of Environmental Impacts of Spent Fuel Pool Leakage 

Resource Area Impact Determination 

Groundwater SMALL 

Surface Water SMALL 

Soils SMALL 

Public Health SMALL 

E.3 Historical Data on Spent Fuel Pool Leakage 

Although the evaluation of spent fuel pool leaks in Section E.2 focuses on the potential impacts 

of leaks during short-term storage timeframe, it is helpful to review the historical occurrences of 

spent fuel pool leaks. A review of past spent fuel pool leaks helps to establish a representative 

baseline for the analysis of future impacts and provides context to those impacts. As presented 

in Table E-4, the NRC has identified seven sites where contamination from the spent fuel pool 

has migrated outside of the spent fuel pool building. Two of the sites identified (Hatch and 

Turkey Point) were associated with operational issues that resulted in short-term, high-volume 

releases of water from the spent fuel pool. In both of these cases, the release was immediately 

identified by the licensee and appropriate action was taken to minimize impacts on the 

environment. Five of the sites (Indian Point, Palo Verde, Salem, Seabrook, and Watts Bar) 

were associated with a spent fuel pool leak that went undetected for some period of time. In 

addition to these seven sites, two additional sites (San Onofre and Yankee Rowe) were 

identified in which the spent fuel pool was implicated as a potential source of onsite 

contamination. The NRC has also identified at least seven sites where leakage from the spent 

fuel pool was contained within the leakage-collection system, or within the spent fuel pool 
Appendix E 

185(*௅ E-22 September 2014 

building. Spent fuel pool leakage at boiling water reactor plants has been identified primarily 

through leak-detection systems. Spent fuel pool leakage at pressurized water reactor plants 

has been detected in the leak-chase system (channels installed behind spent fuel pool liner 

welds); as seepage associated with concrete cracks; by the presence of white deposits on 

structures (boric acid precipitate); by the presence of moisture in the seismic gap between the 

fuel-handling building and auxiliary building; and by the presence of abnormally high levels of 

tritium in groundwater (i.e., above normal background levels of approximately 200 pCi/L and by 

contamination of protective clothing) (Copinger et al. 2012). 

At several of the sites listed in Table E-4, namely Indian Point (Units 1 and 2), Palo Verde 

(Unit 1), Salem (Units 1 and 2), Seabrook, and Watts Bar, spent fuel pool leakage has resulted 

in inadvertent liquid radioactive releases to the environment. Releases that were known to have 

occurred to the environment from spent fuel pool leakage prior to 2006 were examined by the 

NRC Liquid Radioactive Release Lessons Learned Task Force as part of its review of historical 

information on abnormal, unplanned, unmonitored releases of radioactive liquids into the 

environment from nuclear power plants (NRC 2006b). The NRC Groundwater Task Force 

(NRC 2010b) reviewed data on releases to groundwater that occurred subsequent to the 

publication of the Lessons Learned Task Force report. A more recent study identified other 

nuclear power facilities that have experienced spent fuel pool leakage, including Crystal River 

Unit 3, Davis-Besse Unit 1, Diablo Canyon Units 1 and 2, Duane Arnold, Hope Creek, and 

Kewaunee (Copinger et al. 2012). For those facilities, with the exception of Kewaunee, the 

leakage was contained within the spent fuel pool leakage-collection system. For Kewaunee, 

the leakage was contained in the waste drumming room adjacent to the spent fuel pool 

(Copinger et al. 2012). 

Table E- lists the maximum contamination detected onsite and at offsite locations from the 

spent fuel pool leakage events. None of the spent fuel pool leakage events listed in Table E-

are known to have resulted in contamination of drinking water. 

NRC Groundwater Task Forces 

In 2006, the NRC chartered an in-house Lessons Learned Task Force to conduct a systematic 

lessons-learned review of unplanned, unmonitored releases of radioactive liquids into the 

environment from nuclear plants, which included inadvertent releases from spent fuel pools as 

well as other plant systems. The Lessons Learned Task Force reviewed industry experience, 

associated public health impacts (if any) of the radioactive liquid releases into the environment, 

the NRC regulatory framework, related NRC inspection and enforcement programs, industry 

reporting requirements, past industry actions following significant inadvertent releases, 
Appendix E 

September 2014 E-23 185(*௅

Table E-4. Occurrence of Spent Fuel Pool Leakage at U.S. Nuclear Power Plants 

Site 

Date(s) of Leak 

Discovery Detection Method 

Radioactive 

Liquid Released 

to Environment? 

Radionuclides 

Detected 

Operational Releases 

Hatch December 1986 Operator observation Yes Tritium and mixed 

fission products 

Turkey Point August 1988 Operator observation Yes Tritium, cesium-

and cobalt-60 

Confirmed Spent Fuel Pool Leaks 

Indian Point 

(Units 1 and 2) 

$XJXVW

Unit 1 leakage 

predates August 



Discovered during 

excavation 

Yes Tritium, nickel-63, 

cesium-

strontium-90, and 

cobalt-60 

Palo Verde 

(Unit 1) 

-XO\ Routine surveillance Yes Tritium, cobalt-60, 

antimony-DQG

cesium-

Salem (Unit 1) September 2002 Personnel monitoring Yes Tritium 

Seabrook June 1999 Environmental monitoring Yes Tritium 

Watts Bar 

(Unit 1) 

August 2002 Environmental monitoring Yes Tritium 

Crystal River 

(Unit 3) 

2009 Routine surveillance No(a) — 

Davis-Besse 2000 Routine surveillance No(a) — 

Diablo Canyon 

(Units 1 and 2) 

2010 Routine surveillance No(a) — 

Duane Arnold 1994 Routine surveillance No(a) — 

Hope Creek 2009 Routine surveillance No(a) — 

Kewaunee  Routine surveillance No(b) — 

Salem (Unit 2) 2010 Routine surveillance No(a) — 

Potential Spent Fuel Pool Leaks 

San Onofre 

(Unit 1) 

1986 (c) Yes Tritium, cesium-

Yankee Rowe /1999 (d) Yes(d) Tritium 

Sources: 6&(ANP 2003; FPL 2006; NRC 2006b; YAEC 2006; NRC 2010b; NRC 2010c; Copinger et al. 2012 

(a) Leaked spent fuel pool water was contained within spent fuel pool leakage-collection system. 

(b) White deposits, possibly boric acid, observed on the wall and ceiling of the waste drumming room adjacent to the 

spent fuel pool. 

(c) Contaminated groundwater was discovered during the decommissioning of San Onofre Unit 1. The source of the 

contaminated water was not clearly identified, but was suspected to have originated from any of three sources, 

one of which was leakage from the spent fuel pool that occurred from 1986 to1989 (NRC 2010c). Environmental 

monitoring performed by the licensee subsequent to the leak did not identify radionuclides in the environment 

DWWULEXWDEOHWR6DQ2QRIUH6&(

(d) The licensee suspects WKDWWKHVSHQWIXHOSRROOHDNHGSHULRGLFDOO\XQWLOWKHLQVWDOODWLRQRIDOLQHULQ; however, 

the amount of leakage was not discernable based on water level changes and makeup rates (YAEC 2006). The 

licensee identified additional leakage thought to be attributable to the spent fuel pool in 1999. Based on its 

evaluation, the licensee estimated that the leak rate was approximately 10 gal/yr (38 L/yr)(ANP 2003). The most 

significant source of onsite groundwater contamination is suspected to have resulted from a leak in the ionexchange pit that released approximately 2 million gallons PLOOLRQOLWHUV of contaminated water through a 

construction joint at the common wall between the spent fuel pool and ion-exchange pit (YAEC 2006). 
Appendix E 

185(*௅ E-24 September 2014 

international perspectives (principally from the Canadian experiences with tritium releases), and 

NRC communications with members of the public. In its final report (NRC 2006b), the Lessons 

Learned Task Force made 26 recommendations that generally addressed enhanced regulations 

or regulatory guidance for unplanned, unmonitored releases; additional reviews in the areas of 

decommissioning funding and license renewal; and enhanced public communications. 

The most significant conclusion of the Lessons Learned Task Force was with respect to public 

health impacts. Although a number of industry events has caused radioactive liquid releases to 

the environment in an unplanned and unmonitored manner, based on the available data, the 

task force did not find any instance in which the radioactive liquid releases affected the health of 

the public (NRC 2006b). 

Table E-5. Dose from Inadvertent Releases of Radioactive Liquids from Nuclear Power Plant 

Spent Fuel Pools 

Site 

Maximum 

Contamination (pCi/L) 

Detected Within the 

Site Boundary 

Maximum Water Contamination 

(pCi/L) at Offsite Locations 

Receptor 

and 

Pathways 

Yearly 

Dose 

(mrem) 

Hatch (a) None detected at offsite water sources; 

long-term monitoring in place 

NA NA 

Indian Point 200,000 for tritium 

100 for nickel-63 

IRUVWURQWLXP-90 

Approximation made in dose 

calculations 

MEI(b) 0.0021(c)

Salem  for tritium(d) None detected NA NA 

Seabrook  for tritium Groundwater plume has not migrated 

offsite 

NA NA 

Turkey Point (e)

 None detected NA NA 

Watts Bar ,000 for tritium Groundwater plume has not migrated 

offsite 

NA NA 

Source: Entergy 2006; FPL 2006; NRC 2013b; NRC 2013c 

(a) $SSUR[LPDWHO\JDORIOLTXLGFRQWDLQLQJ&LRIWULWLXPDQG&LRIPL[HGILVVLRQSURGXFWVZHUH

released to a swamp which is located in the owner-controlled area. No public dose is calculated for releases to 

owner-controlled area. 

(b) MEI = Maximally exposed individual: A hypothetical individual who, because of proximity, activities, or living 

habits, could potentially receive the maximum possible dose of radiation or of a hazardous chemical from a given 

event or process. 

(c) Total body dose was calculated based on the assumption that all onsite groundwater discharged directly to the 

Hudson River (Entergy 2006). The calculated dose represents 0.0021% of the NRC’s radiation dose limit to 

individual members of the public, as defined in 10 CFR Part 20. 

(d) Maximum tritium level in sample of groundwater near the seismic gap; extensive groundwater remediation 

program in place. 

(e) Approximately 6 to JDORIOLTXLG (23 to 26 L) containing [-3 μCi/cm3

 of cesium-[-4 μCi/cm3 of 

tritium, and 2.2 x 10-2 μCi/cm3

 of cobalt-60 were released to storm drains. Leakage discharged into the intake of 

the planWFRROLQJFDQDOZKLFKLVDODUJHFORVHGORRSRQVLWHIORZSDWK)5. 

NA = Not applicable because water contamination was not detected at offsite locations. 
Appendix E 

September 2014 E- 185(*௅

In 2010, following further inadvertent, abnormal releases of radionuclides to the environment 

from nuclear power plant operations, the NRC established a second task force, referred to as 

the NRC Groundwater Task Force. The Groundwater Task Force reevaluated the 

recommendations in the Lessons Learned Task Force final report; reviewed NRC staff actions 

to address the issue of leaks from buried piping at nuclear power plants; and reviewed the 

actions taken in response to more recent releases of tritium from systems other than those 

associated with spent fuel pools into groundwater at nuclear facilities. The scope of the 

Groundwater Task Force work included industry experience; health impacts; the regulatory 

framework; NRC inspections and analyses; enforcement and reporting aspects; industry 

actions; international perspectives; and communications with external stakeholders. After 

completing its review, the Groundwater Task Force determined that the NRC is accomplishing 

its stated mission of protecting public health, safety, and the environment through its response 

to groundwater leaks and spills. 

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Protection Against Radiation.” Washington, D.C. 

10 CFR Part  Code of Federal Regulations, Title 10, Energy3DUW3'RPHVWLF/LFHQVLQJRI

Production and Utilization Facilities.” Washington, D.C. 

10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, “Reactor Site 

Criteria.” Washington, D.C. 

)5. September 18, 1990. “Waste Confidence Decision Review,” Federal Register, 

U.S. Nuclear Regulatory Commission, Washington, D.C. 

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ANP (Framatome ANP). 2003. Site Ground Water Data Collection for YNPS 

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Superfund, RCRA Corrective Action, and Underground Storage Tank Sites. U.S. Environmental 

Protection Agency, Office of Solid Waste and Emergency Response Directive 9200.4-3, 

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Nuclear Power Plants3DOR$OWR&DOLIRUQLD$FFHVVLRQ1R0/

Ferry, L., R. Ferry, W. Isherwood, R. Woodward, T. Carlsen, Z. Demir, R. Qadir, and M. Dresen. 

1999. Final Site-Wide Feasibility Study for Lawrence Livermore National Laboratory Site 300. 

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FPL (Florida Power & Light). 2006. Groundwater Protection—Data Collection Questionnaire. 

Juno Beach, Florida. $FFHVVLRQ1R0/

Freeze, R.A. and J.A. Cherry. “Groundwater.” Prentice-Hall, Inc., Englewood Cliffs, New 

Jersey. 

GE (General Electric Company). 2004. Morris Operation Consolidated Safety Analysis Report. 

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Technologies for Wastewater Treatment. DOE/RL–2009–18, Richland, Washington. Available 

at http://www.osti.gov/scitech/servlets/purl/948439. 
Appendix E 

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IAEA (International Atomic Energy Agency). 1999. Technical Options for the Remediation of 

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Johnson, A., Jr. Behavior of Spent Nuclear Fuel in Water Pool Storage. BNWL–, 

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KWWSZZZRVWLJRYVFLWHFKVHUYOHWVSXUO

1(,1XFOHDU(QHUJ\,QVWLWXWHIndustry Ground Water Protection Initiative—Final 

Guidance Document1(,–:DVKLQJWRQ'&$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 1991a. Offsite Dose Calculation Manual 

Guidance: Standard Radiological Effluent Controls for Pressurized Water Reactors. Generic 

Letter 89–01, Supplement No. 1, NUREG–1301, Washington, D.C. Accession No. 

0/

NRC (U.S. Nuclear Regulatory Commission). 1991b. Offsite Dose Calculation Manual 

Guidance: Standard Radiological Effluent Controls for Boiling Water Reactors. NUREG–1302, 

Generic Letter 89–01, Supplement No. 1, Washington, D.C. Accession No. ML031290469. 

15&861XFOHDU5HJXODWRU\&RPPLVVLRQDOperating Experience Feedback Report: 

Assessment of Spent Fuel Cooling. NUREG–, Volume 12, Washington, D.C. Accession 

1R0/

NRC (U.S. Nuclear 5HJXODWRU\&RPPLVVLRQEGeneric Environmental Impact Statement 

in Support of Rulemaking on Radiological Criteria for License Termination of NRC-Licensed 

Nuclear Facilities. NUREG–1496, Washington, D.C. Accession Nos. ML042310492, 

0/0/

NRC (U.S. Nuclear Regulatory Commission). 2002. Final Generic Environmental Impact 

Statement on Decommissioning of Nuclear Facilities, Supplement 1 Regarding the 

Decommissioning of Nuclear Power Reactors, Final Report. NUREG–Volumes 1 and 2, 

Washington, D.C. Accession Nos. 0/, 0/. 

NRC (U.S. Nuclear Regulatory Commission). 2004. Spent Fuel Pool Leakage to Onsite 

Groundwater. Information Notice 2004– Washington, D.C. Accession No. 0/. 

NRC (U.S. Nuclear Regulatory Commission). 2006a. Indian Point Nuclear Generating Unit 2 - 

NRC Special Inspection Report No. 05000247/2005011. Washington D.C. Accession 

No. 0/
Appendix E 

185(*௅ E-28 September 2014 

NRC (U.S. Nuclear Regulatory Commission). 2006b. Liquid Radioactive Release Lessons 

Learned Task Force Final Report. Washington, D.C. Accession No. 0/

NRC (U.S. Nuclear Regulatory Commission). 2008. Minimization of Contamination and 

Radioactive Waste Generation: Life-Cycle Planning. Regulatory Guide 4.21, Washington, D.C. 

$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 2009. Measuring, Evaluating, and Reporting 

Radioactive Material in Liquid and Gaseous Effluents and Solid Waste. Regulatory Guide 1.21, 

Revision 2, Washington, D.C. Accession No. ML0

NRC (U.S. Nuclear Regulatory Commission). 2010a. Radioactive Effluents from Nuclear 

Power Plants, Annual Report 2008. Washington, D.C. Accession No. 0/

NRC (U.S. Nuclear Regulatory Commission). 2010b. Groundwater Task Force Final Report. 

Washington, '&$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 2010c. Response to Questions Concerning 

Spent Fuel Pool Leakage at the San Onofre Nuclear Generating Station, Unit 1. Arlington, 

Texas. Accession No. ML101400386. 

NRC (U.S. Nuclear Regulatory Commission). 2011a. Memorandum from R.L. Conaster to 

U.S. Shoop dated April 1, 2011, regarding “Summary of Results from Completion of NRC’s 

Temporary Instruction on Groundwater Protection, TI–3,QGXVWU\Groundwater 

Protection Initiative.” Washington, D.C. Accession No. 0/$. 

NRC (U.S. Nuclear Regulatory Commission). 2011b. Senior Management Review of Overall 

Regulatory Approach to Groundwater Protection. SECY–11–0019, Washington, D.C. 

Accession No. ML12338A692. 

NRC (U.S. Nuclear Regulatory Commission). 2012. Decommissioning Planning During 

Operations. Regulatory Guide 4.22, Washington, D.C. Accession No. 0/$. 

NRC (U.S. Nuclear Regulatory Commission). 2013a. 2013–2014 Information Digest. NUREG-

9ROXPH :DVKLQJWRQ'&$FFHVVLRQ1R0/$

NRC (U.S. Nuclear Regulatory Commission). 2013b. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants. NUREG–9ROXPH5HYLVLRQ

Washington, '&$FFHVVLRQ1R0/$

NRC (U.S. Nuclear Regulatory Commission). 2013c. Final Environmental Statement: Related 

to the Operation of Watts Bar Nuclear Plant, Unit 2. NUREG–0498, Supplement 2, Volume 1, 

Washington, D.C. Accession No. ML13144A092. 
Appendix E 

September 2014 E-29 185(*௅

NRC (U.S. Nuclear Regulatory Commission). 2014. Memorandum from S.M. Gary to 

U.S. Shoop dated April 11, 2014, regarding “Roll-8SRI7HPSRUDU\,QVWUXFWLRQ7,

“Follow-Up on the Industry’s Ground Water Protection Initiative.” Washington, D.C. Accession 

No. ML14086A644. 

NYSDEC (New York State Department of Environmental Conservation). 2010. Technical 

Guidance for Site Investigation and Remediation. DER-10, Albany, New York. Available at: 

http://www.dec.ny.gov/docs/remediation_hudson_pdf/der10.pdf. 

6&(6RXWKHUQ&DOLIRUQLD(GLVRQ&RPSDQ\SONGS Unit 1 Spent Fuel Pool Liner Plate 

Evaluation. San Clemente, California. ADAMS Legacy Library $FFHVVLRQ1R

Sheppard, M.I. and D.H. Thibault. 1990. “Default Soil Solid/Liquid Partition Coefficients, Kds, 

for Four Major Soil Types: A Compendium.” Health Physics -482, Philadelphia, 

Pennsylvania. 

Till, J.E. and H.R. Meyer, eds. 1983. Radiological Assessment: A Textbook on Environmental 

Dose Analysis. NUREG/CR–3332, Oak Ridge National Laboratory, Oak Ridge, Tennessee. 

Accession No. 0/. 

YAEC (Yankee Atomic Electric Company). 2006. Groundwater Monitoring Plan to Support 

Closure under the Massachusetts Contingency Plan. Rowe, Massachusetts. Accession No. 

0/. 

Appendix F 

–

Spent Fuel Pool Fires 

September 2014 F-1 185(*௅

Appendix F 

Spent Fuel Pool Fires 

This appendix examines the environmental impacts of a spent fuel pool fire during the shortterm storage timeframe.1 The environmental impacts of spent fuel pool fires described in this 

appendix support the U.S. Nuclear Regulatory Commission’s (NRC’s) generic determination of 

the environmental impacts of spent fuel pool fires and their risk, as described in Section 4.18.2.1 

of this Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel

(GEIS). The NRC has conducted extensive evaluations of the risk and impacts of spent fuel 

pool fires. While initial studies were concerned with spent fuel pool fire risk during the operating 

life of a reactor, a risk study completed in 2001 examined the risk of a spent fuel pool fire during 

the reactor decommissioning period (NRC 2001). The analysis in this appendix shows that the 

probability-weighted impacts, or risk, from a spent fuel pool fire for the short-term storage 

timeframe are SMALL because, while the consequences from a spent fuel pool fire could be 

significant and destabilizing, the probability of such an event is extremely remote. 

F.1 Environmental Impacts of Spent Fuel Pool Fires 

In the event of an accident that leads to a loss of water in a spent fuel pool (via rapid drainage 

or extended boiling), without successful efforts to replenish the lost water, spent fuel 

temperatures could increase significantly. If cooling of the spent fuel were not reestablished, 

the fuel could heat up to temperatures on the order of 1,000qC (1,832qF). At this temperature, 

the spent fuel’s zirconium cladding would begin to react with air in a highly exothermic chemical 

reaction called a runaway zirconium oxidation reaction or autocatalytic ignition. This accident 

scenario is often referred to as a “spent fuel pool zirconium fire.” Radioactive aerosols and 

vapors released from the damaged spent fuel could be carried throughout the spent fuel pool 

building and into the surrounding environment. This release could lead to exposures of the 

surrounding population and contamination of property (e.g., land or structures) in the vicinity of 

the site. Under appropriate atmospheric conditions, the radioactive aerosols from very large 

releases could be transported long distances before they were deposited or dispersed. 

 

1 As discussed in Section 1.8, the NRC assumes that all spent nuclear fuel (spent fuel) is removed from 

the pools and placed in dry-cask storage by the end of the short-term storage timeframe. This appendix, 

therefore, does not analyze the impacts of a spent fuel pool fire after the short-term storage timeframe 

because a spent fuel pool will not be used to store spent fuel after that time. 
Appendix F 

185(*௅ F-2 September 2014 

Under certain conditions, the high temperature runaway zirconium oxidation reaction occurring 

in one part of the pool could also spread to other spent fuel in the pool. The proximity of fuel 

assemblies to one another, combined with the effects of radiative heat transfer when these 

assemblies are at very high temperatures, could allow the runaway oxidation reaction to spread 

from spent fuel with high decay heat to spent fuel with lower decay heat that would otherwise 

not have begun burning. 

A spent fuel pool accident could develop into a spent fuel pool fire in a number of ways. As the 

15&ILUVWGHWHUPLQHGLQVSHQt fuel pool accidents can arise from either the loss of spent 

fuel pool cooling, drainage of the spent fuel pool, or the dropping of heavy items into the spent 

IXHOSRRO15&6LQFHWKDWWLPHWKH15&KDVUHILQHGLWVDQDO\VLVDQGKDVORRNHGDW

various ways that these events could occur. For example, in 1989 the NRC conducted a study 

that assessed various accident sequences including spent fuel pool failure due to wind-driven 

missiles, aircraft crashes, heavy-load drop, seal failure, inadvertent draining, loss-of-cooling, 

and seismic events (NRC 1989). 

The NRC has also assessed the probability of spent fuel pool accidents. The probability of 

spent fuel pool accidents is the sum of the frequency of those accident sequences that lead to 

radiological release, considering both the frequency of the different types of initiating events and 

the probability of a release given that a particular initiating event has occurred. In its earliest 

study, the NRC determined that the probability of the drainage of the spent fuel pool was much 

less than a loss-of-cooling event for the reactor because accidental drainage of the spent fuel 

SRROUHTXLUHVPXOWLSOHVLPXOWDQHRXVIDLOXUHV15&)XUWKHULQWKH15&TXDQWLILHG

the probabilities of various accident initiating events and assessed the health and economic 

consequences of a spent fuel pool accident (NRC 1989). The potential consequences of a 

spent fuel pool fire can be considered in light of these probabilities and expressed in several 

different measures of impacts (e.g., collective radiation dose to the public and economic 

consequences). 

The NRC chose to develop its generic analysis for spent fuel pool fires by selecting 

NUREG–Technical Study of Spent Nuclear Fuel Pool Accident Risk at Decommissioning 

Nuclear Power Plants (NRC 2001) as the principle basis for its quantitative estimates of the 

impacts, and then discuss any significant uncertainties and how those uncertainties would affect 

those estimates. The NRC chose NUREG–for this purpose because the following 

features are particularly relevant to the spent fuel pool severe accident analysis of the GEIS: 

x NUREG– was developed for reactors during decommissioning rather than operating 

reactors, and thus analyzes the earliest and highest-risk period of the short-term storage 

timeframe considered in the GEIS. 

x NUREG– analyzes a wide variety of initiating events. 
Appendix F 

September 2014 F-3 185(*௅

x NUREG– was developed as a generic analysis by, for example, considering 

geographic variation in seismic hazard (see Figure 3.2 of NUREG–) and by performing 

sensitivity studies to examine the effects of variation in site-specific factors such as 

population density. 

x NUREG– references preceding studies of spent fuel pool risks and compares the 

results, thereby serving as a valuable update to earlier spent fuel pool risk studies. 

x NUREG– has received extensive peer technical review and public comment. 

x NUREG– provides quantitative estimates at a reference reactor site (i.e., Surry Power 

Station [Surry]) for which information on the impacts of potential reactor accidents is also 

available, allowing a comparison of potential impacts of both pool and reactor accidents. 

As detailed in the following sections, the impacts from a spent fuel pool fire are expressed in 

terms of both the consequence that would occur if the accident occurred and as a probabilityweighted consequence. The probability-weighted consequence, also known as risk, is a 

quantitative measure of the severity of the accident that accounts for the likelihood of its 

occurrence. The probability-weighted consequence is calculated by multiplying a consequence, 

such as cumulative dose, cost to the local economy, or area of land contamination, by the 

probability of the accident’s occurrence. In the following analyses, the NRC first provides a 

discussion of the consequences of a spent fuel pool fire. The NRC then determines the risk of a 

spent fuel pool fire by looking at the probability of this type of event during the short-term 

storage timeframe and multiplying the probability by the consequences. The probabilityweighted consequences provide the expected environmental impacts of a spent fuel pool fire, 

and represent the NRC’s best forward-looking judgment concerning spent fuel pool fire risk 

during the short-term storage timeframe. 

As discussed in more detail below, the NRC confirmed that the overall risks associated with 

these types of accidents remain low because the spent fuel pool loss-of-cooling event probability 

is low (NRC 2001). As discussed in more detail in Section F.1.2, since the NRC completed 

NUREG– in 2001, the NRC has continued to implement regulations and orders that further 

reduce the likelihood of a spent fuel pool fire. These additional reductions in the likelihood of a 

spent fuel pool fire mean that the risks are lower now than those NRC reported in NUREG–

Finally, as part of an ongoing examination of the risk of spent fuel pool accidents, the NRC 

performed a study of the probability and consequences of a beyond-design-basis earthquake 

affecting the spent fuel pool for a U.S. boiling water reactor. That study, documented in SECY–

13–0112, Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel 

Pool for a U.S. Mark I Boiling Water Reactor (NRC 2013a), used updated methods to look at the 

probability and consequences of a spent fuel pool loss-of-cooling event for both a high-density 

and a low- density loading spent fuel storage configuration. Based in part on that study, the 

NRC performed an analysis of spent fuel pool fire risk to determine whether the NRC should 
Appendix F 

185(*௅ F-4 September 2014 

conduct additional research on the potential need to require reactor licensees to accelerate 

transfer of older, cooler spent fuel from the spent fuel pool to dry cask storage. The results of 

this analysis were documented in COMSECY–13–0030 (NRC 2013a). The results in SECY–

13–0112 and COMSECY–13–0030 support the NRC’s conclusion that, while the consequences 

from a spent fuel pool fire could be significant and destabilizing, the probability of a spent fuel 

pool fire is extremely remote. Further, the NRC reviewed the analyses in SECY-13-0112 and 

COMSECY–13–0030 and determined that neither would be an appropriate technical basis for 

the generic spent fuel pool fire consequence analysis in the GEIS. SECY–13–0112 lacked 

features comparable to NUREG– that would support a generic analysis of continued 

storage, while COMSECY–13–0030 was drafted to satisfy a limited purpose, did not contain a 

NEPA analysis, and was not intended to satisfy the NRC’s NEPA obligation. While important 

information has been garnered from those analyses, the NRC continues to believe that the 

analysis in NUREG–is the appropriate technical basis from which to evaluate the impacts 

from a spent fuel pool fire during the short-term timeframe because of the factors described 

earlier in this section. 

F.1.1 Consequences of a Spent Fuel Pool Fire 

The release of radionuclides into the environment resulting from a spent fuel pool fire can lead 

to severe consequences, both in terms of direct human health impacts (e.g., early fatalities or 

latent cancer fatalities) and economic damages arising from the actions taken to avoid human 

exposures (e.g., evacuation and relocation costs, costs for cleanup of contaminated land, and 

the loss of economic value associated with land that cannot be used following a severe 

accident). These consequences do not consider the probability that an accident will occur. 

Possible initiating events and the probability that these events could occur are discussed in 

Section F.1.2. The following discussion and Table F-1 examine the consequences of a spent 

fuel pool fire. 

In NUREG–DQG7DEOH)-1, source terms for high ruthenium (Ru) and low Ru are 

expressed as ranges. For example, the total collective dose for the high Ru source term ranges 

from 1.34 × 10 WR × 10 person-Sv (1.34 × 10 WR× 10 person-rem).3 The ranges in 

Table F-1 are mean values of consequences of a spent fuel pool fire in which the NRC assumed 

a late evacuation of  percent of the population inside the 16-km (10-mi) emergency planning 

zone around Surry. The late evacuation assumption means that evacuation is started after the 

release. The low value corresponds to a fire that occurs 10 years after shutdown, at which time 

 

3 A person-Sievert (person-Sv) is a unit of collective dose. Collective dose is the sum of individual 

radiation doses received by a population. The incidence of health effects will vary from no observable 

health effects in large numbers of exposed individuals that receive low doses to observable health effects 

in small numbers of exposed individuals that receive large doses. Population health effects from spent 

fuel fires, including early fatalities and latent cancer fatalities, are summarized in Table F-1. 
Appendix F 

September 2014 F- 185(*௅

radioactive decay has reduced the amount of radioactive material that could be released. The 

high value corresponds to a fire that occurs within 30 days after shutdown. 

Table F-1. Spent Fuel Pool Accident Probability and Consequences(a)

Accident 

Frequency 

(per year)(b)

Individual Risk per Event 

Total person-Sv 

per Event 

Collective 

Early 

Fatality per 

Event 

(10 mi)(c)

Latent 

Fatality(d) 

(0–500 mi) 

Total 

Onsite and 

Offsite 

Economic 

(million $ 

per event) 

Early Fatality 

(1 mi)(c)

Latent Fatality 

(10 mi)(c)

NUREG–

(high Ru) 

îíH to 

2.4 × 10íI

4.68 × 10í to 

4.43 × 10í

6.39 × 10í to 

8.49 × 10í

1.34 × 10 WR

× 10 PL(c)

<1 (0.360) to 

191 

- - 

NUREG–

(low Ru) 

îíH to 

2.4 × 10íI

1.63 × 10í to 

îí

1.29 × 10í to 

1.88 × 10í

î4 WR

× 104 PL(c)

<1 to 2 20,000–



- 

NUREG– 2.0 × 10í - - 2.6 × 10

PL(g)

- (h,i)

NUREG/ 

BR–0184 

- - - 2.6 × 10

PL(j) 

- (h,k)

(a) All values are approximate. 

(b) $YDOXHRI[-LVVFLHQWLILFQRWDWLRQIRUDYDOXHWKDWFDQDOVREHH[SUHVVHGDV7KLVYDOXHPHDQVWKDWWKH

SUREDELOLW\RIWKHDFFLGHQWRFFXUULQJLQDQ\\HDULVRQHFKDQFHLQRURQHFKDQFHLQ

(c) Consequence values were obtained from NUREG–15&7DEOHVDQGRI$SSHQGL[%>1RWH6LPLODU

values appear in NUREG–15& 7DEOHV-DQG-2), but were incorrectly reporting values from 

Appendix 4B.] 

(d) Consequence values were obtained from NUREG–15&$SSHQGL[DQGUHIOHFWDUDQJHRIUHVXOWVIURPWKH

seven cases evaluated. 

(e) Electric Power Research Institute data from NUREG–15&

(f) Lawrence Livermore National Laboratory data in NUREG–15&

(g) Case 2 values were obtained from NUREG–15&7DEOH&DVHDVVXPHGWKHHQWLUHVSHQWIXHOSRRO

inventory was released. 

(h) Values DUHEDVHGRQLPSDFWVZLWKLQPL and are adjusted to 2010 dollars using the Consumer Price Index Inflation 

Calculator. 

(i) Values were obtained from NUREG–0LOOLRQLQGROODUVH[FOXGHVUHSODFHPHQWSRZHUFRVWV

(NRC 1989, 7DEOHVDQG

(j) Values were obtained from NUREG/BR–15&7DEOH&

(k) Values were obtained from NUREG/BR–0LOOLRQLQGROODUVH[FOXGHVUHSODFHPHQWSRZHUFRVWV15&

7DEOH&DQG&

Table F-1 shows that the most severe spent fuel pool fire consequences would occur from a fire 

starting within 30 days after a final reactor shutdown in conjunction with a late or delayed 

evacuation of the affected area. The late evacuation would result in consequences more severe 

than those for an early evacuation because a late evacuation means that people will evacuate 

after the release of radioactive material. Further, the values shown in Table F-1 are conditional 

consequences, based on an assumption that a severe accident occurs without consideration of 

the remote probability of an accident. Probability-weighted consequences are discussed in 

Section F.1.2. 

As discussed below, the assumptions described above are conservative assumptions of the 

consequences of the spent fuel pool fire. These conservative assumptions further reduce the 
Appendix F 

185(*௅ F-6 September 2014 

likelihood that the actual consequences would be as high as indicated in Table F-1. For 

example, the low Ru results from NUREG– more realistically represent the anticipated 

consequences of even a high-YRODWLOLW\5XVSHQWIXHOSRROILUHVHTXHQFH7KH percent 

evacuation estimate is less than the NRC’s best estimate of actual evacuation of SHUFHQW of 

the populace from the 16-km (10-mi) emergency planning zone, which was used by the NRC in 

its 2012 State-of-the-Art Reactor Consequence Analyses Report (NRC 1990, 2012a). However, 

in NUREG–WKH15&XVHGDYDOXHRISHUFHQWLQVHQVLWLYLW\VWXGLHVWRDGGUHVVFRQFHUQV

that the fraction of the public that does not evacuate could be higher. “Late evacuation” is a 

reasonably conservative assumption for decay times of less than about 2 years, for which the 

time-to-release could be less than 10 hours. However, the time-to-release (following the 

initiating event) will be longer than 10 hours after the spent fuel has cooled at least 2 years, and 

early evacuation, in which evacuation is completed before the release begins, would be 

increasingly more likely as the decay time increases. The more recent analyses (i.e., 

SECY–13–0112) suggest that, even for accidents occurring within a few months of final 

shutdown and assuming mitigation measures are unsuccessful, releases could start anywhere 

from eight hours to several days after the event. Early evacuation results in lower public doses 

because more people will evacuate before release occurs. Finally, the main contributors to the 

likelihood of uncovering the spent fuel are seismic events and cask drop. These events are no 

more or less likely to occur in any particular time interval during continued storage. Therefore, 

the probability of these initiating events occurring within the first 30 days after shutdown is an 

order of magnitude less than the per year probability during the 60-year short-term storage 

timeframe. 

The low Ru and high Ru values shown in Table F-1 refer to two different source terms used in 

NUREG– (NRC 2001). The low Ru source term is based on release fractions for chemical 

element groups that are discussed in NUREG–Accident Source Terms for Light-Water 

Nuclear Power Plants 15&Use of the NUREG–VRXUFHWHUPPHDQVWKDWWKH

consequence estiPDWHVLQWKH*(,6DUHEDVHGRQD percent release of radioiodine and 

radiocesium, the two radioisotope groups that contribute the most to offsite consequences. In 

addition, NUREG– considered uncertainties associated with the Ru group and fuel fines 

component of the NUREG–UHOHDVHIUDFWLRQV. The fuel fines component of the source 

term, comprised of small particles of spent fuel, is represented by the element groups for cerium 

and lanthanum. To conservatively address potential uncertainties in the source term, 

NUREG–FRPSXWHGFRQVHTXHQFHVIRUDPRGLILHGVRXUFHWHUPWKDWDVVXPHGD percent 

UHOHDVHIUDFWLRQIRUUXWKHQLXPDQGD percent release fraction for lanthanum and cerium, 

referred to as the “high Ru source term.” The higher release fraction for Ru in the high Ru 

source term is the same fraction as those used for volatile fission products like isotopes of 

iodine and cesium. As stated in NUREG–WKHKLJKHUUHOHDVHIUDFWLRQVIRUODQWKDQXPDQG

FHULXPLQWKHKLJK5XVRXUFHWHUPDUHEDVHGRQDVWXG\RIWKH&KHUQRE\Oaccident. 

As described in NUREG–5XLQDVWHDPHQYLURQPHQWKDVDYHU\ORZYDSRUSUHVVXUHWKDW

tends to limit its release (NRC 2001). For spent fuel pool accidents involving rapid draindown of 
Appendix F 

September 2014 F- 185(*௅

the pool, and thus primarily an air environment during fuel heat up, the volatility of Ru might be 

much higher. Recent modeling suggests that Ru release in an air environment would in fact be 

much higher than in a steam environment, but still several orders of magnitude below the 

release fractions used for the high Ru release in NUREG– (Gauntt 2010). For this reason, 

the low Ru results from NUREG– (NRC 2001) are more representative of the anticipated 

consequences of even a high-volatility Ru spent fuel pool fire sequence. 

The NRC assesses the consequences of a spent fuel pool fire and other severe accidents in 

terms of health impacts and economic damages. The health impacts from spent fuel pool fires 

are measured through both individual impacts at select locations, and overall population 

consequences. Health impacts include the early fatality risk to an individual within 1.6 km (1 mi) 

of the plant and the latent fatality risk to an individual within 16 km (10 mi) of the plant. These 

health impacts represent possible exposures and consequences to the population near a 

nuclear facility. Early fatalities are the number of fatalities expected to occur within a few weeks 

or months of the accident for the individuals exposed to large doses of radiation. Latent 

fatalities are the number of cancer-related fatalities that occur over the lifetime of the exposed 

individuals.

Other health impacts that the NRC considers include collective dose to the public within 80 km 

PLRIWKHSODQWDQGWKHFROOHFWLYHODWHQWIDWDOLWLHVZLWKLQNPPLRIWKHSODQW15&

2001). The collective dose is the dose received by the total population living within a specific 

distance from the facility, including return dose and the dose to workers during decontamination 

RIFRQWDPLQDWHGODQGWKLVYDOXHGHSHQGVXSRQWKHVLWH-specific population within a specific 

distance of the plant. In Table F-1, health effects taken from NUREG–(NRC 2001) are 

based on a postulated spent fuel pool fire at Surry releasing a large fraction (i.e., approximately 

 percent of the iodine and cesium) from a radiological inventory consisting of its final core 

offload plus its previous ten refueling outages, which is HTXLYDOHQWWRDSSUR[LPDWHO\FRUHV. A 

similar scenario examined in NUREG–(NRC 1989) and NUREG/BR–0184 15&

involved releasing a large fraction (i.e., 100 percent of the iodine and cesium) from a 

radiological inventory consisting of FRUHs of spent fuel from the R.E. Ginna nuclear power 

plant and an 80-NP-mi) average population density of 330 persons/km2 (860 persons/mi2) 

(based on the population around the Zion Nuclear Power Station [Zion] in Illinois). In general, 

health impacts could be higher or lower than the values reported in these studies if the amount 

of radioactive material that could be released (which depends on the amount of material in the 

pool and the fraction of that material involved in the fire) were higher or lower than assumed in 

these studies or the total population and population density were higher or lower. 

For perspective, the radiological inventory of Cs-IURP185(*–(NRC 2001) can 

be computed as approximately 40 MCi of Cs-, and the radiological inventory from 

NUREG–(NRC 1989) was computed to be approximately 20 MCi. These values are 

somewhat lower than the average values reported in COMSECY–13–0030 (NRC 2013b). 
Appendix F 

185(*௅ F-8 September 2014 

Table  from COMSECY–13–0030 illustrates that the radiological inventory of Cs- in highdensity storage at nuclear power plants can range from 20.4 to 1 MCi of Cs-, assuming 

each spent fuel pool is at its licensed capacity of spent fuel in storage. Conversely, the release 

fractions assumed in NUREG– (i.e. percent of the radioiodine and radiocesium) or 

NUREG–i.e., 100 percent of the radioiodine and radiocesium) are higher than the release 

fractions computed in more recent studies (e.g., SECY–13–0112 [NRC 2013a], which estimated 

cesium release fractions from 49 percent to less than 1 percent). Therefore, although the total 

radiological inventory at a given site might be higher than the values used in NUREG–

(NRC 2001) and NUREG– (NRC 1989), the release fraction would likely be significantly 

lower than that assumed in either report. 

Likewise for population, 7DEOHRI&206(&<–13–0030 shows the distribution of population 

density around nuclear power plant sites in the United States (NRC 2013b). The average 

population density within 80 km (PL) of U.S. nuclear power plant sites is approximately 

120 persons/ km2 (300 persons/mi2), consistent with the Surry site. The average population 

around the Zion site of 330 persons/km2 (860 persons/mi2) is greater than the 90th percentile 

population density of approximately SHUVRQVkm2 (persons/mi2). As discussed in 

NUREG– (NRC 2001), the use of the Surry site means that the accident consequences 

could be greater at higher population sites, but the quantitative health objectives used in 

NUREG–IRUFRPSDULVRQVWRWKH&ommission’s safety goals represent the risk to the 

average individual within 1.6 km (1 mi) and 16 km (10 mi) of the plant. That risk should not vary 

significantly with the size of the site-specific population around a plant because those risks are 

averaged (i.e., determined by dividing the total number of cases by the affected population 

within the specified region). 

Health impacts can also be affected by protective action guidelines, or the radiation dose levels 

above which emergency response officials will recommend protective actions like evacuation or 

sheltering. Higher protective action guidelines could increase public doses by allowing people 

to remain in affected locations longer or by reducing the area that would be subject to long-term 

actions (e.g., decontamination or interdiction). Different types of radioactive material can also 

change health impacts. For example, early fatalities would likely be caused by short-lived 

radioactive material that is present in operating reactors. Once spent fuel has been removed 

from a reactor and stored in the spent fuel pool, short-lived radioactive material will decay to 

such low levels that accidents would result in fewer early fatalities in the surrounding population. 

The NRC also analyzes consequences in terms of the economic consequences arising from the 

actions taken to avoid human exposure. The economic consequences identified in Table F-1 

take into account various costs, including offsite and onsite property damage resulting from the 

release of radioactive material and the resulting land contamination. Offsite property damage 

includes evacuation costs, relocation costs for displaced persons, property decontamination 

costs, loss of use of contaminated property through interdiction, crop, and milk losses. The 
Appendix F 

September 2014 F-9 185(*௅

onsite property damage costs include onsite cleanup and decontamination, repair of the spent 

fuel pool, and removal of fuel. The total onsite and offsite economic damage values were 

HVWLPDWHGWREHEHWZHHQDQGELOOLRQGROODUVSHUHYHQW15& when 

adjusted to 2010 dollars. 

These values represent the economic consequences out to 80 km (PL), which is consistent 

with how NRC typically examines offsite property impacts from reactor accidents 15&. 

For very large releases (e.g., those that are possible in the event of a spent fuel pool fire), 

aerosols can potentially be transported beyond 80 km (PL) under appropriate atmospheric 

conditions. This effect can be seen in the NRC’s more recent analysis in SECY–13–0112 (NRC 

2013a) by comparing the consequences from an accident in which mitigation is credited—which 

would lead to a smaller release—to the consequences of an accident in which no mitigation is 

credited. )RUH[DPSOH7DEOHVDQGRISECY–13–0112 show that land interdiction and 

relocation of individuals, respectively, could occur well beyond the range of 80 km (PL) in the 

event of a very large release from the spent fuel pool. As with health impacts, the economic 

impacts would vary for different facilities. For example, higher total population or population 

density, higher property values, and higher level of protective action guidelines in place, could 

result in higher relocation costs, and land use (e.g., whether land is used as farmland or not) 

could also impact decontamination and condemnation costs. For perspective, the population 

density used to estimate the economic impacts presented in Table F-1 involved an 80-km 

-mi) average population density of 330 persons/km2 (860 persons/mi2) based on the 

population around the Zion in Illinois 15&. This population density is slightly 

higher than the 90th SHUFHQWLOHSRSXODWLRQGHQVLW\UHSRUWHGLQ7DEOHRI&206(&<–13–0030 

(NRC 2013b). Although the economic consequences could be higher or lower at a specific site, 

the site-specific factors that influence the magnitude of the economic consequences of a spent 

fuel pool would have a similar influence on the magnitude of the economic consequences of a 

reactor accident. Because of this, when put in the context of the probability of an accident 

occurring, the probability-weighted economic consequences of a spent fuel pool fire at a given 

site can be compared to the probability-weighted consequences of a reactor accident at the 

same site. This is discussed further in Section F.1.2. 

Although discussed in more detail in the next section, Table F-1 also includes probability and 

cRQVHTXHQFHYDOXHVIRUDVSHQWIXHOSRROILUH15&$VVKRZQLQTable F-1, 

the zirconium cladding fire probability in the 1989 regulatory analysis was calculated as 

2 × 10í/yr, which is almost identical to the 2.4 × 10í/yr probability from NUREG–

(NRC 2001) that the NRC is using for this appendix. 

F.1.2 Probability-Weighted Consequences of a Spent Fuel Pool Fire 

As discussed in Section 4.18.2.1, with respect to severe (or beyond-design-basis) accidents, the 

consequences of a severe accident, should one occur, would be significant and destabilizing. 

The impact determinations for these accidents, however, are made with consideration of the low 
Appendix F 

185(*௅ F-10 September 2014 

probability of these events. The environmental impact determination with respect to severe 

accidents, therefore, is based on the risk, which the NRC defines as the product of the 

probability and the consequences of an accident. This means that a high-consequence, lowprobability event, like a severe accident, could still result in a small impact determination, if the 

risk is sufficiently low. 

The NRC has considered a number of initiating events that could lead to a spent fuel pool fire. 

These events include loss of offsite power, internal fires, loss of pool cooling, loss-of-coolant 

inventory, seismic event, cask drop, aircraft crash, and a tornado missile (NRC 2001). These 

initiating events are discussed in more detail below and, as supplemented by the overall 

discussion of accidents in Section 4.18 of this GEIS, provide the range of credible initiating 

events for spent fuel pool fires. 

The main contributors to the frequency of loss-of-coolant in the pool and exposure of the spent 

fuel to air are seismic events and cask drop (NRC 2001). The low frequency of other events, 

(e.g., loss of offsite power, internal fires, loss of pool cooling, and loss-of-coolant inventory) 

were found in NUREG–WREHORZRQWKHEDVLVRIVSHFLILFLQGXVWU\GHFRPPLVVLRQLQJ

commitments and staff decommissioning assumptions discussed in Sections 3.3 and 3.4 of 

NUREG– (NRC 2001). As shown in Table F-1, for the credible initiating events 

considered, the NRC has determined that, considering the range in seismic hazard across the 

United States, the mean value of the frequency of fuel being uncovered could be between 

 ×10í Ryrí and 2.4 × 10í Ryrí depending upon the seismic hazard assessment 

(NRC 2001). Although some sites could have a value greater than 1 × 10í Ryrí, the value 

used in NUREG–bounds about  percent of the sites using the Lawrence Livermore 

National Laboratory hazard curves. These values are consistent with those used in 

COMSECY–13–0030 (NRC 2013b), where the likelihood of a release was judged in Table 43 to 

range from × 10í WR× 10í RyríZLWKDEHVWHVWLPDWHRQWKHRUGHURI× 10í Ryrí. 

For sites where seismically induced radiological release frequency exceeded the mean, the 

NRC determined in NUREG–WKDWEDVHGRQWKHJHQHULFVSHQWIXHOSRROIUDJLOLW\DQDO\VLV

the seismic risk at all but four sites—which included three western plants for which updated 

seismic hazard information was not available—was below the value consistent with the large 

early release frequency criterion for managing reactor risk (i.e., 1 × 10í Ryrí) (NRC 2001). 

Further, the NRC is requiring all operating reactor licensees to perform an updated seismic 

hazard evaluation for each site, which will include an evaluation of spent fuel pool seismic risk 

(NRC 2012b). Should new information indicate spent fuel pool risk is significantly greater than 

 

 The seismic risk analysis performed in NUREG–ZDVEDVHGRQVLWH-specific seismic hazard 

estimates for nuclear power plants in the central and eastern United States found in NUREG–1488, 

“Revised Livermore Seismic Hazard Estimates for 69 Nuclear Power Plant Sites East of the Rocky 

Mountains” (NRC 1994). As such, nuclear power plants in the western United States (e.g., Diablo 

Canyon, San Onofre, and Columbia) were not specifically considered in this study. 
Appendix F 

September 2014 F-11 185(*௅

previously considered, the NRC would take the appropriate regulation action to ensure 

protection to public health and safety. Seismic risk, in general, is discussed in more detail in 

Section 4.18. However, because of the reduction in both the radionuclide inventory due 

radioactive decay and the heat generated by the spent fuel, the greatest risk from a spent fuel 

pool fire would be at the beginning of the short-term timeframe, and risk would decrease over 

time. 

On the issue of boiloff events, NUREG–15&IRXQGWKDW, given the industry 

decommissioning commitments and staff decommissioning assumptions, the likelihood of 

boiloffs from all causes was comparable to the likelihood of fuel uncovery from a cask drop or to 

the likelihood of a seismically induced pool failure based on the EPRI seismic hazard estimates, 

and approximately an order of magnitude lower than the likelihood of a seismically induced pool 

failure based on the Lawrence Livermore National Laboratory seismic hazard estimates. Slow 

boiloff events can lead to an accident progression qualitatively similar to a partial draindown or a 

slow draindown. However, the time before the water in the spent fuel pool would heat up and 

boil off would vary based on the decay power of the spent fuel in the pool. Boiloff events are 

discussed in Section RI185(*– As the short-term timeframe considered in this 

GEIS can last up to 60 years after final shutdown, the drop in decay power of the fuel would 

lead to a boiloff scenario that proceeds increasingly slowly with the passage of time. In general, 

decay power is dominated by the most recently discharged fuel, as shown in the comparison of 

a high- and low- density loading pool configuration found in Section 6.3.1 of SECY–13–0112 

(NRC 2013a). The effect that reduced decay power has on time available for pool recovery is 

demonstrated by Table 2.1 of NUREG– (NRC 2001), which shows that the time until fuel 

uncovery ranges from at least 4 days at 60 days following shutdown to more than 22 days at 

10 years following shutdown. As the spent fuel continues to cool following the permanent 

cessation of operation, the increasingly slow rate of boiloff that results renders pool recovery 

increasingly likely with the passage of time. Based on significant time between the initiating 

event and the spent fuel assemblies becoming partially or completely uncovered, the licensee 

and State and Federal authorities would have time to initiate appropriate mitigating actions to 

prevent a spent fuel pool fire, and if a release is projected to occur, for offsite agencies to take 

protective actions to protect the health and safety of the public. Although the environment near 

a pool undergoing boiloff could make pool recovery challenging, the pool is an unpressurized 

system and the water level can be recovered with fairly simple systems. Further, in contrast to 

large leaks resulting from structural failure of the spent fuel pool, large volumes of water would 

not be needed to make up for boiloff losses. Nevertheless, boiloff events were considered in 

NUREG–DQGDUHLQFOXGHGLQWKHUHVXOWVVXPPDUL]HGLQTable F-2. 

As discussed earlier, the source term used in this GEIS is derived from the low Ru source term 

used in NUREG–,WLQFOXGHVERWKWKHILQDOFRUHRIIload and the previous ten refueling 

RXWDJHRIIORDGV15&7KH15&HVWLPDWHGWKLVWREHURXJKO\FRUHORDGVLQWKHVSHQW

fuel pool, based on an adjusted inventory for the Millstone 1 nuclear power plant that accounted 
Appendix F 

185(*௅ F-12 September 2014 

for larger reactors and the fact that NUREG–ZDVOimited to spent fuel pool accidents 

during decommissioning (NRC 2001). As discussed previously, these values are somewhat 

lower than those reported in COMSECY–13–0030 (NRC 2013b). In addition, the NRC 

considered a range of times in which the event could occur after shutdown, including 30 days, 

GD\V\HDUV\HDUVDQG\HDUVDIWHUILQDOVKXWGRZQ15&

Table F-2. Comparison of Frequency-Weighted Consequences from Reactor Accidents and 

Spent Fuel Pool Fires 

Accident 

Type 

Individual Risk Population Risk 

Early 

Fatalities 

(within 1 mi) 

(Ryrí) 

Latent 

Fatalities 

(within 10 mi) 

(Ryrí) 

Collective 

Dose 

(person-Sv 

Ryrí) 

Early 

Fatalities 

(Ryrí) 

Latent 

Fatalities 

(Ryrí) 

Economic 

Damage 

($ Ryrí)

(a)

Severe 

Reactor 

Accident(b)

îí îí 0.06 2.0 × 10í îí 1.1 × 10F

Spent Fuel 

Pool Fire(d) 

3.9 × 10í to 

3.0 × 10í

3.1 × 10í to 

 × 10í

0.11 to 0.13 1.9 × 10í to 

 × 10í

 × 10í to 

.9 × 10íH

1.0 × 10Ito 

1.1 × 10J

(a) Values adjusted to 2010 dollars using the Consumer Price Index Inflation Calculator. 

(b) From NUREG–IRU6XUU\3RZHU6WDWLRQ15&H[FHSWIRUHFRQRPLFGDPDJHVHH1RWHF

(c) From NUREG–Supplement 6, Surry Power Station Units 1 and 2 (NRC 2002), without public exposure 

costs. 

(d) From NUREG–15&7DEOH-2 late evacuation and Table 3.1 total fuel uncovery frequency 

assuming Lawrence Livermore National Laboratory seismic hazard), except population latent fatality and 

economic damage risks. 

(e) From NUREG–15&7DEOHV$-WKURXJK$-9), which reflect a range of the three Surry cases 

evaluated, for distances up to 160 km (100 mi), and between 30 days and 1 year decay time prior to the 

accident. Event frequency is 2.4 × 10í Ryrí(NRC 2001). 

(f) NUREG/BR–15&7DEOHV&DQG&ZLWKRXWUHSODFHPHQWSRZHUFRVWV

(g) From NUREG–15&7DEOHVDQGZLWKRXWUHSODFHPHQWSRZHUFRVWV

Spent fuel is susceptible to ignition (i.e., a runaway oxidation reaction) only if the fuel is not aircoolable in the event of water loss. There may be many scenarios where the fuel is aircoolable. For example, for the specific conditions analyzed in SECY–13–0112 (NRC 2013a, the 

NRC found that the fuel was air-coolable (defined in that study as no radioactive release within 

KRXUVDERXWWZRPRQWKVDIWHUUHDFWRUVKXWGRZQBecause the short-term timeframe 

considered in this GEIS can last for up to 60 years beyond the licensed life for operation, the 

drop in decay power of the fuel makes air-coolability increasingly likely with the passage of time 

in the event of a complete loss of water. However, the effect of partial draindowns that restrict 

airflow can result in degraded air-cooling. As discussed in NUREG–15&the NRC 

has not defined an age after which spent fuel is no longer susceptible to ignition. NUREG–

therefore assumed that a fire would be initiated if the water level reached 0.9 m (3 ft) from the 

top of the spent fuel. The quantitative impact estimates in Table F-1 and Table F-2 are based 
Appendix F 

September 2014 F-13 185(*௅

on this assumption, with the range of quantitative impact estimates using decay times of 

anywhere from 30 days to 10 years after final shutdown. However, as the fuel continues to age 

after reactor shutdown, it will become less hazardous due to radioactive decay and the 

reduction of the heat generated by the spent fuel. Thus, both the consequences and risk 

predicted by the analysis will continue to decrease in comparison to the values in Table F-1 

through the short-term timeframe because the fuel would have been cooling in the spent fuel 

pool for a longer period of time, which would increase the likelihood of air-coolability and 

decrease source term (less radionuclide inventory) due to decay, particularly for the short-lived 

radionuclides that would contribute the most to the potential for early fatalities. 

In NUREG–WKH15&GHWHUPLQHGWKDWWKHSUREDELOLW\-weighted consequences of a spent 

fuel pool accident, including a spent fuel pool fire, could be comparable to the probabilityweighted consequences of a severe reactor accident (NRC 2001). Therefore, the NRC has 

decided to include a comparison of the frequency-weighted consequences of a severe reactor 

accident to the frequency-weighted consequences of a spent fuel pool fire to provide a more 

complete picture of the overall risks of a spent fuel pool fire. As discussed above, the 

frequency-weighted consequences, or the risk, of a spent fuel pool fire represent the NRC’s 

determination of the environmental impacts of this event. 

Table F-2 provides the probability-weighted consequences (risk) resulting from a spent fuel pool 

fire. This table demonstrates that the probability-weighted consequences of a spent fuel pool 

fire are comparable to those for severe reactor accidents. Early in the short-term timeframe, the 

offsite health impacts of a spent fuel pool fire, as evaluated in NUREG– (NRC 2001), can 

be comparable to those from a severe accident at an operating reactor. More recent studies, 

such as NUREG–6WDWH-of-the-Art Reactor Consequence Analyses (SOARCA) Report 

(NRC 2012a) and SECY–13–0112 (NRC 2013a, respectively, suggest that probability-weighted 

health impacts of reactor accidents and spent fuel pool accidents would be low and well within 

the Commission’s safety goals. In the unlikely event of an accident at either a reactor or spent 

fuel pool, the probability-weighted consequences of offsite economic impacts would be 

comparable because, while the economic impacts of a spent fuel pool fire could be larger than 

those from a reactor accident, a spent fuel pool accident is less likely than a reactor accident. 

With the exception of the economic damage risk figures for spent fuel pool fire, all of the risk 

values in Table F-2 are for Surry. Economic damage risk figures for spent fuel pool fires are not 

DYDLODEOHIRU6XUU\WKXVWKLV*(,6Xses available economic damage risk figures that are as 

VLPLODUDVSRVVLEOH$VLPLODUFDVHVWXGLHGSUHYLRXVO\E\15&LQYROYHGFRUHVRIVSHQWIXHO

from the R.E. Ginna nuclear power plant and an 80-NP-mi) average population density of 

330 persons/km2 (860 persons/mi2), which is based on the population around the Zion in Illinois 

(NRC 1989). Given that the analysis in this GEIS is concerned with spent fuel pool fires at 

nuclear power plants that have permanently ceased operations, the economic damage risk 

figures for spent fuel pool fires presented in Table F-2 do not include replacement power costs. 
Appendix F 

185(*௅ F-14 September 2014 

The costs considered include those for onsite cleanup, repair, disposal of wastes, and offsite 

economic damage (e.g., relocation of people and property decontamination). 

The NRC is using the results for Surry because there are few stations for which quantitative risk 

values are available for both an onsite reactor accident and a spent fuel pool fire. The NRC 

believes that a comparison of severe reactor accidents and spent fuel pool fires for Surry is 

appropriate for this generic analysis because: 

x Each of the two pressurized water reactor units at Surry generate approximately the same 

levels of thermal and electric power as the reference facility described elsewhere in this 

GEIS (838 MW(e) versus the reference value of 1,000 MW(e)), and the shared Surry spent 

fuel pool is licensed to store 1,044 spent fuel assemblies—the equivalent of about 4.6 full 

UHDFWRUFRUHVRUDERXW078—which is approximately the pool capacity used elsewhere 

LQWKLV*(,6078YHUVXVWKHUHIHUHQFHYDOXHRI0787KH15&KDVGHWHUPLQHG

that the differences between the Surry and the reference facility values are not significant for 

this impact analysis and, as noted above, the impacts can be scaled appropriately for any 

particular facility’s surrounding population and source term characteristics. 

x The consequences of a severe reactor accident will change in direct proportion to the 

reactor’s power level. Likewise, the consequences of a spent fuel pool fire will change in 

direct proportion to the amount of spent fuel stored in the pool. In the case of Surry, both 

the reactor power level and the spent fuel pool licensed capacity are both about the same 

proportion lower than the reference facility described in Chapter 2 of the GEIS. As a result, 

the ratio of severe reactor accident risk to spent fuel pool fire risk is likely to be similar for the 

reference reactor described in Chapter 2. 

The risk values in Table F-2 include individual risks and population risks. The individual risk 

values for both severe reactor accidents and spent fuel pool fires are comparable to each other 

and both lower than the NRC’s Quantitative Health Objectives contained in its Safety Goal 

3ROLF\6WDWHPHQW)5IRUERWKLQGLYLGXDOHDUO\IDWDOLW\ULVN × 10íRyrí) and 

individual latent fatality risk (2 × 10í Ryrí) (NRC 2001). As stated above, the population risk 

values for the two accident types are comparable. The public exposure costs are not included 

in the severe reactor accident economic cost-risk figures because the spent fuel pool fire 

economic damage risk from the reports cited did not include public exposure costs. 

This analysis shows that the probability-weighted consequences for a spent fuel pool fire, as 

analyzed in NUREG–DUHFRPSDUDEOHWRWKHSUREDELOLW\-weighted consequences for 

severe power reactor accidents analyzed in the 1996 and 2013 License Renewal GEIS (NRC 

1996, 2013c). Not only are spent fuel pool probability-weighted consequences comparable, but 

NUREG–FRQWDLQVVHYHUDOEXLOW-in conservative assumptions. For example, NUREG–

assumed that the zirconium fuel cladding would start to burn and was nonrecoverable as soon 

as the water level in the spent fuel pool fell to within 0.9 m (3 ft) of the top of the fuel assemblies 
Appendix F 

September 2014 F- 185(*௅

15&+RZHYHUD'HQLDORI3HWLWLRQIRU5XOHPDNLQJ)5DQDO\Vis shows 

that there would be significant time between the initiating event and the spent fuel assemblies 

becoming partially or completely uncovered. In addition, air-cooling of spent fuel in the event of 

a complete draindown would be sufficient to prevent spent fuel pool zirconium fires at a point 

much earlier following fuel offload from the reactor than was considered in NUREG–

 FR 46204). Thus, more time would be available for operator intervention, which would 

lower the probability of a draindown event leading to a spent fuel pool fire. 

Since the publication of NUREG–WKH15&KDVUHTXLUHGOLFHQVHHVWRXQGHUWDNHDGGLWLRQDO

actions to further reduce the probability of a spent fuel pool fire. These additional actions 

resulted from insights following the September 11, 2001 terrorist attack and the March 11, 2011 

Fukushima Dai-ichi accident. 

In response to the September 11, 2001 terrorist attacks, the NRC imposed license conditions at 

most operating reactors to ensure that licensees have mitigating strategies in place for attacks 

on spent fuel pools. Those conditions would remain in place after shutdown. Where license 

conditions are not in place, the NRC has determined, based on site-specific physical 

characteristics, that the spent fuel pool is not susceptible to being breached and drained of 

cooling water. These requirements were FRGLILHGLQ&)5KK:KLOHWKH

UHTXLUHPHQWVRI&)5KKDUHFXUUHQWO\QRWDSSOLFDEOHIRUVSHQWIXHOSRROVDW

decommissioning reactors, the NRC is considering rulemaking to, among other things, apply the 

requirements of 10 CFR KKWRGHFRPPLVVLRQLQJIDFLOLWLHVZLWKVSHQWIXHOVWLOOLQDVSHQW

fuel pool. See rulemaking docket NRC-2011-0299, “Station Blackout Mitigation” for more 

information. Other organizations, such as Sandia National Laboratory, have confirmed the 

effectiveness of the additional mitigation strategies to maintain spent fuel cooling in the event 

the pool is drained and LWVLQLWLDOZDWHULQYHQWRU\LVUHGXFHGRUORVWHQWLUHO\)5

Generic strategies for spent fuel pool cooling are further discussed in a publication prepared by 

the Nuclear Energy Institute, a nuclear industry policy group, in NEI–06–12, Revision 2 (NEI 

2006), which has been endorsed by the NRC. As a result of these additional actions, NRC has 

concluded that the probability of an initiating event leading to a spent fuel pool fire is less likely 

than analyzed in the NUREG– (NRC 2001) and previRXVVWXGLHV)5

Therefore, the analysis provided in Table F-2, based upon NUREG–LVDFRQVHUYDWLYH

estimate of spent fuel pool risk. 

The NRC conducted additional evaluations to assess its regulatory framework in response to 

the March 2011 Fukushima Dai-ichi events. On March 11, 2011, a massive earthquake off the 

east coast of Honshu, Japan, produced a devastating tsunami that struck the coastal town of 

Fukushima. The six-unit Fukushima Dai-ichi nuclear power plant was most directly affected by 

these events. Damage to the systems and structures of the reactor building resulted in the 

release of radioactive material to the surrounding environment. While this accident led to a 

substantial release of radioactive material, the fuel stored in the spent fuel pools was not 
Appendix F 

185(*௅ F-16 September 2014 

uncovered and the event did not lead to a spent fuel pool fire. Information on the event 

indicates that spent fuel pool cooling was lost for all spent fuel pools following the loss of offsite 

power (INPO 2011). But subsequent analyses and inspections confirmed that the spent fuel 

pool water levels did not drop below the top of the fuel in any of the spent fuel pools and no 

significant damage occurred to the fuel in the pools. These events demonstrate that, even 

without spent fuel cooling for multiple days, the pools were able to keep the spent fuel cool 

(INPO 2012). 

In response to the earthquake, tsunami, and resulting reactor accidents at Fukushima Dai-ichi, 

the Commission directed the staff to convene an agency task force of senior leaders and 

experts to conduct a methodical and systematic review of the relevant NRC regulatory 

requirements, programs, and processes, including their implementation, and to recommend 

whether the agency should make near-term improvements to its regulatory system. As part of 

the short-term review, this Near-Term Task Force concluded that some additional improvements 

to spent fuel pool storage and other structures, systems, and components would be beneficial. 

In NRC Order EA–12–049, the NRC required operating reactor licensees to implement 

mitigating strategies to ensure that spent fuel pool cooling can be accomplished through 

alternative means to prevent fuel damage (NRC 2012c). In addition, in NRC Order EA–12–

the NRC determined that operating reactor licensees must have a reliable means to remotely 

monitor a wide-range of spent fuel pool levels to support effective prioritization of event 

mitigation and recovery actions in the event of a beyond-design-basis external event 

(NRC 2012d). 

As part of the agency’s Station Blackout Mitigation rulemaking, the NRC is considering a variety 

of requirements that would further decrease the probability of a spent fuel pool fire during the 

short-term timeframe. Among the options being evaluated as part of this rulemaking is the need 

to require licensees of decommissioning facilities to develop mitigating strategies to restore 

spent fuel pool cooling, similar to what is now required of operating reactor licensees. These 

measures would further reduce the probability of a spent fuel pool fire, and thus further increase 

the conservatism of the estimate of spent fuel pool risk provided in Table F-2. 

F.1.3 Conclusion 

In summary, the conservative estimates that the NRC is using to assess spent fuel pool fire 

accidents, based upon NUREG–DQGRWKHUDQDO\VHVUHVXOWVLQSUREDELOLW\-weighted 

population doses and economic consequences that are comparable to the values calculated for 

a severe reactor accident, as estimated in the 1996 and 2013 License Renewal GEIS (NRC 

1996, 2013c). Further, mitigation measures implemented by licensees as a result of NRC 

orders and regulations adopted since NUREG–KDYHIXUWKHUORZHUHG the probability and 

risk of a spent fuel pool fire. As a result, the NRC finds that the environmental impacts from 

spent fuel pool fires are SMALL during the short-term storage timeframe. 
Appendix F 

September 2014 F- 185(*௅

F.2 References 

F.2.1 Summary of Major Studies Considered in this Appendix 

One of the earlier spent fuel pool accident studies considered by the NRC was Reactor Safety 

Study: An Assessment of Accident Risks in U.S. Commercial Nuclear Power Plants (NRC 

7KH5HDFWRU6DIHW\6WXG\SURYLGHVDV\VWHPDWLFTXDQWLILFDWLRQRIFRPPHUFial nuclear 

reactor accident probabilities. Appendix I of the Reactor Safety Study covers various accidents, 

including spent fuel pool accidents. The Reactor Safety Study states that spent fuel pool 

accidents can arise from either loss of spent fuel pool cooling, drainage of the spent fuel pool, or 

dropping of heavy items into the spent fuel pool. The Reactor Safety Study also indicates that 

the probability of a loss-of-cooling event is small at less than 0.1 events per year. The Reactor 

Safety Study used this information to estimate the probability of fuel damage due to loss of pool 

cooling. This study examined drainage of the spent fuel pool and concluded that the probability 

of drainage is much lower than for a loss-of-cooling event because drainage would require 

multiple failures to occur simultaneously. In addition to loss-of-cooling accidents, the Reactor 

Safety Study examined mechanical failure, both for dropping a cask into the spent fuel pool or 

due to an earthquake. This study concluded that the risks for a spent fuel pool accident were 

orders of magnitude below those involving the reactor core because of the robust design of the 

spent fuel pool. 

In 1989, the NRC completed a generic analysis of potential accidents in spent fuel pools, 

Regulatory Analysis for the Resolution of Generic Issue 82, ‘Beyond Design Basis Accidents in 

Spent Fuel Pools’ (NRC 1989). This analysis reexamined spent fuel pool fires because 1) spent 

fuel pool storage had been expanded, including use of high-density storage racks and 2) new 

research had provided evidence of the possibility of fire propagation between assemblies in an 

air-cooled environment. This generic analysis examined the various spent fuel pool and spent 

fuel storage rack designs. The NRC used this information to assess various accident 

sequences, including failure due to missiles, aircraft crashes, heavy-load drop, seal failure, 

inadvertent draining, loss-of-cooling, and seismic events. The NRC quantified the probabilities 

of these initiation events and assessed both the health and economic consequences. 

The safety and environmental effects of spent fuel pool storage were further addressed in 

conjunction with regulatory assessments of permanently shutdown nuclear plants and 

decommissioning nuclear power plants. NUREG/CR–A Safety and Regulatory 

Assessment of Generic BWR and PWR Permanently Shutdown Nuclear Power Plants (Travis et 

DODGGUHVVHGWKHDSSURSULDWHQHVs of regulations (e.g., requirements for emergency 

planning and insurance) associated with spent fuel pool storage. The study also provided 

bounding estimates for offsite consequences for the most severe accidents, which would involve 

draining of the spent fuel pool (e.g., complete draining of the spent fuel pool occurs 12 days 

after shutdown of the reactor). 
Appendix F 

185(*௅ F-18 September 2014 

In 2001, the NRC published the results of its technical study on spent fuel pool accident risk at 

decommissioning nuclear power plants. This study, NUREG–Technical Study of Spent 

Nuclear Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants, also examined 

spent fuel pool zirconium fires (NRC 2001). The NRC’s analyses showed that, although the 

consequences for a spent fuel pool fire could be high, the risk (probability-weighted 

consequence) would be low because the loss-of-coolant event frequency is low. The NRC’s 

analysis was based on a spent fuel pool at a decommissioning nuclear power plant but included 

times shortly after plant shutdown. Therefore, the study included analysis of accident conditions 

for spent fuel that had various amounts of decay heat. The risk analyses included sensitivity 

studies to evaluate scenarios in which members of the public residing near the plant did not 

evacuate as promptly as expected, given emergency preparedness requirements. This analysis 

DVVXPHGDVSHQWIXHOSRROLQYHQWRU\HTXLYDOHQWWRUHDFWRUFRUHVDPXFKPRUHGHQVHO\

SDFNHGSRROWKDQDVVXPHGE\WKH5HDFWRU6DIHW\6WXG\)XUWKHU185EG–LQFOXGHG

core loads with an average fuel burnup of 60 gigawatt-days/metric ton uranium, which is 

consistent with high-burnup fuel. This study represents the NRC’s current judgment as to the 

expected impacts from a spent fuel pool fire during the short-term storage timeframe. 

In 2013, the NRC completed Consequence Study of a Beyond-Design-Basis Earthquake 

Affecting the Spent Fuel Pool for a U.S. Mark I Boiling Water Reactor, which was published as 

SECY–13–0112 (NRC 2013a). This study continued the NRC’s examination of the risks and 

consequences of postulated spent fuel pool accidents. The purpose of this study was to 

determine if accelerated transfer of older, cooler spent fuel from the spent fuel pool at a 

reference plant to dry cask storage would significantly reduce risks to public health and safety. 

The specific reference plant used for this study was a GE Type 4 BWR with a Mark I 

containment. This study presented a detailed analyses using state-of-the-art, validated, 

deterministic methods and assumptions, as well as probabilistic insights where practical. 

Previous studies had shown that earthquakes present the dominant risk for spent fuel pools, so 

this analysis considered a severe earthquake with ground motion stronger than the maximum 

earthquake reasonably expected to occur for the reference plant, which would challenge the 

spent fuel pool integrity. The study considered two spent fuel configurations—high-density and 

low-density loading—and the successful and XQVXFFHVVIXOGHSOR\PHQWRI&)5KK

mitigation. The results of SECY–13–0112 are consistent with earlier research conclusions that 

spent fuel pools are robust structures that are likely to withstand severe earthquakes without 

leaking. The results of SECY–13–0112 show that the overall level of safety with respect to 

spent fuel storage in a spent fuel pool currently achieved at the reference plant is high and that 

the level of risk at the reference plant is very low. 

In 2013, the NRC performed an evaluation of whether additional study of expedited transfer of 

spent fuel from spent fuel pools might be warranted. This evaluation was documented in 

COMSECY–13–0030 (NRC 2013b). For this analysis, the NRC evaluated the merits of 

additional research by comparing the status quo to a scenario in which expedited transfer would 
Appendix F 

September 2014 F-19 185(*௅

be required. The NRC’s analysis in COMSECY–13–0030 expanded upon the regulatory 

analysis in SECY–13–0112 (NRC 2013a) by covering spent fuel pool designs used in operating 

and decommissioned reactors in the United States. To determine if additional studies were 

needed, the NRC conducted a two-part analysis of expedited transfer. The NRC first assessed 

the potential safety benefits by using the Commission’s 1986 Safety Goal Policy Statement. The 

NRC then proceeded to perform a cost-benefit analysis to provide additional information for the 

Commission’s consideration. Despite the large releases for some low-probability accident 

progressions analyzed, the projected consequences indicated that there would be no offsite 

early fatalities from acute radiation effects. In addition, the NRC found that the added costs 

involved with expedited transfer of spent fuel to dry cask storage in order to achieve the lowdensity loading spent fuel pool storage alternative were not warranted in light of the benefits 

from expedited transfer. Based on the generic assessment and the other considerations 

detailed in COMSECY–13–0030 (NRC 2013b), the NRC found that additional studies were not 

needed to reasonably conclude that the expedited transfer of spent fuel to dry cask storage 

would provide only a minor or limited safety benefit (i.e., below the safety goal screening 

criteria), and that expected implementation costs would not be warranted. In 2014, the NRC 

closed the Tier 3 Japan lessons learned activity related to expedited transfer of spent fuel

however, the Commission directed the NRC staff to modify the regulatory analysis in 

COMSECY–13–0030 to explain why the “1 x 8” spent fuel pool loading configuration was not 

found to provide a substantial increase in safety (NRC 2014). 

F.2.2 List of References 

&)53DUWCode of Federal Regulations, Title 10, Energy, 3DUW3'RPHVWLF/LFHQVLQJRI

Production and Utilization Facilities.” Washington, D.C. 

)5$XJXVW36DIHW\*RDOVIRUWKH2SHUDWLRQVRI1XFOHDU3RZHU3ODQWV

Policy Statement, Republication.” Federal Register, U.S. Nuclear Regulatory Commission, 

Washington, D.C. 

)5$XJXVW37KH$WWRUQH\*HQHUDORI&RPPRQZHDOWKRI0DVVDFKXVHWWV

7KH$WWRUQH\*HQHUDORI&DOLIRUQLD'HQLDORI3HWLWLRQVIRU5XOHPDNLQJ ́Federal Register, 

U.S. Nuclear Regulatory Commission, Washington, D.C. 

Gauntt, R.O. 2010. MELCOR 1.8.5 Modeling Aspects of Fission Product Release, Transport 

and Deposition. SAND2010–, Sandia National Laboratory, Albuquerque, New Mexico. 

Available at http://prod.sandia.gov/techlib/access-FRQWUROFJLSGI.
Appendix F 

185(*௅ F-20 September 2014 

INPO (Institute of Nuclear Power Operations). 2011. Special Report on the Nuclear Accident at 

the Fukushima Dai-ichi Nuclear Power Station. INPO–11–5HYLVLRQ$WODQWD*HRUJLD

Available at 

KWWSZZZQHLRUJFRUSRUDWHVLWHPHGLDILOHIROGHUBB6SHFLDOB5HSRUWBRQB)XNXVKLPDB'DLLF

hi_MASTER_11_08_11_1.pdf. 

INPO (Institute of Nuclear Power Operations). 2012. Lessons Learned from the Nuclear 

Accident at the Fukushima Dai-ichi Nuclear Power Station. INPO–11–$GGHQGXP

Revision 0, Atlanta, Georgia. Available at 

http://www.wano.info/Documents/Lessons%20Learned.pdf. 

NEI (Nuclear Energy Institute). 2006. B.5.b Phase 2 & 3 Submittal Guideline. NEI–06–12, 

5HYLVLRQ:DOQXW&UHHN&DOLIRUQLD$FFHVVLRQ1R0/

15&861XFOHDU5HJXODWRU\&RPPLVVLRQReactor Safety Study: An Assessment of 

Accident Risks in U.S. Commercial Nuclear Power Plants. NUREG–:$6+–1400), 

:DVKLQJWRQ'&$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 1989. Regulatory Analysis for the Resolution of 

Generic Issue 82, “Beyond Design Basis Accidents in Spent Fuel Pools.” NUREG–

Washington, D.C. Accession No. ML082330232. 

NRC (U.S. Nuclear Regulatory Commission). 1990. Severe Accident Risks: An Assessment 

for Five U.S. Nuclear Power Plants. NUREG–9ROXPH:DVKLQJWRQ'&$FFHVVLRQ

No. ML120960691. 

NRC (U.S. Nuclear Regulatory Commission). 1994. Revised Livermore Seismic Hazard 

Estimates for Sixty-Nine Nuclear Power Plant Sites East of the Rocky Mountains. 

NUREG–:DVKLQJWRQ'&$FFHVVLRQ1R0/

NRC (U.S. Nuclear RegXODWRU\&RPPLVVLRQAccident Source Terms for Light-Water 

Nuclear Power Plants. NUREG–:DVKLQJWRQ'&$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 1996. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants. NUREG–:DVKLQJWRQ'&$YDLODEOHDW

http://www.nrc.gov/reading-rm/doc-FROOHFWLRQVQXUHJVVWDIIVU. 

NRC (U.S. Nuclear Regulatory Commission). Regulatory Analysis Technical Evaluation 

Handbook. NUREG/BR–:DVKLQJWRQ'&$FFHVVLRQ1R0/
Appendix F 

September 2014 F-21 185(*௅

NRC (U.S. Nuclear Regulatory Commission). 2001. Technical Study of Spent Nuclear Fuel 

Pool Accident Risk at Decommissioning Nuclear Power Plants. NUREG–:DVKLQJWRQ

D.C. Accession No. ML010430066. 

NRC (U.S. Nuclear Regulatory Commission). 2002. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants, Supplement 6 Regarding Surry Power Station, Units 1 

and 2. NUREG–6XSSOHPHQW:DVKLQJWRQ'&$FFHVVLRQ1R0/

NRC (U.S. Nuclear Regulatory Commission). 2012a. State-of-the-Art Reactor Consequence 

Analyses (SOARCA) Report. NUREG–:DVKLQJWRQ'&$FFHVVLRQ1R0/$

NRC (U.S. Nuclear Regulatory Commission). 2012b. Request for Information Pursuant to Title 

10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, 

of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident. 

Washington, D.C. Accession No. 0/$. 

NRC (U.S. Nuclear Regulatory Commission). 2012c. Issuance of Order to Modify Licenses 

with Regard to Requirement for Mitigation Strategies for Beyond-Design-Basis External Events. 

EA–12–049, Washington, '&$FFHVVLRQ1R0/$

NRC (U.S. Nuclear Regulatory Commission). 2012d. Issuance of Order to Modify Licenses 

with Regard to Reliable Spent Fuel Pool Instrumentation. EA–12–15&–2012–

:DVKLQJWRQ'&$FFHVVLRQ1R0/$

NRC (U.S. Nuclear Regulatory Commission). 2013a. Consequence Study of a Beyond-DesignBasis Earthquake Affecting the Spent Fuel Pool for a U.S. Mark I Boiling Water Reactor. 

SECY–13–0112:DVKLQJWRQ'&$FFHVVLRQ1R0/$

NRC (U.S. Nuclear Regulatory Commission). 2013b. Staff Evaluation and Recommendation 

for Japan Lessons-Learned Tier 3 Issue on Expedited Transfer of Spent Fuel. COMSECY–13–

0030, Washington, D.C. Accession No. ML13329A918. 

NRC (U.S. Nuclear Regulatory Commission). 2013c. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants. NUREG–5HYLVLRQ Washington, D.C. 

Accession No. 0/$. 

NRC (U.S. Nuclear Regulatory Commission). 2014. Memorandum from R.C. Bavol to M.A. 

Atorius, dated May 23, 2014, “Staff Requirements—COMSECY–13–0030—Staff Evaluation and 

Recommendation for Japan Lessons-Learned Tier 3 Issue on Expedited Transfer of Spent 

Fuel.” Washington, D.C. Accession No. ML14143A360.
Appendix F 

185(*௅ F-22 September 2014 

Travis, R.J., R.E. Davis, E.J. Grove, and M.A. Azarm. Safety and Regulatory 

Assessment of Generic BWR and PWR Permanently Shutdown Nuclear Power Plants. 

NUREG/CR–, Brookhaven National Laboratory, Upton, New York. Accession No. 

ML082260098. 
Appendix G 

–

Spent Fuel Storage Facilities 

September 2014 G-1 185(*௅

Appendix G 

Spent Fuel Storage Facilities 

This appendix provides summary information concerning spent nuclear fuel (spent fuel) pools 

and independent spent fuel storage installations (ISFSIs), which are located primarily at 

operating commercial power reactors and decommissioned reactor sites.

Table G-1 through Table G-3 provide information about spent fuel pools. Specifically, Table G-1 

lists operating reactors and the capacities of their spent fuel pools. Capacities at single-unit 

SUHVVXUL]HGZDWHUUHDFWRU3:5SRZHUSODQWVUDQJHIURP assemblies at the H.B. Robinson 

Steam Electric Plant, Unit 2 to 2,363 assemblies at the Callaway Plant and the Wolf Creek 

Generating Station. At boiling water reactor (BWR) power plants, spent fuel pool capacities 

range from 1,803 assemblies at the Brunswick Steam Electric Generating plant to 4,608 

assemblies at Fermi, Unit 2. 

Table G-2 indicates the capacity of spent fuel pools for power reactors under construction, 

namely Vogtle Electric Generating Plant, Units 3 and 4; Virgil C. Summer Nuclear Station Units, 

2 and 3; and Watts Bar Nuclear Plant, Unit 2. Table G-3 provides the capacity of spent fuel 

pools for decommissioning reactors. As of June 30, 2014, seven decommissioning reactors at 

five sites have spent fuel stored in pools. These are Crystal River Nuclear Generating Plant, 

Unit 3; Kewaunee Power Station; Millstone Power Station, Unit 1; San Onofre Nuclear 

Generating Station, Units 2 and 3; and Zion Nuclear Power Station, Units 2 and 3. 

Table G-4 and Table G- provide information about ISFSIs with general and specific licenses 

under Title 10 of the Code of Federal Regulations &)53DUWUHVSHFWLYHO\These tables 

indicate which storage systems are in use at the ISFSIs and, if applicable, the transportation 

package associated with the storage system. The tables also indicate whether the storage 

system or transportation package is approved for use with high-burnup fuel.1 The ISFSIs are 

located at operating and decommissioning reactor sites. As of June 30, 2014, ISFSIs were 

operating at 64 sites. All ISFSIs are dry storage facilities except for the facility at the General 

Electric-Hitachi Morris Operation (GEH Morris) site, which is a wet storage facility. Table G-

also presents information about two specifically licensed ISFSIs (the Private Fuel Storage 

Facility and the Idaho Spent Fuel Facility) that were never constructed. 

 

1 The tables do not account for storage systems or transportation packages that the NRC has approved 

for use with high-burnup fuel but that are not in use at this time (e.g., the HI-STORM FW system). 
Appendix G 

185(*௅ G-2 September 2014 

The 10 CFR Part general license authorizes a nuclear power plant licensee to store spent 

fuel in casks approved by the U.S. Nuclear Regulatory Commission (NRC) at a site licensed to 

RSHUDWHDSRZHUUHDFWRUXQGHU&)53DUW RU. An NRC-approved cask is one that has 

undergone a technical review of its safety aspects and has been found to be adequate to store 

spent fuel at a site that meets all of the NRC's UHTXLUHPHQWVLQ&)53DUW$OLFHQVHHLV

required to perform an evaluation of its site to demonstrate that the site is adequate for storing 

spent fuel in dry casks. This evaluation must show that the cask certificate of compliance 

conditions and technical specifications can be met and must include an analysis of earthquake 

events and tornado missiles. In addition, the licensee must review its security program, 

emergency plan, quality assurance program, training program, and radiation protection 

program, and make any changes necessary to incorporate the ISFSI at the reactor site. 

5HTXLUHPHQWVIRUWKHJHQHUDOOLFHQVHDUHGHVFULEHGLQ6XESDUW.RI&)53DUW

Under a &)53DUWsite-specific license, an applicant submits a license application to the 

NRC. The NRC performs a technical review of all the safety aspects of the proposed ISFSI and 

an environmental review in compliance with the National Environmental Policy Act. If the 

application is approved, the NRC issues a license that is valid for up to 40 years. A spent fuel 

storage license contains technical requirements and operating conditions (i.e., fuel 

specifications, cask leak testing, surveillance, and other requirements) for the ISFSI and 

specifies what the licensee is authorized to store at the site. Requirements for the site-specific 

OLFHQVHDUHGHVFULEHGLQ6XESDUWV$WKURXJK,RI&)53DUW.
September 2014 G-3 185(*௅

Appendix G 

Table G-1. Capacity of Spent Fuel Pools for Operating Nuclear Power Reactors 

Operating Reactors 

Reactor 

Type 

Core Size 

(assemblies) 

Commercial 

Operation 

Start Date 

Pool 

Capacity 

(assemblies) 

Pool 

Capacity(a)

(cores) 

Estimated 

Pool 

Capacity(b)

(MTU) 

Arkansas Nuclear One, Unit 1 PWR   968  484.0 Arkansas Nuclear One, Unit 2 PWR  3/26/1980 988 4.6 494.0 Beaver Valley Power Station, Unit 1 PWR    9.4 

Beaver Valley Power Station, Unit 2 PWR   1,690 9.8 Braidwood Station, Unit 1 PWR 193  2,984  1,492.0 

Braidwood Station, Unit 2 PWR 193  See above (pool shared with Unit 1) 

Browns Ferry Nuclear Plant, Unit 1 BWR     

Browns Ferry Nuclear Plant, Unit 2 BWR     

Browns Ferry Nuclear Plant, Unit 3 BWR     

Brunswick Steam Electric Plant, Unit 1(c,e) BWR   1,803 2.2 

Brunswick Steam Electric Plant, Unit 2(d,e) BWR   1,839 2.3 342.1 

Byron Station, Unit 1 PWR 193  2,984  1,492.0 

Byron Station, Unit 2 PWR 193  See above (pool shared with Unit 1) Callaway Plant PWR 193 12/19/1984 2,363 11.2 Calvert Cliffs Nuclear Power Plant, Unit 1 PWR   1,830 6.4 

Calvert Cliffs Nuclear Power Plant, Unit 2 PWR   See above (pool shared with Unit 1) 

Catawba Nuclear Station, Unit 1 PWR 193  1,421 6.4 

Catawba Nuclear Station, Unit 2 PWR 193 8/19/1986 1,421 6.4 Clinton Power Station, Unit 1 BWR 624    

Columbia Generating Station, Unit 2 BWR  12/13/1984   494.4 

Comanche Peak Steam Electric Station, Unit 1 PWR 193 8/13/1990   

Comanche Peak Steam Electric Station, Unit 2 PWR 193 8/3/1993 See above (pool shared with Unit 1) 
185(*௅ G-4 September 2014 

Appendix G Table G-1. Capacity of Spent Fuel Pools for Operating Nuclear Power Reactors (cont’d) 

Operating Reactors 

Reactor 

Type 

Core Size 

(assemblies) 

Commercial 

Operation 

Start Date 

Pool 

Capacity 

(assemblies) 

Pool 

Capacity(a)

(cores) 

Estimated 

Pool 

Capacity(b)

(MTU) 

Cooper Nuclear Station BWR    3.8 493.1 Davis-Besse Nuclear Power Station, Unit 1 PWR   1,624 8.2 812.0 

Diablo Canyon Nuclear Power Plant, Unit 1 PWR 193  1,324  662.0 

Diablo Canyon Nuclear Power Plant, Unit 2 PWR 193 3/13/1986 1,324  662.0 

Donald C. Cook Nuclear Power Plant, Unit 1 PWR 193  3,613  Donald C. Cook Nuclear Power Plant, Unit 2 PWR 193  See above (pool shared with Unit 1) 

Dresden Nuclear Power Station, Unit 2 BWR    3.9 

Dresden Nuclear Power Station, Unit 3 BWR    3.9 Duane Arnold Energy Center BWR 368    

Edwin I. Hatch Nuclear Plant, Unit 1 BWR   3,349  622.9 

Edwin I. Hatch Nuclear Plant, Unit 2 BWR   2,933 4.2 

Fermi, Unit 2 BWR  1/23/1988 4,608  

Fort Calhoun Station, Unit 1 PWR 133  1,083  

Grand Gulf Nuclear Station, Unit 1 BWR 800  4,348 4.4 

H.B. Robinson Steam Electric Plant, Unit 2(e) PWR     

Hope Creek Generating Station, Unit 1 BWR  12/20/1986 4,006 4.2 

Indian Point Nuclear Generating, Unit 2 PWR 193   6.1 

Indian Point Nuclear Generating, Unit 3 PWR 193   6.0 

James A. FitzPatrick Nuclear Power Plant BWR   3,239 4.8 Joseph M. Farley Nuclear Plant, Unit 1 PWR    8.0 Joseph M. Farley Nuclear Plant, Unit 2 PWR    8.0 LaSalle County Station, Unit 1 BWR  1/1/1984 3,986 4.2 

LaSalle County Station, Unit 2 BWR  10/19/1984  4.3 

Limerick Generating Station, Unit 1 BWR  2/1/1986  4.4 

Limerick Generating Station, Unit 2 BWR  1/8/1990  4.4 

McGuire Nuclear Station, Unit 1 PWR 193 12/1/1981 1,463 6.6 
September 2014 G- 185(*௅

Appendix G 

Table G-1. Capacity of Spent Fuel Pools for Operating Nuclear Power Reactors (cont’d) 

Operating Reactors 

Reactor 

Type 

Core Size 

(assemblies) 

Commercial 

Operation 

Start Date 

Pool 

Capacity 

(assemblies) 

Pool 

Capacity(a)

(cores) 

Estimated 

Pool 

Capacity(b)

(MTU) 

McGuire Nuclear Station, Unit 2 PWR 193 3/1/1984 1,463 6.6 Millstone Power Station, Unit 2 PWR   1,346  

Millstone Power Station, Unit 3 PWR 193 4/23/1986 1,860 8.6 930.0 Monticello Nuclear Generating Plant, Unit 1 BWR 484  2,301 3.8 428.0 Nine Mile Point Nuclear Station, Unit 1 BWR  12/1/1969 4,086  

Nine Mile Point Nuclear Station, Unit 2 BWR  3/11/1988 4,049 4.3 

North Anna Power Station, Unit 1 PWR    9.1 

North Anna Power Station, Unit 2 PWR  12/14/1980 See above (pool shared with Unit 1) 

Oconee Nuclear Station, Unit 1 PWR   1,312  

Oconee Nuclear Station, Unit 2 PWR   See above (pool shared with Unit 1) 

Oconee Nuclear Station, Unit 3 PWR     

Oyster Creek Nuclear Generating Station, Unit 1 BWR  12/1/1969  4.4 

Palisades Nuclear Plant PWR 204  892 3.4 446.0 Palo Verde Nuclear Generating Station, Unit 1 PWR 241 1/28/1986 1,329  

Palo Verde Nuclear Generating Station, Unit 2 PWR 241 9/19/1986 1,329  

Palo Verde Nuclear Generating Station, Unit 3 PWR 241 1/8/1988 1,329  

Peach Bottom Atomic Power Station, Unit 2 BWR   3,819 4.0 

Peach Bottom Atomic Power Station, Unit 3 BWR   3,819 4.0 

Perry Nuclear Power Plant, Unit 1 BWR   4,020 4.4 

Pilgrim Nuclear Power Station BWR     

Point Beach Nuclear Plant, Unit 1 PWR 121   10.4 Point Beach Nuclear Plant, Unit 2 PWR 121  See above (pool shared with Unit 1) Prairie Island Nuclear Generating Plant, Unit 1 PWR 121  1,386  693.0 

Prairie Island Nuclear Generating Plant, Unit 2 PWR 121  See above (pool shared with Unit 1) Quad Cities Nuclear Power Station, Unit 1 BWR    4.1 680.2 

Quad Cities Nuclear Power Station, Unit 2 BWR    4.4 
185(*௅ G-6 September 2014 

Appendix G Table G-1. Capacity of Spent Fuel Pools for Operating Nuclear Power Reactors (cont’d) 

Operating Reactors 

Reactor 

Type 

Core Size 

(assemblies) 

Commercial 

Operation 

Start Date 

Pool 

Capacity 

(assemblies) 

Pool 

Capacity(a)

(cores) 

Estimated 

Pool 

Capacity(b)

(MTU) 

River Bend Station, Unit 1 BWR 624 6/16/1986 3,104 4.0 R.E. Ginna Nuclear Power Plant PWR 121  1,321 9.9 

St. Lucie Plant, Unit 1 PWR    6.9 St. Lucie Plant, Unit 2 PWR  8/8/1983  6.9 

Salem Nuclear Generating Station, Unit 1 PWR 193  1,632  816.0 

Salem Nuclear Generating Station, Unit 2 PWR 193 10/13/1981 1,632  816.0 

Seabrook Station, Unit 1 PWR 193 8/19/1990 1,236  618.0 

Sequoyah Nuclear Plant, Unit 1 PWR 193  2,091 9.8 Sequoyah Nuclear Plant, Unit 2 PWR 193 6/1/1982 See above (pool shared with Unit 1) Shearon Harris Nuclear Power Plant, Unit 1(f) PWR   1,128 6.2 

South Texas Project, Unit 1 PWR 193  1,969 9.2 

South Texas Project, Unit 2 PWR 193 6/19/1989 1,969 9.2 

Surry Nuclear Power Station, Unit 1 PWR   1,044 4.6 Surry Nuclear Power Station, Unit 2 PWR   See above (pool shared with Unit 1) 

Susquehanna Steam Electric Station, Unit 1 BWR  6/8/1983 2,840  

Susquehanna Steam Electric Station, Unit 2 BWR   2,840  

Three Mile Island Nuclear Station, Unit 1 PWR   1,062  

Turkey Point Nuclear Generating Station, Unit 3 PWR    8.8 Turkey Point Nuclear Generating Station, Unit 4 PWR    8.8 

Vermont Yankee Nuclear Power Plant, Unit 1(g) BWR 368   8.1 

Virgil C. Summer Nuclear Station, Unit 1 PWR  1/1/1984  9.9 

Vogtle Electric Generating Plant, Unit 1 PWR 193   6.6 

Vogtle Electric Generating Plant, Unit 2 PWR 193  2,098 9.9 1,049.0 Waterford Steam Electric Station, Unit 3 PWR   1,849  
September 2014 G-

 185(*௅

Appendix G 

Table G-1. Capacity of Spent Fuel Pools for Operating Nuclear Power Reactors (cont’d) 

Operating Reactors 

Reactor 

Type 

Core Size 

(assemblies) 

Commercial 

Operation 

Start Date 

Pool 

Capacity 

(assemblies) 

Pool 

Capacity(a)

(cores) 

Estimated 

Pool 

Capacity(b)

(MTU) 

Watts Bar Nuclear Plant, Unit 1(h) PWR 193  1,386 6.2 693.0 Wolf Creek Generating Station, Unit 1 PWR 193  2,363 11.2 Source: Reactor operating licenses, available through the NRC’s website at http://www.nrc.gov/reactors/operating/list-power-reactor-units.html (NRC 2014a). (a) Represents capacity with full core offload maintained; pool capacity (cores) is derived by subtracting one core’s worth of assemblies from 

pool capacity (assemblies) and then dividing that number by core size (assemblies). 

(b) 3RROFDSDFLW\078LVGHULYHGE\PXOWLSO\LQJNJRUPHWULFWRQSHUDVVHPEO\IRUD3:5or 186 kg (0.186 metric ton) per assembly 

for a BWR by the number of assemblies in pool capacity. 

(c) Plus 160 PWR assemblies. (d) Plus 144 PWR assemblies. (e) Brunswick Steam Electric Plant and H.B. Robinson Steam Electric Plant shipped to Shearon Harris Nuclear Power Plant. (f) 6KHDURQ+DUULVLVOLFHQVHGWRVWRUH%:5IXHODVVHPEOLHVIURPRWKHUSODQWVLQDGGLWLRQWRLWVPWR fuel assemblies. 

(g) Entergy Nuclear Operations has certified that power operations will permanently cease in the fourth quarter of 2014 (Entergy 2013). 

(h) Watts Bar Nuclear Plant, Unit 2 is under construction and would share the pool with Unit 1. 
185(*௅ G-8 September 2014 

Appendix G Table G-2. Capacity of Spent Fuel Pools for Power Reactors Under Construction 

Operating Reactors 

Reactor 

Type 

Core Size 

(assemblies) 

Commercial 

Operation Start Date 

Pool 

Capacity 

(assemblies) 

Pool 

Capacity(a)

(cores) 

Estimated Pool 

Capacity(b)

(MTU) 

Vogtle Electric Generating Plant, Unit 3 PWR  future 889  Vogtle Electric Generating Plant, Unit 4 PWR  future 889  

Virgil C. Summer Nuclear Station, Unit 2 PWR  future 889  

Virgil C. Summer Nuclear Station, Unit 3 PWR  future 889  

Watts Bar Nuclear Plant, Unit 2(c) PWR 193 future Would share pool with Unit 1 (see Table G-1) 

Sources: Combined licenses for Vogtle Electric Generating Plant and Virgil C. Summer Nuclear Station are available through the NRC’s website at http://www.nrc.gov/reactors/new-reactors/col/vogtle.html and http://www.nrc.gov/reactors/new-reactors/col/summer.html, respectively (NRC 2014b). For Watts Bar, information can be found at http://www.nrc.gov/info-finder/reactor/wb/watts-bar.html (NRC 2014c).(a) Represents capacity with full core offload maintained; pool capacity (cores) is derived by subtracting one core’s worth of assemblies from pool 

capacity (assemblies) and then dividing that number by core size (assemblies).

(b) Pool capacity (MTU) is GHULYHGE\PXOWLSO\LQJNJRUPHWULFWRQSHUDVVHPEO\DVVXPHGIRU3:5E\WKHQXPEHURIDVVHPEOLHVLQSRRO

capacity (889). 

(c) The NRC staff anticipates a decision on the application for an operating license LQ.
September 2014 G-9 185(*௅

Appendix G 

Table G-3. Capacity of In-Use Spent Fuel Pools for Decommissioning Facilities

Operating Reactors 

Reactor 

Type 

Core 

Size 

(assemblies) 

Commercial 

Operation Start Date 

Pool 

Capacity 

(assemblies) 

Pool 

Capacity(a)

(cores) 

Est. Pool 

Capacity(b)

(MTU) 

Crystal River Nuclear Generating Plant, Unit 3 PWR     Kewaunee Power Station PWR 121   9.0 

Millstone Power Station, Unit 1 BWR   2, 4.1 

San Onofre Nuclear Generating Station, Unit 2 PWR  8/8/1983  6.1 San Onofre Nuclear Generating Station, Unit 3 PWR  4/1/1984  6.1 Zion Nuclear Power Station, Unit 1 PWR 193  3,012 14.6 

Zion Nuclear Power Station, Unit 2 PWR 193  See above (pool shared with Unit 1) 

Sources: http://www.nrc.gov/info-finder/decommissioning/power-reactor (NRC 2014d); Duke 2013 (for Crystal River Nuclear Generating Plant); Dominion 2013 (for Kewaunee Power Station); Dominion 2011 (for Millstone Power Station); SCE 2013 (for San Onofre Nuclear Generating 

Station); and Commonwealth Edison 1993, 1998 (for Zion Nuclear Power Station).

(a) Represents capacity with full core offload maintained; pool capacity (cores) is derived by subtracting one core’s worth of assemblies from pool 

capacity (assemblies) and then dividing that number by core size (assemblies).

(b) 3RROFDSDFLW\078LVGHULYHGE\PXOWLSO\LQJNJRUPHWULFWRQSHUDVVHPEO\IRUD3:5or 186 kg (0.186 metric ton) per assembly for 

a BWR by the number of assemblies in pool capacity. 
185(*௅ G-10 September 2014 

Appendix G Table G-4. ISFSIs Operating Under 3DUW*HQHUDO/LFHQVH

Site 

Initial 

Storage Date 

Storage System Associated 

Transportation 

Package(a)

Approved for 

High-Burnup 

Spent Fuel?(b) Vendor Design 

Arkansas Nuclear One  BNG Fuel Solutions VSC-24 None No Arkansas Nuclear One  Holtec International HI-STORM -9261 No 

Big Rock Point Nuclear Power Plant 11/18/2002 BNG Fuel Solutions W- - No Braidwood Station 11/23/2011 Holtec International HI-STORM 100 -9261 No 

Browns Ferry Nuclear Plant  Holtec International HI-STORM 100S -9261 No 

Brunswick Steam Electric Plant(c) 10/28/2010 Transnuclear, Inc. NUHOMS -9302 Yes (T, S) 

Byron Station 9/9/2010 Holtec International HI-STORM 100S -9261 No 

Catawba Nuclear Station  NAC International, 

Inc. 

NAC-UMS - Yes (T, S) 

Catawba Nuclear Station  NAC International, 

Inc. 

MAGNASTOR Under Review Yes (S) 

Columbia Generating Station 9/2/2002 Holtec International HI-STORM 100S -9261 No 

Comanche Peak Steam Electric Station

2/28/2012 Holtec International HI-STORM 100 -9261 No 

Donald C. Cook Nuclear Power Plant

8/1/2012 Holtec International HI-STORM 100 -9261 No 

Cooper Nuclear Station 10/21/2010 Transnuclear, Inc. NUHOMS -9302 Yes (T) 

Davis-Besse Nuclear Power Station 1/1/1996 Transnuclear, Inc. NUHOMS None No 

Dresden Nuclear Power Station  Holtec International HI-STAR 100 -9261 No 

Dresden Nuclear Power Station  Holtec International HI-STORM 100 -9261 No 

Duane Arnold Energy Center 9/1/2003 Transnuclear, Inc. NUHOMS -9302 Yes (T) 

Fort Calhoun Station  Transnuclear, Inc. NUHOMS -9302 Yes (T) 

Grand Gulf Nuclear Station 11/18/2006 Holtec International HI-STORM 100S -9261 No 

Haddam Neck  NAC International, 

Inc. 

NAC-MPC - No 

Edwin I. Hatch Nuclear Plant  Holtec International HI-STAR 100 -9261 No 
September 2014 G-11 185(*௅

Appendix G 

Table G-4. ISFSIs Operating Under 3DUW*HQHUDO/LFHQVH (cont’d)

Site 

Initial 

Storage Date 

Storage System Associated 

Transportation 

Package(a)

Approved for 

High-Burnup 

Spent Fuel?(b) Vendor Design 

Edwin I. Hatch Nuclear Plant  Holtec International HI-STORM 100/S -9261 No Edwin I. Hatch Nuclear Plant  Transnuclear, Inc. NUHOMS -9302 Yes (T) H.B. Robinson Steam Electric Plant  Transnuclear, Inc. NUHOMS -9302 Yes (T, S) 

Hope Creek Generating Station 11/10/2006 Holtec International HI-STORM 100 -9261 No Indian Point Nuclear Generating Plant

1/11/2008 Holtec International HI-STORM 100 -9261 No 

James A. FitzPatrick Nuclear Power Plant

 Holtec International HI-STORM 100/S -9261 No 

Joseph M. Farley Nuclear Plant  Holtec International. HI-STORM 100S -9261 No Kewaunee Power Station 8/22/2009 Transnuclear, Inc. NUHOMS -9302 Yes (T) 

La Crosse Boiling Water Reactor(c)  NAC International, 

Inc. 

NAC-MPC - No 

LaSalle County Station 11/1/2010 Holtec International HI-STORM 100S -9261 No 

Limerick Generating Station 8/1/2008 Transnuclear, Inc. NUHOMS -9302 Yes (T, S) 

Maine Yankee 8/24/2002 NAC International, 

Inc. 

NAC-UMS - Yes (T, S) 

McGuire Nuclear Station 8/1/2013 NAC International, 

Inc. 

MAGNASTOR pending 

-

Yes (T, S) 

McGuire Nuclear Station 2/1/2001 Transnuclear, Inc. TN Metal Casks None No McGuire Nuclear Station  NAC International, 

Inc. 

NAC-UMS - Yes (T, S) 

Millstone Power Station  Transnuclear, Inc. NUHOMS -9302 Yes (T) 

Monticello Nuclear Generating Plant

 Transnuclear, Inc. NUHOMS -9302 Yes (T, S) 

Nine Mile Point Nuclear Station 9/8/2012 Transnuclear, Inc. NUHOMS -9302 Yes (T) 

North Anna Power Station 3/10/2008 Transnuclear, Inc. TN Metal Casks None No 

North Anna Power Station 3/10/2008 Transnuclear, Inc. NUHOMS-HD -9302 Yes (T, S) Oconee Nuclear Station  Transnuclear, Inc. NUHOMS None Yes (S) Oyster Creek Nuclear Generating 12/20/2001 Transnuclear, Inc. NUHOMS -9302 Yes (T, S) 
185(*௅ G-12 September 2014 

Appendix G Table G-4. ISFSIs Operating Under 3DUW*HQHUDO/LFHQVH (cont’d)

Site 

Initial 

Storage Date 

Storage System Associated 

Transportation 

Package(a)

Approved for 

High-Burnup 

Spent Fuel?(b) Vendor Design 

StationPalisades Nuclear Plant  EnergySolutions VSC-24 None No 

Palisades Nuclear Plant  Transnuclear, Inc. NUHOMS -9302 Yes (T, S) 

Palo Verde Nuclear Generating Station

 NAC International, 

Inc. 

NAC-UMS - Yes (T, S) 

Peach Bottom Atomic Power Station

6/12/2000 Transnuclear, Inc. TN Metal Casks -9293 No 

Perry Nuclear Power Plant (c) 9/29/2012 Holtec International HI-STORM 100 -9261 No 

Point Beach Nuclear Plant  EnergySolutions VSC-24 None No 

Point Beach Nuclear Plant  Transnuclear, Inc. NUHOMS -9302 Yes (T) 

Quad Cities Nuclear Power Station  Holtec International HI-STORM 100S -9261 No R.E. Ginna Nuclear Power Plant(c) 8/23/2010 Transnuclear, Inc. NUHOMS -9302 Yes (T) 

River Bend Station  Holtec International HI-STORM 100S -9261 No St. Lucie Plant 3/21/2008 Transnuclear, Inc. NUHOMS-HD -9302 Yes (T, S) Salem Nuclear Generating Station 11/10/2006 Holtec International HI-STORM 100 -9261 No 

San Onofre Nuclear Generating Station

10/3/2003 Transnuclear, Inc. NUHOMS - No 

-9302 Yes (T) 

Seabrook Station  Transnuclear, Inc. NUHOMS-HD -9302 Yes (T,S) 

Sequoyah Nuclear Plant  Holtec International HI-STORM 100/S -9261 No Surry Nuclear Power Station  Transnuclear, Inc. NUHOMS-HD -9302 Yes (T, S) Susquehanna Steam Electric Station

10/18/1999 Transnuclear, Inc. NUHOMS -9302 Yes (T, S) 

Turkey Point Nuclear Generating Station

 Transnuclear, Inc. NUHOMS-HD -9302 Yes (T, S) 

Vermont Yankee Nuclear Power Plant

 Holtec International HI-STORM 100 -9261 No 

Waterford Steam Electric Station 11/8/2011 Holtec International HI-STORM 100 -9261 No 
September 2014 G-13 185(*௅

Appendix G 

Table G-4. ISFSIs Operating Under 3DUW*HQHUDO/LFHQVH (cont’d)

Site 

Initial 

Storage Date 

Storage System Associated 

Transportation 

Package(a)

Approved for 

High-Burnup 

Spent Fuel?(b) Vendor Design 

Yankee Rowe 6/26/2002 NAC International, 

Inc. 

NAC-MPC - No 

Vogtle Electric Generating Plant 10/26/2013 Holtec International HI-STORM 100S -9261 No Zion Nuclear Power Station 1/9/2014 NAC International, 

Inc. 

MAGNASTOR pending 

-

Yes (T, S) 

Sources: NRC 2013a; UxC 2013; NRC 2013b; Greene et al. 2013; storage and transportation certificates of compliance available in the NRC’s Agencywide Documents Access and Management System (ADAMS).(a) A docket number in this column indicates that a storage system is in use at the site that has an associated transportation package 

certificate. Other systems may or may not be in use at the site that do not have associated transportation package certificates. Certified WUDQVSRUWDWLRQSDFNDJHVFRXOGUHTXLUHDGGLWLRQDO15&UHYLHZXQGHUWKH15&¶VWUDQVSRUWDWLRQUHTXLUHPHQWVLQ&)53DUWEHIore the packages may be used for transportation. Whether a transportation package requires additional NRC review is dependent on whether 

modifications to the design or the construction of the storage system have occurred since the NRC issued the initial certificates of compliance for storage under 10 CFR 3DUWDQGIRUWUDQVSRUWDWLRQXQGHU10 CFR 3DUW$GGLWLRQDONRC review of transportation 

packages or contents could also be required if so specified in the transportation certificate of compliance. 

(b) An “S” in this column indicates that the storage system is approved for use with high-burnup fuel and a “T” indicates that the transportation 

package is approved for use with high-burnup fuel. A “No” in this column indicates that neither the storage system nor the transportation package has been approved for use with high-burnup fuel. This column does not indicate whether high-burnup fuel is actually in storage at the site. 

(c) Initial storage dates for Brunswick Steam Electric Plant (Progress Energy 2010), R.E. Ginna Nuclear Power Plant (CENG 2010), La Crosse 

Boiling Water Reactor (Dairyland 2012), and Perry Nuclear Power Plant (FirstEnergy 2012) were obtained from licensee letters.
185(*௅ G-14 September 2014 

Appendix G Table G-5. ISFSIs Operating UQGHU3DUW6SHFLILF/LFHQVHV

Site 

License 

No. Start Date 

Expiration Storage System 

Associated 

Transportation 

Package(a)

Approved 

for HighBurnup 

Spent 

Fuel?(b)

Initial 

License 

Renewed 

License Vendor Design 

Calvert Cliffs Nuclear Power Plant

SNM–  2012 NA Transnuclear, Inc. NUHOMS None No 

Diablo Canyon Nuclear Power Plant

SNM– 3/22/2004 2024 NA Holtec International HI-STORM 

100 

-9261 No 

Fort St. Vrain SNM– 11/4/1991 2011 2031 FW Energy 

Applications, Inc. or the U.S. Department of Energy 

Foster Wheeler 

None Yes (S) 

H.B. Robinson Steam Electric Plant, Unit 2

SNM– 8/13/1986 2006 2046 Transnuclear, Inc. NUHOMS -9302 Yes (T, S) 

Humboldt Bay SNM–   NA Holtec International HI-STAR HB -9261 No 

Idaho National Laboratory TMI-2 Fuel Debris

SNM– 3/19/1999 2019 NA Transnuclear, Inc. NUHOMS None No 

Idaho Spent Fuel Facility(c)

SNM– 11/30/2004 2024 NA Licensee: DOE 

(formerly Foster Wheeler Environmental Corporation) 

Concrete Vault 

None No 

Morris Operation (GE Hitachi)

SNM–  2002 2022 NA Wet storage NA No 

North Anna Power Station Units 1 and 2

SNM– 6/30/1998 2018 NA Transnuclear, Inc. NUHOMSHD -9302 Yes (T, S) 

Oconee Nuclear Station, Units 1, 2, and 3

SNM- 1/29/1990 2010  Transnuclear, Inc. NUHOMS None Yes (S) 
September 2014 G- 185(*௅

Appendix G 

Table G-5. ISFSIs Operating UQGHU3DUW6SHFLILF/LFHQVHV(cont’d) 

Site 

License 

No. Start Date 

Expiration Storage System 

Associated 

Transportation 

Package(a)

Approved for 

High-Burnup 

Spent 

Fuel?(b)

Initial 

License 

Renewed 

License Vendor Design 

Prairie Island Nuclear Generating Plant

SNM– 10/19/1993 2013 NA Transnuclear, Inc. TN-40 -9313 Yes (S) 

Private Fuel Storage Facility(c)

SNM– 2/21/2006 2026 NA Holtec 

International 

HI-STORM 100 

-9261 No 

Rancho Seco SNM– 6/30/2000 2020 NA Transnuclear, Inc. NUHOMS -9302 Yes (T) 

Surry Nuclear Power Station

SNM–  2006 2046 General Nuclear Castor None No 

Surry Nuclear Power Station

SNM–  2006 2046 NAC International, 

Inc. 

NAC-I28 None No 

Surry Nuclear Power Station

SNM–  2006 2046 Transnuclear, Inc. NUHOMSHD -9302 Yes (T, S) 

Surry Nuclear Power Station

SNM–  2006 2046 Westinghouse, Inc. MC-10 None No 

Trojan SNM– 3/31/1999 2019 NA Holtec 

International 

HI-STORM 100 

-9261 No 

Sources: NRC 2013a; UxC 2013; NRC 2013b; Greene et al. 2013; storage and transportation certificates of compliance available in ADAMS; some information for Idaho National Laboratory TMI-2, the Private Fuel Storage facility, and Morris Operation obtained from additional sources: see DOE 

IRU,GDKR70,-2 facility), NRC 2006 (for Private Fuel Storage), and NRC 2004 (for Morris).

(a) A docket number in this column indicates that a storage system is in use at the site that has an associated transportation package certificate. 

Other systems may or may not be in use at the site that do not have associated transportation package certificates. Certified transportation SDFNDJHVFRXOGUHTXLUHDGGLWLRQDO15&UHYLHZXQGHUWKH15&¶VWUDQVSRUWDWLRQUHTXLUHPHQWVLQ&)53DUWEHIRUHWKHSDFNDJHs may be 

used for transportation. Whether a transportation package requires additional NRC review is dependent on whether modifications to the design or the construction of the storage system have occurred since the NRC issued the initial certificates of compliance for storaJHXQGHU3DUW

DQGIRUWUDQVSRUWDWLRQXQGHU3DUW$GGLWLRQDO15&UHYLHZRIWUDQVportation packages or contents could also be required if so specified in the 

transportation certificate of compliance. 

(b) An “S” in this column indicates that the storage system is approved for use with high-burnup fuel and a “T” indicates that the transportation 

package is approved for use with high-burnup fuel. A “No” indicates that neither the storage system nor the transportation package has been approved for use with high-burnup fuel. This column does not indicate whether high-burnup fuel is actually in storage at the site. 

(c) Private Fuel Storage Facility and Idaho Spent Fuel Facility were licensed but have not been constructed. 

HTGR = high-temperature gas-cooled reactor; NA = Not applicable.
Appendix G 

185(*௅ G-16 September 2014 

References 

&)53DUWCode of Federal Regulations, Title 10, Energy3DUW3'RPHVWLF/LFHQVLQJRI

Production and Utilization Facilities.” Washington, D.C. 

&)53DUW&RGHRI)HGHUDO5HJXODWLRQV7LWOH(QHUJ\3DUW3/LFHQVHV

Certifications, and Approvals for Nuclear Power Plants.” Washington, D.C. 

&)53DUWCode of Federal Regulations, Title 10, Energy3DUW3/LFHQVLQJ

Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive 

Waste, and Reactor-Related Greater than Class C Waste.” Washington, D.C. 

CENG. 2010. Letter from T.L. Harding to NRC, dated September 16, 2010, regarding “General 

License 30-day Cask Registration Notification.” Ontario, New York. Accession 

No. 0/

Commonwealth Edison. 1993. Zion Station Updated Final Safety Analysis Report. Volume 3, 

&KLFDJR,OOLQRLV$FFHVVLRQ1R0/.

Commonwealth Edison. 1998. Letter from R.S. Starkey to NRC, dated November 10, 1998, 

regarding “Submittal of Defueled Safety Analysis Report.” Chicago, Illinois. Accession 

No. ML1$

Dairyland (Dairyland Power Cooperative). 2012. Letter from J.B. McRill to NRC, dated July 12, 

2012, regarding “Registration of Spent Fuel Dry Storage Cask in Use.” LAC–*HQRD

Wisconsin. Accession No. ML12199A069. 

DOE (U.S. Department oI(QHUJ\/HWWHUIURP%-'DYLVWR15&, GDWHG0DUFK

UHJDUGLQJ36XEPLWWDORI7KUHH0LOH,VODQG8QLW,QGHSHQGHQW6SHQW)XHO6WRUDJH

Installation (TMI–,6)6,8SGDWH5HSRUWV'RFNHW–20).” EM–FMDP––008, Idaho Falls, 

Idaho. AccessiRQ1R0/

Dominion (Dominion Energy Kewaunee, Inc.). 2013. Letter from D.G. Stoddard to NRC, dated 

May 14, 2013, regarding “Dominion Energy Kewaunee, Inc., Kewaunee Power Station 

Certification of Permanent Removal of Fuel from Reactor Vessel.” Serial No. 13–293, Glen 

Allen, Virginia. Accession No. ML13$. 

Dominion (Dominion Nuclear Connecticut, Inc.). 2011. Millstone Power Station Unit 1 Defueled 

Safety Analysis Report. Revision 8.0, Waterford, Connecticut. Accession No. ML11231A618. 
Appendix G 

September 2014 G- 185(*௅

Duke (Duke Energy). 2013. Letter from J.A. Franke to NRC, dated February 20, 2013, 

regarding “Crystal River Unit 3—Certification of Permanent Cessation of Power Operations and 

that Fuel Has Been Permanently Removed from the Reactor.” 3F0213–&U\VWDORiver, 

Florida. Accession No. 0/$

Entergy (Entergy Nuclear Operations, Inc.). 2013. Letter from M. Perito to NRC, dated 

September 23, 2013, regarding “Notification of Permanent Cessation of Power Operations.” 

White Plains, New York. Accession 1R0/$

FirstEnergy (First Energy Nuclear Operating Company). 2012. Letter from H.D. Hanson, Jr. to 

NRC, dated October 23, 2012, regarding “Spent Fuel Storage Cask Registration.” L–12–383, 

Perry, Ohio. Accession No. ML12310A088. 

Greene, S.R., J.S. Medford, and S.A. Macy. 2013. Storage and Transport Cask Data for Used 

Commercial Nuclear Fuel—2013 U.S. Edition. ATI-TR-Knoxville, Tennessee. Available 

at http://curie.ornl.gov/content/storage-and-transport-cask-data-used-commercial-nuclear-fuel2013-us-edition-0. 

National Environmental Policy Act of 1969 (NEPA), as amended. 42 USC 4321 et seq. 

NRC (U.S. Nuclear Regulatory Commission). 2004. Letter from J. Monninger to J.E. Ellis, 

dated December 21, 2004, regarding “Issuance of Renewed Materials License No. SNM–

Morris Operation Independent Spent Fuel Storage Operation.” TAC No. L23091, Washington, 

D.C. Accession No. ML043630433. 

NRC (U.S. Nuclear Regulatory Commission). 2006. Letter from W.H. Ruland to J.D. Parkyn, 

dated February 21, 2006, regarding “Issuance of Materials License No. SNM–IRUWKH

Private Fuel Storage Facility (TAC No. L23821).” Washington, D.C. Accession 

No. 0/

NRC (U.S. Nuclear Regulatory Commission). 2013a. 2013-2014 Information Digest. NUREG–

9ROXPH:DVKLQJWRQ'& $FFHVVLRQ1R0/$. 

NRC (U.S. Nuclear Regulatory Commission). 2013b. Directory of Certificates of Compliance 

for Radioactive Materials Packages. NUREG-0383, Volume 2, Revision 28, Washington, D.C. 

Accession No. ML13309A031. 

NRC (U.S. Nuclear Regulatory Commission). 2014a. “Operating Reactors.” Washington, D.C. 

Available at http://www.nrc.gov/reactors/operating/list-power-reactor-units.html. 

NRC (U.S. Nuclear Regulatory Commission). 2014b. “Combined License Applications for New 

Reactors.” Washington, D.C. Available at http://www.nrc.gov/reactors/new-reactors/col.html. 
Appendix G 

185(*௅ G-18 September 2014 

NRC (U.S. Nuclear Regulatory Commission). 2014c. “Watts Bar Unit 2 Reactivation.” 

Washington. D.C. Available at http://www.nrc.gov/info-finder/reactor/wb/watts-bar.html. 

NRC (U.S. Nuclear Regulatory Commission). 2014d. “Power Reactor Sites Undergoing 

Decommissioning.” Washington, D.C. Available at http://www.nrc.gov/infofinder/decommissioning/. 

Progress Energy. 2010. Letter from P.N. Mentel to NRC, dated November 18, 2010, regarding 

“Registration and Use of Casks to Store Spent Fuel and System Thermal Performance 

Assessment.” BSEP 10–6RXWKSRUW1RUWK&DUROLQD$FFHVVLRQ1R0/

SCE (Southern California Edison). 2013. Letter from P. Dietrich to NRC, dated June 12, 2013, 

regarding “Certification of Permanent Cessation of Power Operations, San Onofre Nuclear 

Generating Station Units 2 and 3.” San Clemente, California. Accession No. ML131640201. 

UxC (8[&RQVXOWLQJ&RPSDQ\//&32YHU'U\6WRUDJH6\VWHPV'HSOR\HGLQWKH

US.” StoreFUEL 4–, Roswell, Georgia. 
Appendix H 

–

Estimated Costs of Alternatives 

September 2014 H-1 185(*௅

Appendix H 

Estimated Costs of Alternatives 

This appendix provides the cost information upon which the U.S. Nuclear Regulatory 

Commission (NRC) EDVHVWKHFRVWSRUWLRQRILWVFRVWVDQGEHQHILWVDQDO\VLVLQ&KDSWHURIWKLV

Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel (GEIS). 

Tables H-1 through H-3 provide the estimated costs of site-specific licensing reviews for new 

reactors, reactor license renewals, and independent spent fuel storage installations (ISFSI), 

respectively, which are applicable to the NRC’s potential options in case of no action. Table H-4 

provides estimated costs for generic elements of the proposed action, as well as the NRC’s 

potential options in case of no action, including costs for development of the GEIS, rulemaking, 

and a policy statement, as applicable. Finally, Table H-SURYLGHVWKHWRWDOHVWLPDWHGFRVWVIRU

the proposed action and the NRC’s options in case of no action. 
Appendix H 

185(*௅ H-2 September 2014 Table H-1. Estimated Site-Specific Costs for New Reactor Reviews Cost per Activity(a) NRC Cost Licensee Cost(b) Total Cost(c) First review $1,6

0,000 $1,6

0,000 $3,290,000 

Existing review with supplement $981,000 $981,000 $1,960,000 New review $49,800 $49,800 $99,600 Title 10 of the Code of Federal Regulations

&)53DUWUHYLHZZLWKVXSSOHPHQW

$232,000 $232,000 $4,000 

Year Activity(d) Number Constant 2014 3% Discount 7% Discount 

 First review 1 $3,290,000 $3,200,000 $3,080,000  Existing review with supplement 2 $3,930,000 $3,810,000 $3,0,000 

 10 CFR 3DUWUHYLHZZLWKVXSSOHPHQW 1 $4,000 $1,000 $434,000 

2016 Existing review with supplement 3 $0,000 0,000 $

,140,000 

 Existing review with supplement 2 $3,930,000 $,000 $3,200,000 

2018 New review 2 $199,000 $,000 $1,000 

Sum(c) $17,700,000 $16,800,000 $15,700,000 

(a) $VGHVFULEHGLQ&KDSWHUWKH15&HVWLPDWHVWKDWIRUQHZUHDFWRUUHYLHZVXQGHU&)53DUW the first site-specific review of continued storage in 

a new reactor environmental impact statement (EIS) would require approximately 3.9 full-time equivalents (FTE) for NRC and $1 million in contractor 

support. The NRC estimates that subsequent site-specific reviews that require supplementation of existing EISs require approximately 2.9 FTE for NRC, or $481,000, DQGLQFRQWUDFWVXSSRUWThe NRC estimates that a review of the environmental impacts of continued storage for a new RSHUDWLQJOLFHQVHXQGHU&)53DUWZLOOUHTXLUH)7(, or $232,000. 

(b) The NRC assumes that licensees incur costs that are equal to those incurred by the NRC, so the total cost is double the NRC’s costs. 

(c) Because of rounding, some costs may not appear to sum correctly. (d) The NRC assumes that Levy, South Texas Project (Units 3 and 4), Comanche Peak (Units 3 and 4), Calvert Cliffs, Fermi (Unit 3), North Anna, Lee, 

and the PSE&G Power, LLC/PSE&G Nuclear, LLC Early Site Permit EISs all will require supplementation. One of these reviews will be the first 

review, and the others are labeled as existing reviews with supplements. Watts Bar 2 is the &)53DUWUHYLHZZLWKVXSSOHPHQWDWLRQ7KH15&treats Turkey Point and Bell Bend as new reviews because the NRC is not likely to issue a draft EIS for either project by the end of fiscal year 2014; 

the NRC assumes that the environmental impacts of continued storage will be addressed within a normal review schedule for those projects. 
Appendix H 

September 2014 H-3 185(*௅ Table H-2. Estimated Site-Specific Costs for Reactor License Renewals Cost per Activity(a) NRC Cost Licensee Cost(b) Total Cost(c) First review $4,000 $4,000 $830,000 Existing review with supplement $232,000 $232,000 $4,000 Existing review without supplement $183,000 $183,000 $3,000 New or subsequent renewal review $49,800 $49,800 $99,600 Year Activity(d) Number Constant 2014 3% Discount 7% Discount  First review 1 $830,000 $806,000 $6,000  Existing review with supplement 2 $930,000 $903,000 $869,000 2016 Existing review with supplement 4 $1,860,000 $1,0,000 $1,620,000  Existing review without supplement 3 $1,100,000 $1,000,000 $894,000  Subsequent renewal 1 $99,600 $91,100 $81,300 2018 Renewal review 4 $398,000 $4,000 $304,000 2018 Subsequent renewal 1 $99,600 $88 $

6,000 

2019 Renewal review 3 $299,000 $2,000 $213,000 2019 Subsequent renewal 1 $99,600 $8

,900 $00 

2020 Renewal review 2 $199,000 $16

,000 $133,000 

2020 Subsequent renewal 1 $99,600 $83,400 $66,400 2021 Subsequent renewal 1 $99,600 $81,000 $62,000 2022 Subsequent renewal 1 $99,600 $

8,600 $

8,000 

2023 Subsequent renewal 1 $99,600 $

6,300 $

4,200 

2024 Subsequent renewal 1 $99,600 $

4,100 $,600 

 Subsequent renewal 1 $99,600 000 $4

,300 

2026 Subsequent renewal 1 $99,600 $69,900 $44,200  Subsequent renewal 1 $99,600 $6

,800 $41,300 

2028 Subsequent renewal 1 $99,600 $6

,800 $38,600 

2029 Subsequent renewal 1 $99,600 $63,900 $36,100 2030 Subsequent renewal 1 $99,600 $62,100 $33,

00 

2031 Subsequent renewal 1 $99,600 $60,300 $31,

00 

2032 Subsequent renewal 1 $99,600 $

8,

00 $29,

00 
Appendix H 

185(*௅ H-4 September 2014 Table H-2. Estimated Site-Specific Costs for Reactor License Renewals (cont’d) Year Activity(d) Number Constant 2014 3% Discount 7% Discount 2033 Subsequent renewal 1 $99,600 $

6,800 $2

,00 

2034 Subsequent renewal 1 $99,600 100 00 

 Subsequent renewal 1 $99,600 $

3,

00 $24,100 

2036 Subsequent renewal 1 $99,600 000 $22,

00 

 Initial or subsequent renewal 1 $99,600 $

0,

00 $21,000 

2038 Initial or subsequent renewal 1 $99,600 $49,000 $19,600 2039 Initial or subsequent renewal 1 $99,600 $4

,600 $18,400 

2040 Initial or subsequent renewal 1 $99,600 $46,200 $1

,200 

2041 Initial or subsequent renewal 1 $99,600 $44,800 $16,000 2042 Initial or subsequent renewal 1 $99,600 $43,

00 $1

,000 

2043 Initial or subsequent renewal 1 $99,600 $42,300 $14,000 2044 Initial or subsequent renewal 1 $99,600 $41,000 $13,100 Sum(c) $8,400,000 $7,000,000 $5,870,000 

(a) $VGHVFULEHGLQ&KDSWHUWKH15&DVVXPHVWKDWWKHILUVWUHYLHZZRXOGUHTXLUHDQHVWLPDWHG)7(RU4,000. The NRC further assumes 

that some reviews would require supplementation of existing EISs, and these reviews would require approximately 1.4 FTE, or $232,000. 

Reviews that do not require supplementation would require approximately 1.1 FTE, or $183,000. Reviews of future applications (those that 

have not yet been submitted) would require approximately 0.3 FTE, or $49,800. 

(b) The NRC assumes that licensees incur costs that are equal to those incurred by the NRC, so the total cost is double the NRC’s costs. 

(c) Due to rounding, some costs may not appear to sum correctly. (d) The NRC assumes that South Texas Project (Units 1 and 2), Grand Gulf, Callaway, Limerick, Davis-Besse, Seabrook, and Indian Point would 

require supplementation given current project schedules. One of these reviews would be the first review. The NRC assumes that Sequoyah, Byron, and Braidwood will be existing reviews that do not require supplements by the end of fiscal year 2014. Diablo Canyon, Waterford, Fermi (Unit 2), Riverbend, La Salle, Perry, Clinton, one facility in the STARS (Strategic Teaming and Resource Sharing) Alliance, and Watts Bar 1 are 

labeled as new license renewal reviews because the NRC will be able to address the environmental impacts of continued storage within a normal review schedule for those projects. The NRC has not identified specific plants that will seek subsequent license renewals, but estimates 

that half of the existing reactor fleet will do so. 
Appendix H 

September 2014 H- 185(*௅ Table H-3. Estimated Site-Specific Costs for ISFSI Licensing Cost per Activity(a) NRC Cost Licensee Cost(b) Total Cost(c) First renewal review $83,000 $83,000 $166,000 Renewal review $41,

00 $41,

00 $83,000 

Year Activity(d) Number Constant 2014 3% Discount 7% Discount 

 First renewal review 2 $332,000 $322,000 $310,000 2018 Renewal review 1 $83,000 $

3,

00 $63,300 

2019 Renewal review 2 $166,000 $143,000 $118,000 2020 Renewal review 1 $83,000 $69,

00 $,300 

2022 Renewal review 1 $83,000 $6

,00 $48,300 

2024 Renewal review 1 $83,000 $61,800 $42,200  Renewal review 1 $83,000 $60,000 $39,400 2026 Renewal review 2 $166,000 $116,000 $

3,

00 

2032 Renewal review 1 $83,000 $48,800 $24,600 Sum(c) $1,160,000 $961,000 $775,000 

(a) $VGLVFXVVHGLQ&KDSWHUWKH15&HVWLPDWHVWKDWDSSUR[LPDWHO\)7(RU3,000, would be necessary to support site-specific 

consideration of continued storage in the first two ISFSI Environmental Assessments, both of which are currently under review. The NRC HVWLPDWHVWKDWODWHU,6)6,(QYLURQPHQWDO$VVHVVPHQWVZLOOUHTXLUH)7(RU41,00. 

(b) The NRC assumes that licensees incur costs that are equal to those incurred by the NRC, so the total cost is double the NRC’s costs. 

(c) Due to rounding, some costs may not appear to sum correctly. (d) Activity dates are based on license expiration dates. Currently, two site-specific ISFSI license renewal applications, Calvert Cliffs and Prairie 

Island, are docketed at the NRC. Therefore, the NRC assumes that these reviews will be the first reviews. Other site-specific ISFSI licenses that will expire during the 30-year analysis period are North Anna (2018), Three Mile Island Unit 2 (2019), Trojan (2019), Rancho Seco 

(2020), GE Morris (2022), Diablo Canyon (2024), Idaho Spent Fuel Facility (+XPEROGW%D\2026), Private Fuel Storage (2026), and Fort St. Vrain (2032). Other facilities with site-specific ISFSIs do not require renewal by 2044. See Appendix G for more information on ISFSIs. 
Appendix H 

185(*௅ H-6 September 2014 

Table H-4. Estimated Costs of Generic Elements(a)

GEIS Development (applies to proposed action and all options in case of no action 

except site-specific review) (b)

 FTE(c) Contractor Total

Annual Cost 20.0 $3,000,000 $6,320,000 

Year(c) Constant 2014 

2013(e) $6,420,000 

2014 $6,320,000 

Sum(f) $12,700,000 

Rulemaking (applies to the Proposed Action) (b)

 FTE(c) Contractor Total

Annual Cost 3.0 $0 $498,000 

Year(c) Constant 2014 

2013(e) $06,000 

2014 $498,000 

 Sum(f) $1,000,000 

Policy Statement (Applies to the Policy Statement option) (d)

 FTE(c) Contractor Total

Annual Cost  $0 $249,000 

Year(c) Constant 2014 3% Discount 7% Discount

201 $249,000 $242,000 $233,000 

2016 $249,000 $2,000 $2,000 

Sum(f) $498,000 $476,000 $450,000 

(a) Generic elements are those portions of the alternatives that are not directly attributable to any 

site-specific review. 

(b) The NRC assumes that the effort necessary to develop the GEIS and rule occurs during fiscal years 

2013 and 2014. While these costs are technically past, or “sunk,” costs, the NRC includes them here 

to provide a complete and transparent analysis of the costs of the proposed action and NRC’s 

potential options in the case of no action. Finally, because costs of the GEIS and rulemaking are not 

future costs, the NRC does not discount them in this analysis. 

(c) One FTE costs $166,000 based on data from fiscal year 2013 (the most recent available data). 

(d) The NRC assumes that the effort necessary to develop the policy statement occurs during fiscal 

\HDUVDQGEHFDXVHXQOLNHWKH*(,6DQGUule, the NRC is not currently developing a 

policy statement. 

(e) The NRC uses the Bureau of Labor Statistics’ (BLS) Consumer Price Index (CPI) to adjust 2013 

costs to 2014 dollars (BLS 2014). 

(f) Due to rounding, some costs may not appear to sum correctly. 
Appendix H 

September 2014 H- 185(*௅

Table H-5. Total Estimated Costs of the Proposed Action and NRC’s Options in Case of 

No Action 

Proposed Action

Constant 2014 

GEIS $12,00,000 

Rulemaking $1,000,000 

Total Cost(a) $13,700,000 

Site-Specific Review Option

Constant 2014 3% Discount 7% Discount 

New reactor reviews $1,00,000 $16,800,000 $1,00,000 

Reactor license renewal $8,400,000 000,000 0,000 

ISFSI licensing $1,210,000 $961,000 

Total Cost(a) $27,300,000 $24,700,000 $22,300,000 

GEIS-Only Option

With No Cost Savings(b) Constant 2014 3% Discount 7% Discount 

New reactor reviews $1,00,000 $16,800,000 $1,600,000 

Reactor license renewal $8,400,000 000,000 0,000 

ISFSI licensing $1,160,000 $961,000 $,000 

GEIS development $12,00,000 $12,00,000 $12,00,000 

Total Cost(a) $40,000,000 $37,500,000 $35,100,000 

With 50% Cost Savings(b) Constant 2014 3% Discount 7% Discount 

New reactor reviews $8,0,000 $8,390,000 $,840,000 

Reactor license renewal $4,200,000 $3,00,000 $2,930,000 

ISFSI licensing $,000 $481,000 $388,000 

GEIS development $12,00,000 $12,00,000 $12,00,000 

Total Cost(a) $26,400,000 $25,100,000 $23,900,000 

Policy Statement Option

With No Cost Savings(b) Constant 2014 3% Discount 7% Discount 

New reactor reviews $1,00,000 $16,800,000 $1,00,000 

Reactor license renewal $8,400,000 000,000 0,000 

ISFSI licensing $1,160,000 $961,000 $,000 

GEIS development $12,00,000 $12,00,000 $12,00,000 

Policy statement $498,000 $,000 $,000 

Total Cost(a) $40,500,000 $38,000,000 $35,500,000 
Appendix H 

185(*௅ H-8 September 2014 

Table H-5. Total Estimated Costs of the Proposed Action and NRC’s Options in Case of No 

Action (cont’d)

Policy Statement Option, cont’d 

50% Cost Savings(b) Constant 2014 3% Discount 7% Discount 

New reactor reviews $8,0,000 $8,390,000 $,840,000 

Reactor license renewal $4,200,000 $3,00,000 $2,930,000 

ISFSI licensing $,000 $481,000 $388,000 

GEIS development $12,00,000 $12,00,000 $12,00,000 

Policy statement $498,000 $,000 $4,000 

Total Cost(a) $26,900,000 $25,600,000 $24,300,000 

(a) Due to rounding, some costs may not appear to sum correctly. Costs for the proposed action are not 

discounted because the proposed action includes no future costs. 

(b) 7KH15&HVWLPDWHVWKDWVWDIIDQGDSSOLFDQWVPD\UHGXFHWKHLUHIIRUWVE\DVPXFKDVFRPSDUHG

to the site-specific review option in both the GEIS-only and policy statement options. While effort will 

vary in each review, the reliance on the GEIS (and policy statement) to address generic issues related 

to continued storage will entirely resolve concerns for some issues, while other issues may require 

additional effort in resolving comments, addressing site-specific litigation, or establishing that the 

GEIS findings are applicable to a specific licensing proceeding. 

References 

&)53DUWCode of Federal Regulations, Title 10, Energy3DUW3'RPHVWLF/LFHQVLQJRI

Production and Utilization Facilities.” Washington, D.C. 

&)53DUWCode of Federal Regulations, Title 10, Energy3DUW3/LFHQVHV

Certifications, and Approvals for Nuclear Power Plants.” Washington, D.C. 

&)53DUWCode of Federal Regulations, Title 10, Energy, PaUW3/LFHQVLQJ

Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive 

Waste, and Reactor-Related Greater than Class C Waste.” Washington, D.C. 

BLS (U.S. Bureau of Labor Statistics). 2014. CPI Detailed Report—Data for March 2014. 

Washington, D.C. Available at http://www.bls.gov/cpi/cpid1403.pdf. 
Appendix I 

–

High-Burnup Fuel 

September 2014 I-1 185(*௅

Appendix I 

High-Burnup Fuel 

During the public comment period on the draft Generic Environmental Impact Statement (GEIS), 

the U.S. Nuclear Regulatory Commission (NRC) held 13 public meetings in various locations 

throughout the United States. During those meetings, numerous questions, concerns, and 

comments were raised about the use of high-burnup fuel at nuclear power plants. As a result of 

the public’s interest in this topic, the NRC developed this appendix to provide background 

information about high-burnup fuel. The material is presented in a question and answer format. 

Q. What does “burnup” mean? 

A. Burnup is a measure of the fraction of fissionable atoms that can undergo the fission 

process. It can be expressed as a measure of the time a fuel assembly stays in the reactor 

core and how much energy is extracted from that nuclear fuel assembly. Burnup is typically 

expressed in units of gigawatt-days per metric ton of the initial amount of the uranium in the 

fuel (GWd/MTU). 

Q. What is high-burnup fuel and how does it differ from low-burnup fuel? 

A. High-burnup fuel is typically defined as fuel with a burnup (a measure of the time a fuel 

DVVHPEO\VWD\VLQWKHUHDFWRUFRUHJUHDWHUWKDQ GWd/MTU. Low-burnup fuel is defined 

as any fuel with a lower exposure than this value. Average fuel burnups have increased 

IURPDURXQG GWd/MTU WZRGHFDGHVDJRWRRYHU GWd/MTU today. High-burnup fuel 

is thermally hotter and more radioactive than low-burnup fuel for a given cooling time. The 

difference in decay heat (a function of the fuel transferring heat to decrease its temperature 

over time) and radioactive source term depends on the difference in the fuel burnup (i.e., 

how long the fuel was being used in the reactor), the initial enrichment of the fuel, and the 

irradiation environment that the fuel was exposed to in the reactor. High-burnup fuel is 

typically cooled longer than low-burnup fuel before it can be placed into a dry storage 

system. How much longer depends on the difference in burnup, the specific dry storage 

system design, and the decay heat loading pattern of the fuel being used.

Q. How is mixed oxide (MOX) fuel different from uranium oxide (UOX) fuel? 

A. As explained in Chapter 2 of the GEIS, mixed oxide (MOX) fuel is a type of nuclear reactor 

fuel that contains plutonium oxide mixed with either natural or depleted uranium oxide in the 

form of ceramic pellets. MOX fuel is not currently being produced in the United States; 
Appendix I 

185(*௅ I-2 September 2014 

however, an application is pending before the NRC for a MOX fuel fabrication facility. The 

mechanical design of MOX fuel is very similar to UOX fuel used in existing light water 

reactors. The planned MOX fuel also is intended for use in existing light water reactors in 

the United States. As with high-burnup UOX fuel, MOX fuel has higher thermal output and 

different radionuclide composition that needs to be considered in storage system design, 

operations, and maintenance. 

Q. How is high-burnup fuel licensed for reactor operations by the NRC? 

A. In reactor licensing and operations, the question of fuel burnup is addressed in reactor fuel 

system design safety reviews. The NRC uses the guidance in NUREG-0800 (Section 4.2, 

“Fuel System Design”) 15&when conducting these safety reviews. The reactor fuel 

system consists of numerous components including arrays (i.e., assemblies or bundles) of 

fuel rods, fuel pellets, insulator pellets, and tubular cladding. During reactor fuel system 

design safety reviews, the NRC evaluates the nuclear, thermal, mechanical, and materials 

design of the fuel system. These reviews provide assurance that (1) the fuel system is not 

damaged as a result of normal operations and anticipated operational occurrences, (2) fuel 

system damage is never so severe as to prevent control rod insertion when it is required, (3) 

the number of fuel rod failures is not underestimated for postulated accidents, and (4) 

coolability is always maintained. Fuel burnup is one of several fuel design operating limits 

established to ensure fuel reliability and acceptable performance during normal operations, 

anticipated operational occurrences, and postulated accidents. Fuel system design safety 

reviews consider the effects of burnup levels on the nuclear, thermal, mechanical, and 

materials design of the fuel system. For example, in a fuel system safety review, fuel rod 

failure criteria consider the high-burnup effects on overheating of fuel pellets. As a result, 

NRC acceptance of a reactor fuel design includes the fuel design’s burnup operating 

limits. In addition, the NRC evaluates the environmental impacts of the agency’s actions in 

accordance with the National Environmental Policy Act of 1969. 

Q. What happens to the high-burnup fuel after its use in a reactor? 

A. When any fuel is no longer suitable for use in the reactor, it is placed in a spent fuel pool 

where it is stored at least until it is cool enough that it can be transferred to dry storage. 

Data collected to date suggest very little or no degradation of the spent fuel in the pools as 

long as the water chemistry is maintained. The dry cask storage system receives a 

Certificate of Compliance from the NRC before it can be used for storing spent fuel. The 

behavior of the high-burnup fuel and the consequences of its potential degradation are 

thoroughly evaluated against standards for criticality, thermal, containment, and shielding 

safety along with the ability to safely retrieve it from storage before the NRC issues the 

Certificate of Compliance. 
Appendix I 

September 2014 I-3 185(*௅

Q. Can high-burnup fuel be stored in dry cask storage systems? 

A. As indicated above, when spent fuel is removed from a reactor, it is first stored in a spent 

fuel pool where it cools. After the spent fuel has cooled sufficiently so that its decay heat 

and radiation will not significantly damage the fuel itself or the storage components, the fuel 

can be transferred to a dry cask storage system. High-burnup fuel must be cooled longer 

than low-burnup fuel before it can be placed into a dry cask storage system. How much 

longer depends on the difference in burnup, the specific dry cask storage system design, 

and the decay heat loading pattern of the fuel being used. For H[DPSOHIRUDweightpercent enriched (in uranium-IXHODVVHPEO\LQRQHSDUWLFXODUVWRUDJHV\VWHPWKH

UHTXLUHGFRROLQJWLPHJRHVIURPWRWR\HDUVIRUIXHOEXUQXSs RIDQG

 GWd/MTU, respectively. There are three types of dry cask storage systems for spent 

nuclear fuel (spent fuel): 

x Storage-only systems that have not been approved for transportation. 

x Dual-purpose systems that are designed for both storage and transport. Most of 

these systems have been approved for storage of high-burnup fuel only, but some 

also have been approved for transport of high-burnup fuel. 

x Canister systems in which the canister may or may not be put into a new overpack 

for transport. 

NRC regulations allow for the approval of spent fuel storage in dry casks for a period up to 

40 years. While there is no indication that high-burnup fuel cannot be stored for the full 

40 years, the NRC has only approved the storage of high-burnup fuel for 20 years. The 

20-year period allows for earlier consideration of the increasing operational experience with 

and investigations of high-burnup fuel. A list of NRC-certified storage casks and 

transportation casks for high-burnup spent fuel is provided in Appendix G. 

Q. How does dry cask storage of high-burnup fuel differ from low-burnup fuel? 

A. Dry cask storage systems need to comply with NRC’s regulations at &)53DUW Based 

on research on the behavior of high-burnup spent fuel, the NRC has issued guidance for the 

conditions under which the fuel can be stored without expecting it to degrade in an unsafe 

manner (e.g., cladding temperature is limited to 400°C qF) for normal conditions of 

storage and short-term loading operations, the atmosphere is dry and inert). Cask design 

and loading configuration are used to meet requirements for the cask thermal load. 

Although high-burnup fuel most recently discharged from the reactor presents the largest 

thermal load, casks are typically loaded with spent fuel of different discharge times and 

potentially different burnup (i.e., loaded into different “zones” within the casks) so that the 

hottest assemblies are not all placed in a single cask. For example, the pressurized water 

reactor fuel qualification tables for NUHOMS-24PHB dry storage casks specify minimum 
Appendix I 

185(*௅ I-4 September 2014 

FRROLQJWLPHVRI\HDUV]RQH\HDUV]RQH, and 6 years (zone 3) for spent fuel 

with 4*:G078EXUQXS(based on 4 percent assembly average initial U-HQULFKPHQW

compared to cooling times of 29.2 years (zone 1), 13.2 years (zone 2), DQG\HDUV]RQH

IRUVSHQWIXHOZLWK*:G078EXUQXSfuel (Transnuclear Inc. 2009). Whatever the 

thermal output or radiation flux of the spent fuel placed in the container, the loading must be 

consistent with the cask certificate and comply with the regulations. 

The heat and radiation flux from any spent fuel assembly will vary as a function of initial 

enrichment, burnup, and time since the assembly was removed from the reactor. As a result 

of higher initial enrichment and longer service life in the reactor, high-burnup spent fuel has 

higher radioactivity and thermal output compared to low-burnup spent fuel. 

In 2011, the International Atomic Energy Agency (IAEA) published a report that provides 

information on the thermal output and radiation flux for UOX fuel as a function of burnup and 

decay after discharge from the reactor (IAEA 2011). Table I-1 and Table I-2 provide values 

estimated from curves presented in the IAEA report for the thermal output and the neutron 

flux. Based on Table I-1, high-burnup fuel *:G078DIWHU\HDUVRIGHFD\has 

thermal output similar to 30 GWd/MTU fuel after  years of decay. High-burnup fuel also 

has increased neutron flux that could affect the thickness needed for the concrete overpack 

to reduce the neutron flux near the dry cask storage system. Based on Table I-2, highburnup fuel *:G078DIWHr 60 years of decay has a neutron flux similar to 

30 GWd/MTU fuel after approximately 1\HDUVRIGHFD\

Table I-1. Dependence of decay heat (kW/MTU) on burnup and decay time for UOX fuel 

Decay Time 

Burnup 

30 GWd/MTU 

Burnup 

45 GWd/MTU 

Burnup 

55 GWd/MTU 

Burnup 

70 GWd/MTU 

\HDUV 1.6 kW/MTU 2.3 2.8 

\HDUV 0.9 1.3 1.6 2.2 

60 years 0.4   0.9 

200 years 0.2 0.2 0.2 0.3 

Source: IAEA 2011. Values are estimated from Figure 13 of the report. 

Table I-2. Dependence of neutron emission on burnup and cooling year for UOX fuel 

Decay Time 

Burnup 

30 GWd/MTU 

Burnup 

45 GWd/MTU 

Burnup 

55 GWd/MTU 

Burnup 

70 GWd/MTU 

\HDUV  0.6 0.9 1.4 

\HDUV 0.2 0.4 0.6 1.0 

60 years 0.01 0.1  0.2 

200 years NS NS NS NS 

Source: IAEA 2011. Values ZHUHHVWLPDWHGIURP7DEOHRIWKHUHSRUW

Neutron emissions in Giga neutrons per second per metric tons of uranium (Gn/s/ MTU). 

NS = not significant. Values were too small to determine from Figure (i.e., <0.01). 
Appendix I 

September 2014 I- 185(*௅

Q. How do degradation processes affect storage of high-burnup spent fuel? 

A. As storage times have increased, so has interest in improving the understanding of 

degradation mechanisms that affect spent fuel as it is stored. Recent reports have identified 

a variety of degradation mechanisms and discussed the potential effects on storage (e.g., 

NRC 2012, Hanson et al. 2012, IAEA 2011, and Sindelar et al. 2011). 

The mechanical integrity of the spent fuel cladding and assembly is important for ensuring 

that handling and transportation of spent fuel can be conducted with relative ease. The 

mechanical designs of lower-burnup UOX fuel and higher-burnup UOX and MOX fuel are 

very similar, but some of the after-irradiation properties of higher-burnup UOX and MOX fuel 

are potentially significant in determining the rate of degradation or differences in 

performance. Examples of the differences in after-irradiation properties between lowerburnup UOX fuel and higher-burnup UOX and MOX fuel include higher fuel rod internal 

pressures and thinner cladding due to more cladding oxidation and hydride layer buildup 

causing higher cladding stress; higher decay heat; higher specific activity; and finer grain 

structure of the fuel pellet, which potentially would increase the source term in the event of 

an accident. 

The IAEA has provided a useful perspective on the impact of degradation processes for 

both wet and dry storage systems: 

“Because wet storage is associated with low temperatures, cladding degradation is 

expected to be low. High-burnup UOX and MOX storage will increase the heat load, and 

potentially radioactive releases. This may require an upgrade of the pool facility with 

respect to heat removal and pool cleanup systems, and additional neutron poison 

material in the pool water or in storage racks. Re-evaluation of criticality and regulatory 

aspects may also be required. In dry storage and transportation, the cask has to provide 

safe confinement/containment. In parallel, the decay heat has to be removed to limit 

temperature induced material alterations. Thus, dry storage is more sensitive to 

increased UOX burnup and MOX use than wet storage because of higher temperatures 

resulting in higher stresses on the cladding. The ability to meet applicable regulatory 

limits will need to be re-evaluated for higher burnup UOX and MOX on a case by case 

basis. Sub-criticality during transportation has to be ensured even under accident 

conditions, such as, for example, cask drop. Higher burnup fuel may have significantly 

more hydrogen in the cladding and structure and, thus, reduced ductility. Since MOX fuel 

has a similar design to UOX fuel, its mechanical behaviour should not be different. The 

result of these evaluations for storage and transportation may require a redesign of the 

cask heat removal and shielding systems, redesign of the structural support for the spent 

fuel assemblies, a decrease in the number of spent fuel assemblies that can be placed 

into a single storage cask, and an increased decay time in the pool prior to placement in 

dry storage.” (IAEA 2011)
Appendix I 

185(*௅ I-6 September 2014 

The NRC continues to follow international and national efforts on degradation mechanisms, 

and is conducting its own, NRC-funded studies to ensure that its understanding of these 

processes is sufficient and to use the increasing information and operational experience with 

storage, handling, and transportation of spent fuel to confirm the adequacy of or make any 

necessary changes to the regulatory framework. 

Q. Can high-burnup fuel be transported? 

A. Yes. The NRC has certified transportation packages for the transport of spent fuel, and 

some of these packages have been authorized to carry high-burnup fuel. The NRC 

approves designs only after a full safety review. Based on these reviews, the NRC has 

certified package designs to transport high-burnup fuel currently in storage at ISFSIs 

including, for example, the NAC-UMS, HI-STAR 100, and MP-Transportation of spent 

fuel would be accomplished in accordance with NRC regulations (i.e., 10 CFR Parts 20 and 

DQGDSSOLFDEOHU.S. Department of Transportation requirements. A list of NRC-certified 

storage casks and transportation casks for high-burnup spent fuel is provided in 

Appendix G. 

Q. Is the NRC doing any research on high-burnup fuel? 

A. Yes, the NRC has a number of recently completed or in-progress research projects on highburnup fuel. 

1) Effects of hydride reorientation on the ductility of the cladding. This recently competed 

project conducted at Argonne National Laboratory, showed that, hydride reorientation 

will occur to some extent under many conditions of storage, with the degree depending 

on the cladding material, cold work, stress, hydrogen content, and maximum 

temperature. The research indicated that, if the cladding remains above the ductile to 

brittle transition temperature, it should be ductile. Below that temperature, the cladding 

must be considered to be potentially brittle. The U.S. Department of Energy (DOE) is 

continuing this research. 

2) Effects of transportation vibrations on the integrity of high-burnup fuel cladding. 

Preliminary results from this research project, being conducted at Oak Ridge National 

Laboratory, shows that Zircaloy-4 cladding of high-burnup fuel should not fail under 

normal transportation road or rail vibration loads. This research is expected to be 

completed in 2014, then will be continued by the DOE on other fuel rod cladding 

materials. 

3) Stress loads on the cladding. While stress due to gases in the high-burnup fuel rods has 

been shown to be insufficient to cause a thermal low-temperature creep or delayed 

hydride cracking, stress also could be exerted by swelling of the pellets over time due to 
Appendix I 

September 2014 I- 185(*௅

the internal generation of helium due to fission product decay. Laboratory studies have 

shown this would not be expected to occur until after 100 years of storage. The NRC is 

conducting an evaluation on the potential cladding stress due to pellet swelling to 

determine if further research is necessary to rule this out as a plausible degradation 

mechanism. 

While all available data has shown that high-burnup fuel can be safely stored, the NRC is 

following the cask demonstration project, which will look for early signs of fuel degradation. 

The NRC will independently evaluate data obtained from this DOE demonstration so it is in 

a position to make changes to its regulatory framework, if necessary. 

Q. How is high-burnup fuel considered in the GEIS? 

A. The environmental impacts described in the GEIS do not require separate consideration of 

high-burnup fuel because the unique characteristics of high-burnup fuel are not a factor in 

environmental impact assessment for the resource areas considered. 

As discussed in Section 2.1.1.3, the use of high-burnup fuel could create less spent fuel 

than a facility that uses low-burnup fuel, while providing the same energy output. Therefore, 

for most resource areas evaluated in the GEIS, the impacts of storing high-burnup fuel 

would be the same as or slightly less than the impacts associated with storing low-burnup 

fuel. This is primarily because storing less spent fuel would require less land. This result is 

consistent with earlier published analyses of the environmental effects of high-burnup fuel 

(Ramsdell et al. 2001) that included the impacts from handling accidents, transportation, and 

onsite storage in support of environmental assessments of operating nuclear power plants. 

References 

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

Protection Against Radiation.” Washington, D.C. 

&)53DUWCode of Federal Regulations, Title 10, Energy3DUW3Packaging and 

Transportation of Radioactive Material.” Washington, D.C. 

&)53DUWCode of Federal Regulations, Title 10, Energy, 3DUW3/LFHQVLQJ

Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive 

Waste, and Reactor-Related Greater than Class C Waste.” Washington, D.C. 

Hanson, B., H. Alsaed, C. Stockman, D. Enos, R. Meyer, and K. Sorenson. 2012. Gap 

Analysis to Support Extended Storage of Used Nuclear Fuel Rev. 0. U.S. Department of 

Energy Report No. FCRD-USED-2011-000136 Rev. 0, Richland, Washington. Available at 

http://energy.gov/sites/prod/files/Gap%20Analysis%20Rev%200%20Final.pdf. 
Appendix I 

185(*௅ I-8 September 2014 

IAEA (International Atomic Energy Agency). 2011. Impact of High Burnup Uranium Oxide and 

Mixed Uranium–Plutonium Oxide Water Reactor Fuel on Spent Fuel Management. IAEA 

Nuclear Energy Series No. NF-T-3.8, Vienna, Austria. Available at http://wwwpub.iaea.org/MTCD/Publications/PDF/Pub1490_web.pdf. 

National Environmental Policy Act of 1969 (NEPA), as amended. 42 USC 4321 et seq. 

NRC (U.S. Nuclear Regulatory Commission). Standard Review Plan for the Review of 

Safety Analysis Reports for Nuclear Power Plants: LWR Edition. NUREG-800, Revision 2, 

Washington, D.C. Accession No. ML. 

NRC (U.S. Nuclear Regulatory Commission). 2012. Identification and Prioritization of the 

Technical Information Needs Affecting Potential Regulation of Extended Storage and 

Transportation of Spent Nuclear Fuel: Draft Report for Comment. Washington, D.C. Accession 

1R0/

Ramsdell, J.V., Jr., C.E. Beyer, D.D. Lanning, U.P. Jenquin, R.A. Schwarz, D.L. Strenge, P.M. 

Daling, and R.T. Dahowski. 2001. Environmental Effects of Extending Fuel Burnup Above 60 

GWd/MTU. NUREG/CR-, Pacific Northwest National Laboratory, Richland, Washington. 

Accession No. ML010310298. 

Sindelar, R.L., A.J. Duncan, M.E. Dupont, P.-S. Lam, M.R. Louthan, Jr., and T.E. Skidmore. 

2011. Materials Aging Issues and Aging Management for Extended Storage and Transportation 

of Spent Nuclear Fuel. NUREG/CR–Savannah River National Laboratory, Aiken, South 

Carolina. Accession No. ML11321A182. 

Transnuclear Inc. 2009. Technical Specifications: TransNuclear Inc. Standardized NUHOMS 

Horizontal Modular Storage System Certificate of Compliance No. 1004, Amendment No. 10. 

'RFNHW-1004, Columbia, Maryland. Accession No. ML092290186. 
BIBLIOGRAPHIC DATA SHEET

6HHLQVWUXFWLRQVRQWKHUHYHUVH

NRC FORM 335

(12-2010)

NRCMD 3.7

U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

(Assigned by NRC, Add Vol., Supp., Rev.,

 and Addendum Numbers, if any.)

3. DATE REPORT PUBLISHED

MONTH YEAR

4. FIN OR GRANT NUMBER

2. TITLE AND SUBTITLE

5. AUTHOR(S) 6. TYPE OF REPORT

7. PERIOD COVERED (Inclusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U. S. Nuclear Regulatory Commission, and mailing address; if 

 contractor, provide name and mailing address.)

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, type "Same as above", if contractor, provide NRC Division, Office or Region, U. S. Nuclear Regulatory 

 Commission, and mailing address.)

10. SUPPLEMENTARY NOTES

11. ABSTRACT (200 words or less)

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.)

14. SECURITY CLASSIFICATION

13. AVAILABILITY STATEMENT

unlimited

7KLV3DJH

unclassified

7KLV5HSRUW

unclassified

15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (12-2010)

NUREG-2157, Volume 1 

FINAL

Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel - Final 

Report and Public Comments September 2014

U.S. NRC

Technical

Waste Confidence Directorate 

Office of Nuclear Material Safety and Safeguards 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001

Same as above

This Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel (GEIS) examines the potential 

environmental impacts that could occur as a result of the continued storage of spent nuclear fuel at at-reactor and away-from-reactor 

sites until a repository is available. For the resource areas considered, this GEIS attempts to establish generic impact determinations 

that would be applicable to a wide range of existing and potential future spent fuel storage sites. While some site-specific 

information is used in developing the generic impact determinations, the NRC does not intend for this GEIS to replace the NEPA 

analysis associated with any individual licensing action. This GEIS makes maximum use of existing environmental impact 

determinations, site-specific data, publicly available literature, and public comments received. 

This GEIS evaluated alternatives to the proposed action, including options under the no-action alternative (site-specific licensing 

review, a GEIS-only option, and a policy statement). The proposed action would have the same potential environmental impacts as 

any of the alternatives evaluated. However, as shown in quantitative analysis of costs, the cost for the proposed action is less than the 

cost for any of the alternatives. 

EIS, GEIS, environmental impact statement, NEPA, national environmental policy act, waste confidence, 

waste confidence decision, waste confidence rule, continued storage


UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

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OFFICIAL BUSINESS
NUREG

-2157, Vol. 1

Final

Generic Environmental Impact Statement for 

Continued Storage of Spent Nuclear Fuel